The US-required classification procedures are codified in 29 CFR 1910.1200, the OSHA Hazard Communication Standard, Appendices A and B, but a cursory glance doesn’t mention ordering:
http://ilpi.com/msds/osha/
ANSI has its own standard, Z400.1, which was incorporated into the GHS but you have to pay to get those, so I have no idea if it mentions ordering.
The HazCom standard is based on the US’s implementation of the GHS model standard, of course. This is the version HCS 2012 was based on:
https://unece.org/ghs-rev3-2009 Annex 3 is “Codification of hazard statements, codification and use of precautionary statements and examples of precautionary pictograms” and states (only for labels):
A3.1.2.4 All assigned hazard statements should appear on the label unless otherwise specified in 1.4.10.5.3.3. The competent authority may specify the order in which they appear. Also, where a combined hazard statement is indicated for two or more hazard statements, the competent authority may specify whether the combined hazard statement or the corresponding individual statements should appear on the label, or may leave the choice to the manufacturer/supplier.
However, Annex 4, “Guidance on the preparation of safety data sheets (SDS)” is silent on putting those in order.
I think the silence is deliberate, especially when we note the word “choice” in the quote above. While putting them in numerical/alphabetical order is aesthetically pleasing and resonates with those who like order, there may be instances in which a particular manufacturer may want a particular hazard or precaution to stand out by listing it first, something that would be defeated by a rigorous alphabetical/numerical requirement. For example, while some of us might think flammability should be first, maybe that’s a lower likelihood than skin contact for a particular product being used in a particular way. So a toxic substance with DMSO as the solvent might be a good example.
Best wishes,
Rob Toreki
Safety Emporium - Laboratory and Safety Supplies https://www.SafetyEmporium.com
esales**At_Symbol_Here**safetyemporium.com or toll-free: (866) 326-5412
Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
On Aug 30, 2023, at 1:36 PM, Nora Dunkel <noradunkel51**At_Symbol_Here**WEBSTER.EDU> wrote:
Does anyone know how SDS writers determine the order in which hazard and precautionary statements appear? I’m working on an inventory/SDS update project, and have run into many situations where two products (mainly paints) have the same precautionary and hazard statements, just listed in different orders. For example, many cans of spray paint list flammability as the first hazard, but occasionally flammability is beneath 3-5 other warnings, such as skin irritation, reproductive toxicity, CNS depression, etc. It seems random, but is there a system for ranking the hazards within an SDS?
Thanks,
Nora Dunkel, CHMM
Chemical Safety Officer
Webster University
Office: Browning Hall/ISB 314
314-246-2244 (desk)
