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When it comes to GHS it is not just 9 simple pictograms and a half hour training lesson!

In GHS world wide as we know it! For hazard communication elements (labels and marks) applicable to other transport classes or transport conditions covered by transport of dangerous goods regulations but not addressed in the GHS (e.g. labels for classes 7 and 9; elevated temperature substance mark; lithium battery mark; etc) refer to Part 5 of the United Nations Recommendations on the Transport of Dangerous Goods

And as the world changes so do the rules, we are already at revision number 6 since 2012 and as a company or employer our staff have a right to know the updates by you the supervisor!

1.   Desensitized Explosives. A new hazard class for Revision 6 which carries the definition of “solid or liquid explosive substances or mixtures which are phlegmatized to suppress their explosive properties in such a manner that they do not mass explode and do not burn too rapidly and therefore may be exempted from the hazard class “Explosives” (see Chapter 2.1; see also Note 2 to paragraph” This new class will have four categories and include its own label elements, H phrases and P phrases.

2.   Pyrophoric Gases. Chapter 2.2 entitled “Flammable Gases (Including Chemically Unstable Gases) is changing to “Flammable Gases”. While the title change is not necessarily newsworthy, the inclusion of the hazard class pyrophoric gases” is. This hazard class now comes with a standardized criteria, label elements and H/P phrases. NOTE: This is not a new hazard class for OSHA HazCom 2012.

3.   Section 9 Restructure. In Chapter 1.5 for Table 1.5.2, there is a new order format for Section 9’s Physical and Chemical Properties.The re-formatting “NOTE: The order of the physical and chemical properties presented in Section 9 may be followed on the SDS as shown in this table, but is not mandatory. The competent authority may decide to prescribe an order for Section 9 of the SDS, or they may leave it to the preparer of the SDS to re-order the properties, if deemed appropriate.”

On the surface these seems to be a simple change in the order the order of properties which does not have to be followed. However, upon a closer inspection of Annex 4: Guidance on The Preparation of Safety Data Sheets, the real impact is seen. There are now THREE tables to consider.

4.   STOT SE Cat 3 Refinement. For many this category in regards to mixtures can be perplexing and to some – vague. When Revision 6 is published, a lone paragraph which further refines the extrapolation of the toxicity of the mixture, cut-off values/concentrations and “relevant ingredients” could help clarify many questions.

5.   Aspiration Category Revisions. Another Health Hazard that can be a challenge is the Aspiration Hazard especially in instances where classification of mixture is needed. Revision 6 completely revises Category 1 and Category 2 with the addition of “relevant ingredients” and the sum of ingredient concentrations. There is a paragraph now for the use of expert judgment and a revision to the “distinct layers” classification.

6.   Aquatic Toxicity M Factor adjustments. The use of M factors for Aquatic Toxicity also sees adjustment in Revision 6. In particular, the phrase “multiplied by their corresponding M factors” is now part of classification for Acute categories 1, 2 and 3. Those simple words could have far-reaching impacts when put to use.

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