Dear Ralph,

1.       As an ACS member here, I just wanted to make a brief comment to you from Australia where we have been introducing GHS since January 2012, and have written a 171 page paper on GHS in Australia.

2.       Regarding GHS in USA:

(a)                To the best of my understanding, on 26 March 2012 the Occupational Safety & Health Administration (OSHA) published the revised Hazard Communication Standard (HCS) in the Federal Register Vol. 77, No. 58 relating to 29 CFR Parts 1910, 1915, and 1926. The revised HCS is in line with the third revised edition of the GHS and will become effective on 25 May 2012 although it will not become mandatory until 1 June 2015. During this phase-in period, and to give industry enough time to produce labels and Safety Data Sheets (SDS) consistent with the revised provisions, employers will be allowed to use at their own discretion, the existing HCS, the revised one, or both.

(b)               OSHA has determined that covered employers must complete all training regarding the new label elements and SDS format by December 1, 2013 since employees will begin seeing the new style labels considerably earlier than the compliance date for labelling. OSHA is requiring compliance with all of the provisions for preparation of new labels and safety data sheets by June 1, 2015. Interestingly, despite publication in the US Federal Register some three months after SafeWork Australia published the new WHS regulations and supporting information in relation to GHS, OSHA is requiring manufacturers to comply with all of the provisions for preparation of new labels and safety data sheets some 18 months before Australia is required to do so.

(c)                Additionally, OSHA is permitting distributors to have an additional six months (by December 1, 2015) to distribute containers with manufacturers’ labels in order to accommodate those they receive very close to the compliance date. Employers will also be given an additional year (by June 1, 2016) to update their hazard communication programs or any other workplace signs, if applicable.

(d)               OSHA published “A Guide to The Globally Harmonized System of Classification and Labelling of Chemicals (GHS)”, which when downloaded from http://www.osha.gov/dsg/hazcom/ghsguideoct05.pdf is 90 pages long and provides a good introduction to GHS.

3.       Regarding your specific question below on non-hazardous ingredient disclosure:

(a)                GHS Rev 3 states under section A4.3.3.2 (on page 409) for Mixtures:

                                                   i.      A4.3.3.2.1 For a mixture, provide the chemical identity, identification number (within the meaning of 4.3.3.1.3) and concentration or concentration ranges of all hazardous ingredients, which are hazardous to health or the environment within the meaning of the GHS, and are present above their cut-off levels. Manufacturers or suppliers may choose to list all ingredients, including non-hazardous ingredients.

                                                 ii.      A4.3.3.2.2    The concentrations of the ingredients of a mixture should be described as:

1.       exact percentages in descending order by mass or volume; or

2.       ranges of percentages in descending order by mass or volume if such ranges are acceptable to the appropriate competent national authority.

                                                iii.      A4.3.3.2.3    When using a proportion range, the health and environmental hazard effects should describe the effects of the highest concentration of each ingredient, provided that the effects of the mixture as a whole are not available.

                                               iv.      NOTE:           The “proportion range” refers to the concentration or percentage range of the ingredient in the mixture.

(b)               On the work I have done so far, GHS classification is expected to classify much more ingredients as hazardous than any former systems.

4.       Also, I have been observing the discussion regarding storage and incompatibilities:

(a)                As far as I'm aware the GHS (commonly known as the purple book) refers to classification and labelling of chemicals, I am not aware that it covers:

                                                   i.      Transportation (which internationally is covered by the UN RTDG, commonly known as the orange book).

                                                 ii.      Sea Transportation (which internationally is covered by the IMDG).

                                                iii.      Air Transportation (which internationally is covered by the IATA).

                                               iv.      Specific storage issues such as incompatibilities etc.

(b)               From the point of view of transportation, issues such as incompatibilities etc. are covered in the orange book with the 9 classes of UN Dangerous Goods to ensure that goods are not transported incorrectly, and in the first place these provide some classification method for Dangerous Goods classes.

(c)                In theory, the UN RTDG and the GHS may be combined at some stage in the future, but from what I understand, this appears to be not much of a likelihood.

5.       Regarding storage of Dangerous Goods in Australia, we have a number of Australian standards relating to storage and handling of some Dangerous Goods (e.g. Flammable and Combustible liquids, Corrosive Substances, etc.) in Australia. These are available for purchase from Standards suppliers. Presumably you will have equivalent standards/guidelines in USA, maybe you need to discuss with OSHA and/or DOT first.

6.       Anyway, I hope this helps the discussion.

Regards Adrian Thomas

Chemicalia Pty Ltd

ABN 17 100 190 270

Postal Address: PO Box 23, Mount Waverley BC, VIC 3149, Australia.

Physical Address: 7 Cremin Court, Mount Waverley, VIC 3149, Australia.

Local Phone: 03-9543-1587

International Phone: +61-3-9543-1587

Mobile Phone: 0409-549-768

International Mobile Phone: +61-409-549-768

Skype Name: adrian.thomas.chemicalia

Email: adrian**At_Symbol_Here**chemicalia.com

Web: http://www.chemicalia.com

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Ralph B. Stuart
Sent: Tuesday, 30 July 2013 1:00 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] GHS and cleaning chemicals

A friend with lab safety experience who now works for as a custodial trainer passed along this question that I thought people on DCHAS-L might have some knowledge of:

   I notice on the new GHS compliant safety data sheets from the manufacturer of the cleaning chemicals used here that they have taken the opportunity to remove the names of all chemicals in the product that are supposedly nonhazardous. Unfortunately that removes a lot of information for knowing how hazardous the product REALLY is. Has anyone mentioned this as a limitation of GHS or is this company unique in removing that information?

I wonder if anyone on the list has noticed this as well?

Thanks for any information on this.

- Ralph

Ralph Stuart CIH

Chemical Hygiene Officer

Department of Environmental Health and Safety Cornell University

rstuart**At_Symbol_Here**cornell.edu