From: "Wright, Mike" <mwright**At_Symbol_Here**USW.ORG>
Subject: Re: [DCHAS-L] GHS P codes question
Date: Thu, 3 Aug 2017 20:08:49 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 673A00C44C25834BA3198AADFC1EB7AE9616E24F**At_Symbol_Here**PIT-MAIL01.uswa-us.local
In-Reply-To


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.

 

Mike Wright  

 

Michael J. Wright

Director of Health, Safety and Environment

United Steelworkers

 

412-562-2580 office

412-370-0105 cell

 

"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."

                                                                                                                                                                                         Jack Layton

 

 

 

 

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
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
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.

 

Harry

 

Virus-free. www.avast.com

 

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

---
For more information about the DCHAS-L e-mail list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org
Follow us on Twitter **At_Symbol_Here**acsdchas



 

--

+++++++
Harry J. Elston, Ph.D., CIH
Principal
Company Information
Google+
Twitter: **At_Symbol_Here**MidwestChemSafe

--- For more information about the DCHAS-L e-mail list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas

Previous post   |  Top of Page   |   Next post



The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to secretary@dchas.org.
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.