While I have recently joined this discussion group, I have not as yet participated in the discussions. However, as this discussion on GHS unfolded, I reached out to several of our SDS and Label Authoring Registered Specialists to ask them for some thoughts on the discussion. They offered this perspective…
HMIS and NFPA ratings were not intended for shipping containers. The original intent was solely in-house labeling. Neither NFPA nor HMIS use chronic health hazards like carcinogenicity or reproductive toxicity for the health hazard rating. Since the NFPA and HMIS have LD50 criteria for their acute toxicity ratings, you could certainly have a better break-down than 1 – 2 or 3 - 4.
Likewise, the GHS was not designed for transportation hazards; GHS was developed for all chemicals. It uses transportation hazards for physical properties but includes health and environmental hazards that were never covered by transport regulations or placarding requirements. The GHS basically unites transportation and workplace hazard communication.
On the topic of the exclamation mark: it is only for low level health hazards. Other hazards -- such as flammable, oxidizers, and acute toxicity hazards -- are very easily understood across the room. The HazCom pictograms are almost all transport pictograms. A “4” would be inappropriate for a chronic hazard (as those are not covered by NFPA at all and are covered by the * for HMIS).
Mary Ann Latko,
CAE CIH CSP QEP
AIHA Registry Programs(R)
Direct +1 703.846.0786 | Office +1 703.846.0755 | Fax +1 703.207.8558 | www.aiharegistries.org
3141 Fairview Park Drive, Suite 777, Falls Church, VA 22042 USA
Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of paracelcusbombastusvon**At_Symbol_Here**juno.com
Sent: Tuesday, February 18, 2014 3:16 PM
Subject: Re: [DCHAS-L] GHS Classification vs NFPA/HMIS
Having just been to a DOT transportation seminar (by DOT) the confusion is great with no short term end insight. NFPA is for fire fighters and fire marshals (the twain do not always talk or agree) where as GHS is for OSHA in your facility and DOT is for transportation between facilities. If you really want to confuse the issue try transportation via water (USCG rules) or by air (IATA and FAA rules). Just another example of government SNAFU.
---------- Original Message ----------
From: Daniel Crowl <crowl**At_Symbol_Here**MTU.EDU>
Subject: Re: [DCHAS-L] GHS Classification vs NFPA/HMIS
Date: Tue, 18 Feb 2014 10:49:02 -0700
The problem arises from the fact that the NFPA numbers are really designed for firefighters during an emergency fire situation. The GHS system is designed for transportation hazards.
I don't think the two can be unified since the design basis is different.
I prefer the NFPA system because it is easy to recognize and I'm too old to change.
Michigan Tech University
On Tue, Feb 18, 2014 at 10:22 AM, Hopkins, Ron <Ron.Hopkins**At_Symbol_Here**eku.edu> wrote:
I have presented several GHS presentations and from my analysis of the degree of hazard, I have equated the exclamation mark would come closer to being a 1 or 2 based on the hazards:
The only one that causes some issues for me is how to quantify "Acute Toxicity" with the modifier (harmful). Key to the numerical value that you would like to utilize, the specific product has to be included in the decision process.
Now, looking at Health Hazard and the terminology used in that category:
Based on the terminology used in this category, I would utilize 3 or 4. Again, the specific product would still have to be considered.
Then, the skull and crossbones, I think that would be a 4.
Lastly, I am not sure that an employer could not utilize some of the components of the NFPA/HMIS system in the warning process. OSHA standards only identify the minimum requirements. If you labeling system contains all of the items prescribed by OSHA, the employer can always opt for a system that exceeds the minimum.
Just a different thought and perspective.
From: DCHAS-L Discussion List
<dchas-l**At_Symbol_Here**MED.CORNELL.EDU> on behalf of Williams, Mark <Mark.Williams**At_Symbol_Here**TELEDYNEES.COM>
Sent: Tuesday, February 18, 2014 9:52 AM
Subject: [DCHAS-L] GHS Classification vs NFPA/HMIS
Hello DCHAS Members,
I have just given our second GHS Haz Comm training and the discrepancy between the numerical GHS hazard classification system and that of NFPA/HMIS is fresh in my mind.
I regard this as a noteworthy tragedy because having at our disposal an instantly accessible, “visible across the room”, numerically quantified shorthand that gives us a quick reference for degree of hazard is a really good idea, and GHS has sort of put a torpedo in the NFPA/HMIS label without supplying a good alternative.
For the near term we might get away with continuing to use NFPA or HMIS stickers on container labels because the GHS classification categories do not appear there, so potential for confusion might be small, however as workers become increasingly GHS sophisticated, the potential for confusion will increase quickly and become untenable in the very near future. Perhaps it already is. Certainly including NFPA/HMIS on the SDS is a source of confusion.
In a severely limited sense, the GHS pictograms do give a sort of tiered “visible across the room” semi-quantified shorthand to degree of hazard. The exclamation mark could be considered a 4 but it gives no indication of what the hazard is, and the presence of another pictogram could indicate a 3, 2 or 1, but with no further indication of degree of hazard. Extremely deficient!
The ideal solution in my view would be for NFPA and HMIS to withdraw from the fray, and to convert the GHS pictograms to a numerically tiered system by including the classification category at the bottom of each pictogram similar to the DOT label style. A 4 on the pictogram would take the place of the exclamation mark which would no longer be needed (and wasn’t that good of an idea to start with). The only pictogram that would need to be modified is the chronic toxicity pictogram as all the rest already have room for a number.
Less ideal, only because it unnecessarily introduces another label element, would be for NFPA and HMIS to change their numbering to the GHS system.
Even better would be to consolidate transportation and Haz Comm pictograms which would eliminate another source of confusion. Call me a dreamer J
I am interested in what others think about this issue.
Teledyne Energy Systems, Inc.
38 Loveton Cir.
Sparks, MD 21152
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