From: "Shoshenskiy, Nicole" <nshoshenskiy**At_Symbol_Here**MSDSONLINE.COM>
Subject: Re: [DCHAS-L] Avery GHS Label Wizard
Date: Wed, 10 Feb 2016 19:43:05 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: C14222A5D2E37D4F88C6E6DF3465DB9D920E94FB**At_Symbol_Here**
In-Reply-To <148F1DE2-4F1A-4242-A450-5CBE446F2554**At_Symbol_Here**>

This is very interesting! I'd be curious as to where they are deriving GHS classifications for single CAS numbers as well. Most of the 3rd party databases do not contain the registered classifications under ECHA which have data tied to them for validation.

Like Ralph and the case of nitric acid, I also tried to poke some holes in the "wizard" by testing it out on a substance that has variable classifications based on physical state and or dilution, formaldehyde. I neglects to bring in at all toxic in contact with skin, it downgrades oral toxicity and leaves out mutagenicity altogether so it's clear they are not pulling data from ECHA harmonized classifications nor does the classification match the LOLI database classification either. Additionally it classifies it as a flammable liquid, but this is % in solution dependent so that classification will not always apply. Why is there no place to enter a flashpoint and boiling point? Its flammability classification depends entirely on % in aqueous solution. I would not trust their data at all. Additionally, It looks like they adopted the purple book as a whole and not HCS 2012. I tried the CAS number for cellulose which is a known combustible dust and it had no data to pull!
into the label. I didn't see HNOC even available to pull into the label manually. I wonder how they are handling HNOCs as well as those hazards separated out by OSHA from the HNOC category, pyrophoric gases, simple asphyxiants and combustible dust with respect to precautionary phrases? They are not available in the "wizard" for selection.

Anyone else have any fun with it?

Nicole Shoshenskiy
Regulatory Analyst, Authoring Services
ACS Chicago Chapter, Secretary 2015 & 2016

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**] On Behalf Of Stuart, Ralph
Sent: Wednesday, February 10, 2016 12:13 PM
Subject: [DCHAS-L] Avery GHS Label Wizard

It's not clear where their automatic GHS designations (based on CAS numbers) come from at this Avery site (for example, their nitric acid label doesn't include an "oxidizer" or "irritant" designation), but it's interesting to see that Avery is breaking into the GHS label market...

They note that "Did you know? You are responsible for assuring the accuracy of your GHS and Safety Labels"...

- Ralph

> Select "Start GHS wizard" on the size/type you want:


Ralph Stuart, CIH, CCHO
Chemical Hygiene Officer
Keene State College


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