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Previous by Date: Subject: Re: [DCHAS-L] GHS Busters Date: Thu, 21 Nov 2013 19:16:46 -0800 Author: NEAL LANGERMAN |
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Interesting post, which I could not respond to since several good points were made. Is GHS really global? No, but that is by design - each particpating country can opt in or out of which sections they elect to follow. But that is by design - if they agreed to participate, they were supposed to follow the rules of participation which included how to properly define categories.
I think Monona hit the root cause on the head, which may lead to the more important question of - where will compliance enforcement come from?
A friend once told me that "history repeats itself," and I have found that to be true. Consider how many OSHA citations were issued for improper MSDS content vs. simply not having an MSDS as an employer? Has an OSHA citation ever been written for an MSDS author being unqualified to make the assessments? But OSHA does have a mandatory employer requirement to evaluate PPE (1910.132) which must be made in writing, on how to safely use the article, based on the information required on the supplied MSDS.
Now, consider the impact of the legal system. How much is left in the litigation reserve payout fund for asbestos? How much have we seen worker's compensation attorneys impact the system, to the detriment of employees and employers. But, they are now guaranteed to make a good living, and where are we?
All I am asking is that as a safety professional we have parnered with OSHA for decades and considering the results, we may have to ask ourselves - are we focusing on the right partners? Just some thoughts to consider.
Several significant/linked ideas were presented on this topic or thread and both authors hit it right on the head. To expand on Ralph's idea, it depends upon the what is considered acceptable by each country. Remember Melamine? A country knew it was extremely hazardous to children and allowed it to be marketed as a milk protien supplement, until they were caught causing significant effects. The plant manager (and second) was publically beheaded and the melamine was collected and put into a central storage location. In about 1 year it had been redistributed for the same purpose - amazingly(?) the same effects occurred, it was again recalled and then destroyed. Cultures and their differences with the value each culture places on a human life comes into play.
We need to consider the bigger picture of how they are related and to think it through.
But, which method of oversight has had more proven success?
Just food for thought...
---- Original message ----
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>Date: Thu, 21 Nov 2013 17:39:11 -0500
>From: DCHAS-L Discussion List
>Subject: Re: [DCHAS-L] GHS Busters
>To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
>
> I hope you are right. My point is that with no
> oversight, things either don't improve or improve so
> as you would barely notice. My suggestion is that
> we look at methods of oversight. Suppose the
> Chemwatch raw data were reworked by company to
> identify, not the countries, but the corporations
> that do good jobs and those that don't. Might
> help. But with now one looking or caring, it will
> just go on.
> Monona Rossol, M.S., M.F.A., Industrial Hygienist
> President: Arts, Crafts & Theater Safety, Inc.
> Safety Officer: Local USA829, IATSE
> 181 Thompson St., #23
> New York, NY 10012 212-777-0062
> actsnyc**At_Symbol_Here**cs.com www.artscraftstheatersafety.org
>
> -----Original Message-----
> From: BIALKE, THOMAS
> To: DCHAS-L
> Sent: Thu, Nov 21, 2013 3:46 pm
> Subject: Re: [DCHAS-L] GHS Busters
>
> I would bet that if you conducted that survey prior
> to GHS implantation, especially in the US you would
> get zero agreement. So 8% is an improvement. Far
> from perfect, but what did Chemwatch offer as a
> solution?
>
> It is so easy to find fault and condemn an program
> without offering a solution.
>
> Witness the Affordable Care Act.
>
> Right now, GHS is the best we have.
>
>
> Thomas Bialke
>
> From: DCHAS-L Discussion List
> [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Monona
> Rossol
> Sent: Thursday, November 21, 2013 1:25 PM
> To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
> Subject: Re: [DCHAS-L] GHS Busters
>
> Thank you Ralph. That supports what I'm seeing
> very well. I already wrote an article about that
> Canadian study of incorrect flash points.
>
> What it really boils down to is people are not
> reading the definitions and just making the same
> assumptions about their chemicals that they have
> always made.
>
> As long as there is no MSDS and no SDS oversight,
> why would manufacturers spend any more time or
> expertise writing their SDSs than they did their
> MSDSs. Just get something out that looks right has
> been and still apparently is: THE RULE.
>
> And that is an established global system.
> Monona Rossol, M.S., M.F.A., Industrial Hygienist
> President: Arts, Crafts & Theater Safety, Inc.
> Safety Officer: Local USA829, IATSE
> 181 Thompson St., #23
> New York, NY 10012 212-777-0062
> actsnyc**At_Symbol_Here**cs.com www.artscraftstheatersafety.org
>
> -----Original Message-----
> From: Ralph B. Stuart
> To: DCHAS-L
> Sent: Thu, Nov 21, 2013 1:13 pm
> Subject: [DCHAS-L] GHS Busters
>
> I noticed an interesting article at
>
> https://www.swiftpage6.com/speasapage.aspx?X=2Y0RSDXNI9G1KQ0R00YEWW
>
> about the challenge of GHS:
>
>
>
> What does GHS stand for?
>
>
>
> The Excercise
>
> Chemwatch have undertaken a systematic comparison of GHS classification
>
> published by official sources in:
>
>
>
> Europe (ECHA)
>
> Japan (NITE)
>
> New Zealand (CCID)
>
> Korea (NIER)
>
> A total of 12,452 Substances were reviewed.
>
>
>
> Interestingly there was very little overlap between Substances reviewed by any
>
> two Jurisdictions - Korea and New Zealand reviewed 1494 Substances in common.
>
>
>
> However, where Substances in common where assigned GHS Classifications, fewer
>
> than 8% were in agreement - New Zealand and the European Union agreed on only 75
>
> Substances of 939 Substances.
>
>
>
> In summary:
>
>
>
> < 8% Harmonisation between any 2 Jurisdictions
>
> < 0.6% Harmonisation between any 3 Jurisdictions
>
> ===
>
> I'm not quite sure of what to make of this data. I wonder if anyone on the list
>
> has done international comparisons that include the US?
>
>
>
> - Ralph
>
>
>
> Ralph Stuart CIH
>
> Chemical Hygiene Officer
>
> Department of Environmental Health and Safety
>
> Cornell University
>
>
>
> rstuart**At_Symbol_Here**cornell.edu