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Subject: Re: [DCHAS-L] GHS P codes question
Date: Thursday, August 3, 2017 at 3:02:59 PM
Author: Harry J. Elston <helston**At_Symbol_Here**MIDWESTCHEMSAFETY.COM> 		Next by Date:
Subject: Re: [DCHAS-L] GHS P codes question
Date: Thu, 3 Aug 2017 15:01:18 -0500
Author: Nicole Shoshenskiy

From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
Subject: Re: [DCHAS-L] GHS P codes question
Date: Thu, 3 Aug 2017 15:28:50 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 6BD7EB0C-665A-47C3-9C69-7F66457B4506**At_Symbol_Here**ilpi.com
In-Reply-To


See Appendix C here: http://www.ilpi.com/msds/osha/1910_1200_APP_C.html  The tables list the hazard and precautionary statement wording that is required based on each classification.  Harry is correct; HazCom does not reference (and presumably therefore, does not require) the P-numbers.  Your SDS and label should contain, for example, the explicitly written statement, "Keep only in original container" rather than simply "P234", although there is no harm/foul in listing the number in addition to the text.  Honestly, I hate all numbers and since the words associated with numbers could theoretically change in the future and folks might try to memorize them and rely on that; I would avoid them altogether.  Don't even get me started with the 1-4 scale in GHS being opposite to the 0-4 in NFPA and HMIS...

The specific precautionary text requirements are listed at www.ilpi.com/msds/osha/1910_1200_APP_C.html#C.2.4

Note that is permissible to combine precautionary or hazard statements on a *label* under certain circumstances, but this would not be acceptable on an SDS.  See http://www.ilpi.com/msds/osha/I20141110.html  And also www.ilpi.com/msds/osha/1910_1200_APP_C.html#C.2.6 for a discussion of "ranking" statements on labels.

Rob Toreki

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On Aug 3, 2017, at 3:02 PM, Harry J. Elston <helston**At_Symbol_Here**MIDWESTCHEMSAFETY.COM> wrote:

The required P-codes are a direct correlation from the classification of the material.  The correspondence is found in the Purple Book from the UN or in Appendix C of 29CFR1910.1200 "Allocation of Label Elements" although HAZCOM does not list "P-NNN" - it just gives the words and the user needs to make the correlation.

Harry

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On Thu, Aug 3, 2017 at 1:54 PM, Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**keene.edu> wrote:
A GHS question for those with more experience than I at writing SDS's:

Are the Precautionary codes associated with a chemical determined on a case by a case basis or are they the same for all chemicals with the same combination of GHS Hazard codes?

Thanks for any information on this.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859

ralph.stuart**At_Symbol_Here**keene.edu

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