OSHA HCS 2012 does not include the GHS hazard statement codes, the precautionary statement codes or the pictogram codes. However, OSHA does not prohibit including the hazard statement and precautionary statement codes on HCS 2012 SDSs along with the required text.

Per the GHS, these GHS codes are intended for reference purposes only. The GHS hazard statement and precautionary statement codes not part of the hazard/precautionary statement text and should not be used to replace it. While the codes may be useful in language translation situations, their main purpose is for example to be used in computer programing the GHS information. The GHS pictogram code is not part of the pictogram and should not appear on labels or in section 2 of the SDS.

As you mention, these GHS codes do not help in understanding the hazards or the precautionary measures for the chemical, as the actual hazard and precautionary statement text and pictograms do. For example just using the code H220 or P210 does not provide helpful information to the user of the chemical product and is not the intent of the GHS.

Michele Sullivan, Ph.D.

> I would suspect that someone shared the same concern I have about code numbers - why have them?  Why not just write what it means? 

The person who raised the question with me is in the process of mining GHS information to organize it into more useful safety information about departmental chemical inventories. When writing computer code for this purpose, the H codes are easier to work with than the whole phrase. As other people indicated, Sigma-Aldrich includes them on their SDS's, so I hadn't noticed that many US SDS's don't have them.

I agree that, in general, human to human communication is best done in plain English rather than codes, but humans are not the only ones involved in 21st Century communication. ;)

Thanks to everyone for their response on this topic.

- Ralph

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

ralph.stuart**At_Symbol_Here**keene.edu

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