The previous management regime was already complex enough, requiring organisations that use hazardous chemicals to interpret a complex array of information from Health and Safety legislation, Dangerous Goods Legislation, Safety Data Sheets (SDSs), seemingly endless Australian Standards and the 1200 odd pages of the Australian Dangerous Goods Code. In this context, it's hardly surprising that many organisations struggled to navigate their way through the complexity and even less surprising that the GHS, with new information and jargon, didn't help.
But the problem isn't only the GHS. For all the changes, those that already had well-functioning programs to manage hazardous chemicals would've felt little more than a bump in the road. Those struggling to come to terms with the new regime, were very likely struggling under the old one to properly manage chemical risks; from understanding the hazards and controlling the risks to meeting the various compliance requirements such as notification, maintaining a manifest and ensuring suitable fire protection measures.
Some of the common areas where performance is often below par includes:
- Misunderstanding what GHS is and how to interpret information within SDSs
- Using generic information within SDSs as specific instruction on safe chemical handling.
- Overlooking the hazards within chemical storage areas
- Compliance with placarding, notification and manifest requirements
Over a series of blog posts Verus will pull apart hazardous chemical management concepts as a way of highlighting how to improve performance in the areas above. This week we start with "Interpreting GHS Information."
Interpreting GHS Information
For manufacturers, suppliers and importers of hazardous chemicals GHS introduced a single universal system to classify and label chemicals they made, imported and supplied that streamlined the effort required. Instead of having to evaluate and classify a chemical each time it was to be made, imported or supplied in a different country, GHS enabled each chemical to be evaluated and classified just once, knowing that the classification can be used anywhere GHS was adopted. The universal GHS classification system also allowed SDSs and warning labels to be standardised. But by eliminating the previous classification systems, and the various terminology used to describe a chemical's properties, end users were left in the dark about how to interpret the information.
Under the old Australian based regime, Material Safety Data Sheets (MSDSs) would outline which products could result in chronic impacts (classified as hazardous) and those which could result in acute impacts (classified as a dangerous goods). Chemicals with acute and/or chronic impacts needed their use and handling assessed, whilst only those with acute impacts (ie those classified as dangerous goods) needed an assessment of storage.
With GHS and corresponding WHS legislation eliminating these and complimentary terms, this method can no longer be used. Instead, SDSs must be interrogated to find out hazard classes, hazard categories, signal words, pictograms, hazard statements and precautionary statements in order to understand the type and scale of hazard posed by the chemical. With little comprehensive guidance to help the end user translate the old language to the new, the transition to GHS hasn't been smooth sailing.
A comparison of some of the new and old terms is outlined below.
|New Terminology||Definition||Comparison to Old Terminology|
|Hazard Class||The nature of the physical, health or environmental hazard, e.g. flammable solid, carcinogen, oral acute toxicity.||Similar to dangerous goods classes, however Hazard Classes are also defined for any Hazardous Chemical, including those that only have chronic impacts, which was generally outside of the previous dangerous goods class definitions.|
|Hazard Category||The division of criteria within each hazard class, e.g. flammable liquids includes four hazard categories. These categories compare hazard severity within a hazard class, ie a Flammable Liquid Category 1 is more flammable that a Flammable Liquid Category 2, 3 or 4.||Similar to packing groups used to further classify how dangerous products were within a Class of dangerous goods. Ie. a Class 8 PGII corrosive substance was more corrosive that a Class 8 PGIII substance.|
|Signal Words||A word used to indicate the relative level of severity of a hazard and alert the reader to a potential hazard on the label. The GHS uses "Danger" and "Warning" as signal words.||No previous equivalent.|
|Pictograms||A graphical composition that may include a symbol plus other graphic elements, such as a border, background pattern or colour that is intended to convey specific information.||Similar to dangerous goods placards, but also used to identify products of both chronic and acute hazards. Where dangerous goods placards can be used for transport purposes and to identify major chemical storage areas, pictograms are generally only used directly on packages in the Australian jurisdictions.|
|Hazard Statements||A statement assigned to a hazard class and category that describes the nature of the hazards of a hazardous product, including, where appropriate, the degree of hazard (eg Flammable Liquids Category 1).||Similar to the Risk Phrases used in older Material Safety Data Sheets (MSDS).|
|Precautionary Statements||A phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous product, or improper storage or handling of a hazardous product.||Similar to the Safety Phrases used in older MSDSs.|
Knowing the above, you'll have a better chance to identify and interpret the information from your SDSs successfully. In our next Blog Entry we will look at how to use the information from SDSs to identify hazardous handling and storage practices. Hit the subscribe button to be notified about this along with future upcoming blogs.
If you aren't sure how to meet your hazardous chemical obligations and need assistance, contact Verus today. Verus' has chemical management specialists that can advise and support you on how to meet your obligations.