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The HazCom Standard requires Hazard Statements and Precautionary statements on labels, per paragraph (f) of the Standard: http://www.ilpi.com/msds/osha/1910_1200.html#1910.1200(f)
Appendix D of the Standard requires their use on SDS’s: http://www.ilpi.com/msds/osha/1910_1200_APP_D.html
Appendix C does incorporate the written code meanings, but not the codes http://www.ilpi.com/msds/osha/1910_1200_APP_C.htmlSo, yes, you are correct, there is nothing in HCS 2012 that actually references the GHS codes associated with these.
As to why, there may be something in the public comments or comments on the final rule about it, but I would suspect that someone shared the same concern I have about code numbers - why have them? Why not just write what it means? Who is going to remember that P271 means use only outdoors or in a well-ventilated area? Heck, I have enough issues with using numbers 1-4 for NFPA and in HCS (but with the scale running the opposite way).
More importantly, I suspect there was concern that revisions of the GHS may change the meaning of the code numbers, perhaps adding or subtracting required elements. Which would then put the HCS code word meanings out of synch with the GHS until the next revision of the HCS (and it will be many years before that happens again). That would cause serious confusion. Just another reason for saying what you mean in the first place!
PS: Lists of codes here in case people don’t know what we’re talking about:
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On Dec 8, 2016, at 9:39 AM, Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU> wrote:
Someone asked me the other day if the Hazard Statement codes (H220, etc.) are part of OSHA's HazComm standard. As far as I can tell, they aren't and US SDS's don't include them. Am I correct in this? Anyway know why they might not be included in the US?
Thanks for any help with this question.
Ralph Stuart, CIH, CCHO
Chemical Hygiene Officer
Keene State College
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