Correct. There's no real discretion once the chemical is classified. The place for "judgement" or more accurately bias, is in the classification itself. It's pretty straightforward for physical hazards, but for chronic health hazards like carcinogenicity the GHS takes a "weight of the evidence" approach that can lead to mischief. The former OSHA Hazcom standard, in contrast, required classification with respect to a hazard based on "one positive, well-conducted study." Full disclosure - I was on the tripartite ILO steering committee that worked on the GHS. We had a pretty serious fight over this, but the EU, most other countries and of course industry wanted "weight of the evidence" classification, and we lost. The result is that we are now seeing GHS-compliant SDS's with all the proper H and P code phrases and pictograms, but which classify the same chemical differently. In fact, we've seen different classifications for the same chemical from the same company depending on whether the SDS was prepared for use in the USA, EU, Japan or Korea.
This is not a big problem in the USA, because our tort system makes it foolish not to classify a chemical as a carcinogen or mutagen if there is a single good positive study. But it's a problem elsewhere.
Forgive me for venting on this subject. Overall I think the GHS is a great step forward. It's made SDS's comprehensible to workers and opened the possibility of right-to-know in many countries that were never going to create a system on their own. But I'm still bugged by the looseness and potential bias in classifying chemicals for chronic health hazards.
Michael J. Wright
Director of Health, Safety and Environment
"My friends, love is better than anger. Hope is better than fear. Optimism is better than despair. So let us be loving, hopeful and optimistic. And we'll change the world."
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU]
On Behalf Of Harry J. Elston
Sent: Thursday, August 03, 2017 3:03 PM
Subject: Re: [DCHAS-L] GHS P codes question
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.
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 Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
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