From:
Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject:
Re: [DCHAS-L] [DCHAS-L] EXTERNAL EMAIL: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.
Date:
May 28, 2021 22:17 UTC
Reply-To:
Monona Rossol
In-Reply-To:
Re: [DCHAS-L] [DCHAS-L] EXTERNAL EMAIL: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.
Well, I might as well weigh in. I LOVE the new category numbering system because it is consistent with so many other European standards. It is our NFPA and other systems that I think are the outliers. Did you REALLY like the NFPA flammability standards? Those would cross a Rabbi's eyes. Give me plain old GHS 1,2,3,4.
And the pictograms are just an initial alert. Students just need to know they indicate you are not done until you read the rest.
Remember that the Purple books were developed by people from many countries including ours. We didn't see any of this as important until the EU gave us until June, 2015 to adopt the GHS or stop exporting to them. And by then, 162 other countries agreed. Our really useless MSDSs were the cause and someone finally call us out. And we got to see the first major change in an OSHA regulation done without 20 years of hand-to-hand combat between worker advocates and industry.
I love GHS (except for the weight of evidence on cancer rating) Monona
-----Original Message-----
From: Mayo, Bret <0000134e357a2939-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Fri, May 28, 2021 3:14 pm
Subject: Re: [DCHAS-L] [DCHAS-L] EXTERNAL EMAIL: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.
I think you hit the nail on the head below when you said, "- it all comes down to training." These students are required to take a training class that combines HazCom and GHS (one of several training modules they must complete) before
they are ever allowed access to a lab. Clearly, some of the key concepts and definitions were missed, so we have a good bit of work to do to figure out why that happened and how to fix it. It was nevertheless frustrating to me that they chose to make important
decisions based on cartoons instead of safety statements, SDS's, consulting with their Principal Investigator, or any of the myriad other available resources.
By the way, I am totally with you on the numbering system issues, too.
Bret
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of ILPI Support
Sent: Friday, May 28, 2021 9:21 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] [DCHAS-L] EXTERNAL EMAIL: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.
"Able to burn or corrode organic tissue by chemical action"
"Capable of destroying or eating away by chemical action : CORROSIVE"
"Any chemical substance that burns or destroys living tissue"
"Capable of burning, corroding, dissolving, or eating away by chemical action"
But from an EHS/waste perspective caustic refers specifically to alkaline or basic materials. Obviously, the correct way to address this would be to use the pH definitions instead - acidic and basic instead of using terms that can be easily
confused with each other. That's one reason the NFPA came out against the word, "inflammable", which, while completely valid and equal to "flammable", confused a lot of people who figured it must mean "not flammable."
In the end, however, it all comes down to training. Incidents like this are great at showing us what we need to train better, and think of ways to make sure the message stays such as posters, charts etc.
My biggest GHS gripe is that the numbering system is completely backward from most other ranking conventions. In the NFPA/HMIS systems a higher number means a higher hazard, third degree burns are more serious than first degree etc. etc.
But for GHS hazard classification, a low number is the higher hazard.. Mind you, the whole idea of using numbers or symbols instead of (or in conjunction with) words is just insane.
