Previous by Date: Subject: Re: [DCHAS-L] GHS and NFPA query Date: Saturday, October 18, 2014 12:47:13 PM Author: Jim <jchem56**At_Symbol_Here**AOL.COM>
I love this thread. Thanks for starting it! There has been much confusion over keeping NFPA and HMIS with the new GHS labeling system.. This topic is of particular interest to me as a hazard communicator in balancing the differing systems in two arenas,
Safety Data Sheets and labeling.
It is worth noting that HMIS and NFPA are industry organizations and not competent authorities in the true regulatory sense. Further, that their respective systems serve different purposes, primarily for Emergency Response and crafted with their specific
industries in mind and so not all aspects of chemical hygiene and safety are encompassed in their guidance systems, as a prior poster noted. In my humble opinion, best chemical hygiene practices in a non-emergency response situation, the OSHA guidance should
prevail.
NFPA will only convey the hazards of the material as it is would be in a fire or spill situation and therefore inadequate for sole labeling in a non-emergency situation especially considering the newest classification schema under GHS. The GHS workplace
label under OSHA would offer the most coverage in my opinion and should they conflict in messaging, they should be not only delineated but a training issue addressed with all expediency should you choose to retain both systems.
I agree with your statement making sure lab staff understanding what chemicals they dealing with suggestions; but include the staff that transport the chemicals within the organization and/or agency.
As a precautionary procedure, I rather have laboratory personnel supervised location storage when non-lab personnel move or store chemical shipments.
The NFPA or HMIS labels, or something from another "competent authority" are for workplace containers you transfer chemicals to. But you're right, you don't need that if you're using the original
distributor's labeling.
In my opinion the NFPA and HMIS labels are basically a courtesy for fire fighters.
One problem with just using those pictogram placards is you still have to be careful about the corrosives, because it doesn't distinguish between acids and bases - or even that DOT quarter-inch
steel corrosive definition that has nothing to do with pH. So if somebody's not careful and sorts chemicals solely based on the pictograms, they just might put all the acids and bases in the same cabinet. So you have to make sure everybody in the lab understands
that, and exactly what those chemicals are that they're dealing with.
The NFPA labeling might no longer be required. From a Hazardous Materials Technician level (completing this in Oct.) I would use that placard as fist line if identification. Any ideas as to why it might not be required?
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