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GHS - OSHA HCS Comparison
Comparison of Hazard Communication Requirements

TABLE OF CONTENTS


Introduction

I.

General Provisions Comparison

    Purpose
    Scope
    Application
    Definitions
    Hazard determination/classification
    Labels
    Workplace labeling
    Updating labels
    MSDS/SDS
    MSDS/SDS component disclosure
    Updating MSDS/SDS
    Information & Training
    Trade secrets /CBI
    Multiple hazards/Precedence
    Hazard determination/classification provisions

Health Hazard Comparison

    Acute Toxicity
    Skin corrosion/irritation
    Serious eye damage/eye irritation
    Respiratory or skin sensitization
    Germ cell mutagenicity
    Carcinogenicity
    Toxic to reproduction
    Target organ toxicity -- single exposure
    Target organ toxicity -- repeated exposure

Physical Hazard Comparison

    Explosives
    Flammable gases
    Flammable Aerosols
    Oxidizing gases
    Gases under pressure
    Flammable liquids
    Flammable solids
    Self-reactive substances
    Pyrophoric liquids
    Pyrophoric solids
    Self-heating substances
    Substances which on Contact with Water emits Flammable Gases
    Oxidizing liquids
    Oxidizing solids
    Organic peroxides
    Corrosive to metals

Label Comparison

    Comparison of HCS & GHS label elements
    GHS& transport pictograms
    Label examples: GHS, ANSI/OSHA (HCS)

MSDS Comparison V-1

    By 16 section format
    By MSDS element

Competent Authority Allowances &Building Block Decisions

    Introduction

    1.1.1 Purpose, Scope & Application Of The GHS
    1.1.3.1.1 Application
    1.1.3.1.4 Consumer sector
    1.1.3.1.5.1 Building blocks

    1.3 Classification Of Hazardous Substances & Mixtures
    1.3.2.4.9.5 Single positive study
    1.3.3.2.2 Lower generic cut-off
    1.3.3.2.3 Higher generic cut-off
    1.3.3.2.4 Document cut-off variations

    1.4  Hazard Communication: Labeling
    1.4.1.5 UNCETDG signal word/hazard statement
    1.4.6.3.1 Supplemental information
    1.4.6.3.2 Supplemental hazard information
    1.4.7.2.2 Updating information
    1.4.7.2.3 Review label/MSDS
    1.4.8.2 CBI
    1.4.9 Training
    1.4.10.4.2.3 domestic & transport pictograms
    1.4.10.5.2  GHS label (c) Precautionary statements and pictograms
    1.4.10.5.2 GHS label (d) Product identifier(ii)
    1.4.10.5. GHS label (d) Product identifier (iii)
    1.4.10.5.3.1 Precedence for the allocation of symbols
    1.4.10.5.3.3 Precedence for allocation of hazard statements
    1.4.10.5.4.1 Location of GHS information on the label
    1.4.10.5.4.2 Supplemental information: option &location
    1.4.10.5.4.3 Use of color outside pictograms
    1.4.10.5.5 Special labeling arrangements
    1.4.10.5.5.1 Workplace labeling
    1.4.10.5.5.2 Consumer product labeling based on the likelihood of injury
    1.4.10.5.5.3 Tactile warnings

    1.5 Hazard Communication: Safety Data Sheets
    1.5.2 Criteria for determining whether an SDS should be produced
    1.5.3.1.2 Alternate cut-offs & MSDS
    1.5.3.1.3 Acute/aquatic toxicity/ based on components at 1%
    1.5.3.1.4 Building blocks/MSDS
    1.5.3.3.1  Additional information on MSDS
    Table1.5.2 SDS Section 2.: graphics/pictograms
    Table1.5.2 SDS Section 3. concentration/ranges
    Table1.5.2 SDS Section 16. Other information

    2.1 Explosives
    2.1.2.2  Hazard categories/classification
    2.1.2.2 Wetted with water or alcohols
    2.1.3 Hazard Communication

    2.2 Flammable Gases
    2.2.2 Hazard categories/classification
    2.2.2  NOTE 1: Ammonia and methyl bromide
    2.2.3 Hazard Communication
    2.2.4.2 Alternative test methods

    2.3 Flammable Aerosols
    2.3.2.2 Hazard categories/classification
    2.3.3 Hazard Communication

    2.4 Oxidizing Gases
    2.4.2 Classification NOTE: Artificial air
    2.4.3 Hazard Communication

    2.5 Gases Under Pressure
    2.5.2 Classification/groups
    2.5.4.2 Complex calculation
    2.5.3 Hazard Communication

    2.6 Flammable Liquid
    2.6.2 Classification/hazard categories
    2.6.1 Table  NOTE 1: Gas oils, diesel and light heating oils
    NOTE 3: Viscous flammable liquids such as paints, enamels, lacquers, varnishes,adhesives and polishes
    2.6.3 Hazard Communication

    2.7 Flammable Solids
    2.7.2 Classification/hazard categories
    2.7.2.4NOTE: tests on solid substances or mixtures
    2.7.3 Hazard Communication

    2.8 Self-Reactive Substances
    2.8.2.2 Classification/hazard categories
    2.8.4.1 Testing/methods
    2.8.3 Hazard Communication

    2.9 Pyrophoric Liquids
    2.9.2 Classification
    2.9.3 Hazard Communication

    2.10 Pyrophoric Solids
    2.10.2 Classification
    2.10.3 Hazard Communication

    2.11 Self-Heating Substances
    2.11.2.2 Classification/hazard categories
    2.11.2.2NOTE 1: tests on solid substances or mixtures
    2.11.3 Hazard Communication

    2.12 Substances Which, In Contact With Water, Emit Flammable Gas
    2.12.2 Classification/hazard categories
    2.11.2.1NOTE 2: tests on solid substances or mixtures
    2.12.3 Hazard Communication

    2.13 Oxidizing Liquids
    2.13.2 Classification/hazard categories
    2.13.4.1 Test method
    2.13.3 Hazard Communication

    2.14 Oxidizing Solids
    2.14.2 Classification/hazard categories
    2.14.4.1 Test method
    2.14.3 Hazard Communication

    2.15 Organic Peroxides
    2.15.2.2 Classification/hazard categories
    2.15.4.1 Test series
    2.15.3Hazard Communication

    2.16 Corrosive To Metals
    2.16.2 Classification
    2.16.3 Hazard Communication

    3.1 Acute Toxicity
    3.1.2 Classification/hazard categories/building blocks
    3.1.4 Hazard Communication

    3.2 Skin Corrosion/Irritation
    3.2.2.4.2 Corrosion: classification/hazard categories/building blocks
    3.2.2.5 Irritation: classification/hazard categories/building blocks
    3.2.4 Hazard Communication

    3.3 Serious Eye Damage/Eye Irritation
    3.3.2.9 Reversible eye effects: classification/hazard categories/building blocks
    3.3.4 Hazard Communication

    3.4 Respiratory or Skin Sensitization
    3.4.3.3 Skin Sensitizer Classification criteria for mixtures: MSDS/labels (note 1)
    3.4.3.3 Respiratory Sensitizer Classification criteria for mixtures (liquid/solid):MSDS/labels (note 3)
    3.4.3.3 Respiratory Sensitizer Classification criteria for mixtures (gaseous):MSDS/labels (note 5)
    3.4.4 Hazard Communication

    3.5 Germ Cell Mutagenicity
    3.5.2.1 Classification/hazard categories/building blocks
    3.5.3.1 Test data for mixtures
    3.5.4 Hazard Communication

    3.6 Carcinogenicity
    3.6.2.1 Route specific classification
    3.6.2.6 One positive study
    3.6.3.1 Test data for mixtures
    3.6.3.3 Carcinogen Classification criteria for mixtures: MSDS/labels (note 1)
    3.6.4 Hazard Communication

    3.7 Reproductive Toxicity
    3.7.2.3.1 One positive study
    3.7.3.1 Test data for mixtures
    3.7.3.3 Category 1 reproductive toxicant Classification criteria for mixtures:MSDS/labels (note 1)
    3.7.3.3 Category 2 Classification criteria for mixtures: MSDS/labels (note 3)
    3.7.4 Hazard Communication

    3.8 Specific Target Organ Systemic Toxicity -- Single Exposure
    3.8.2.1 Classification/hazard categories/building blocks
    3.8.2.10.4 Saturated vapor concentration
    3.8.2 Category 1 target organ/systemic toxicant Classification criteria for mixtures: MSDS/labels (note 1)
    3.8.2 Category 1 target organ/systemic toxicant Classification criteria for mixtures: MSDS/labels (note 3)
    3.8.2 Category 2 target organ/systemic toxicant Classification criteria for mixtures: MSDS/labels (note 4)
    3.8.4 Hazard Communication

    3.9 Specific Target Organ Systemic Toxicity -- Repeat Exposure
    3.9.2.1 Classification/hazard categories/building blocks
    3.9.2.10.4 Saturated vapor concentration
    3.9.3 Category 1 target organ/systemic toxicant Classification criteria for mixtures: MSDS/labels (note 1)
    3.9.3 Category 1 target organ/systemic toxicant Classification criteria for mixtures: MSDS/labels (note 3)
    3.9.3 Category 2 target organ/systemic toxicant Classification criteria for mixtures: MSDS/labels (note 4)
    3.9.4 Hazard Communication

Comparison of Hazard Communication Requirements

OSHA Hazard Communication Standard 29CFR1910.12001(HCS)
Globally Harmonized System2 (GHS)

Comparison of Hazard Communication Requirements

Introduction

The Globally Harmonized System (GHS) is not in itself a regulation or a model regulation. It is a framework from which competent authorities may select the appropriate harmonized classification & communication elements. Competent authorities will decide how to apply the various elements of the GHS within their systems based on their needs and the target audience.

The GHS includes the following elements:
(a) harmonized criteria for classifying substances and mixtures according to their health, environmental and physical hazards; and

(b) harmonized hazard communication elements, including requirements for labeling and material safety data sheets.
The harmonized elements of the GHS may be seen as a collection of building blocks from which to form a regulatory approach. While the full range is available to everyone, and should be used if a country or organization chooses to cover a certain effect when it adopts the GHS, the full range does not have to be adopted. This constitutes the GHS building block approach.

Competent authorities, such as OSHA, will determine how to implement the elements of the GHS within their systems. This document compares the GHS elements to the OSHA Hazard Communication Standard (HCS) elements. The competent authority allowances/decision points and the selection of building blocks are addressed in Section VI.

This Comparison of Hazard Communication Requirements document includes the following segments:

  1. General provisions comparison
  2. Health hazard comparison
  3. Physical hazard comparison
  4. Label comparison
    1. GHS & transport pictograms
    2. Label examples
  5. MSDS comparison
  6. GHS Competent Authority Allowances & Building Block Discussion.


I. General Provisions Comparison

Purpose
Comparison
The purpose of the HCS and GHS are consistent. The HCS is one of the major existing systems which was to be harmonized by the GHS. While the intent of the GHS in international harmonization, it will also address harmonization of sectors and regulations within countries.
OSHA HCS 29CFR1910.12001 GHS2
29 CFR 1910.1200 (a)(1) Purpose

The purpose of this section is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training.

(a)(2)
This occupational safety and health standard is intended to address comprehensively the issue of evaluating the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, and to preempt any legal requirements of a state, or political subdivision of a state, pertaining to this subject. Evaluating the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, may include, for example, but is not limited to, provisions for: developing and maintaining a written hazard communication program for the workplace, including lists of hazardous chemicals present; labeling of containers of chemicals in the workplace, as well as of containers of chemicals being shipped to other workplaces;preparation and distribution of material safety data sheets to employees and downstream employers; and development and implementation of employee training programs regarding hazards of chemicals and protective measures. Under section 18 of the Act, no state or political subdivision of a state may adopt or enforce, through any court or agency, any requirement relating to the issue addressed by this Federal standard, except pursuant to a Federally-approved state plan.		 1.1.1 Purpose

1.1.1.1. The use of chemical products to enhance and improve life is a widespread practice worldwide. But alongside the benefits of these products, there is also the potential for adverse effects to people or the environment. As a result, a number of countries or organizations have developed laws or regulations over the years that require information to be prepared and transmitted to those using chemicals, through labels or Safety Data Sheets(SDS). Given the large number of chemical products available, individual regulation of all of them is simply not possible for any entity. Provision of information gives those using chemicals the identities and hazards of these chemicals, and allows the appropriate protective measures to be implemented in the local use settings.

1.1.1.2   While these existing laws or regulations are similar in many respects, their differences are significant enough to result in different labels or SDS for the same product in different countries .Through variations in definitions of hazards, a chemical may be considered flammable in one country, but not another. Or it may be considered to cause cancer in one country, but not another. Decisions on when or how to communicate hazards on a label or SDS thus vary around the world, and companies wishing to be involved in international trade must have large staffs of experts who can follow the changes in these laws and regulations and prepare different labels and SDS. In addition, given the complexity of developing and maintaining a comprehensive system for classifying and labeling chemicals, many countries have no system at all.

1.1.1.3 Given the reality of the extensive global trade in chemicals, and the need to develop national programs to ensure their safe use, transport, and disposal, it was recognized that an internationally-harmonized approach to classification and labeling would provide the foundation for such programs. Once countries have consistent and appropriate information on the chemicals they import or produce in their own countries, the infrastructure to control chemical exposures and protect people and the environment can be established in a comprehensive manner.

1.1.1.4 Thus the reasons for setting the objective of harmonization were many. It is anticipated that, when implemented, the GHS will:

(a) enhance the protection of human health and the environment by providing an internationally comprehensible system for hazard communication;

(b) provide are recognized framework for those countries without an existing system;

(c) reduce the need for testing and evaluation of chemicals; and

(d)facilitate international trade in chemicals whose hazards have been properly assessed and identified on an international basis.

1.1.1.5 The work began with examination of existing systems, and determination of the scope of the work. While many countries had some requirements, the following systems were deemed to be the "major" existing systems and were used as the primary basis for the elaboration of the GHS:

Requirements of systems in the United States of America for the workplace, consumers and pesticides;

(b)Requirements of Canada for the workplace, consumers and pesticides;

(c)  European Union directives for classification and labeling of substances and preparations;

(d) The United Nations Recommendations on the Transport of Dangerous Goods.

1.1.1.6 The requirements of other countries were also examined as the work developed,but the primary task was to find ways to adopt the best aspects of these existing systems and develop a harmonized approach. This work was done based on agreed principles of harmonization that were adopted early in the process:

(a)the level of protection offered to workers, consumers, the general public and the environment should not be reduced as a result of harmonizing the classification and labeling systems;

(b)  the hazard classification process refers principally to the hazards arising from the intrinsic properties of chemical elements and compounds and mixtures thereof, whether natural or synthetic;

(c)harmonization means establishing a common and coherent basis for chemical hazard classification and communication, from which the appropriate elements relevant to means of transport, consumer, worker and environment protection can be selected;

(d)the scope of harmonization includes both hazard classification criteria and hazard communication tools, e.g. labeling and chemical safety data sheets,taking into account especially the four existing systems identified in the ILO report;

(e)changes in all these systems will be required to achieve a single globally harmonized system; transitional measures should be included in the process of moving to the new system;

(f)the involvement of concerned international organizations of employers,workers, consumers, and other relevant organizations in the process of harmonization should be ensured;

(g)the comprehension of chemical hazard information, by the target audience,e.g. workers, consumers and the general public should be addressed;

(h)validated data already generated for the classification of chemicals under the existing systems should be accepted when reclassifying these chemicals under the harmonized system;

(i)a new harmonized classification system may require adaptation of existing methods for testing of chemicals;

(j)in relation to chemical hazard communication, the safety and health of workers, consumers and the public in general, as well as the protection of the environment, should be ensured while protecting confidential business information, as prescribed by the competent authorities.


Scope
Comparison
The GHS scope clarification is consistent with the HCS exemptions and labeling exceptions. Consumer products and pharmaceuticals are specifically addressed in the GHS scope. The HCS includes laboratories,sealed containers and distributors while as a framework for systems the GHS does not include these specific issues.

The GHS addresses testing in the scope section. The HCS addresses testing under hazard determination. The GHS and HCS do not require testing for health hazards. All the physical hazards in the HCS are not linked to specific test methods (as is the case in the GHS) and testing for physical hazards is not required.
OSHAHCS 29CFR1910.12001 GHS2
29 CFR 1910.1200 (b) Scope  and application

(b)(1)
This section requires chemical manufacturers or importers to assess the hazards of chemicals which they produce or import, and all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, material safety data sheets, and information and training. In addition, this section requires distributors to transmit the required information to employers. (Employers who do not produce or import chemicals need only focus on those parts of this rule that deal with establishing a workplace program and communicating information to their workers. Appendix E of this section is a general guide for such employers to help them determine their compliance obligations under the rule.)

(b)(2)
This section applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.

(b)(3)
This section applies to laboratories only as follows:

(b)(3)(i)
Employers shall ensure that labels on incoming containers of hazardous chemicals are not removed or defaced;

Employers shall maintain any material safety data sheets that are received with incoming shipments of hazardous chemicals, and ensure that they are readily accessible during each work shift to laboratory employees when they are in their work areas;

(b)(3)(iii)
Employers shall ensure that laboratory employees are provided information and training in accordance with

paragraph (h) of this section, except for the location and availability of the written hazard communication program under paragraph(h)(2)(iii) of this section; and,

(b)(3)(iv)
Laboratory employers that ship hazardous chemicals reconsidered to be either a chemical manufacturer or a distributor under this rule, and thus must ensure that any containers of hazardous chemicals leaving the laboratory are labeled in accordance with paragraph (f)(1) of this section, and that a material safety data sheet is provided to distributors and other employers in accordance with paragraphs (g)(6) and (g)(7) of this section

(b)(4)
In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use(such as are found in marine cargo handling, warehousing, or retail sales),this section applies to these operations only as follows:

(b)(4)(i)
Employers shall ensure that labels on incoming containers of hazardous chemicals are not removed or defaced;

(b)(4)(ii)
Employers shall maintain copies of any material safety data sheets that are received with incoming shipments of the sealed containers of hazardous chemicals, shall obtain a material safety data sheet as soon as possible for sealed containers of hazardous chemicals received without a material safety data sheet if an employee requests the material safety data sheet, and shall ensure that the material safety data sheets are readily accessible during each work shift to employees when they are in their work area(s); and,

(b)(4)(iii)
Employers shall ensure that employees are provided with information and training in accordance with paragraph (h) of this section(except for the location and availability of the written hazard communication program under paragraph (h)(2)(iii) of this section), to the extent necessary to protect them in the event of a spill or leak of a hazardous chemical from a sealed container.

(b)(5)
This section does not require labeling of the following chemicals:

(b)(5)(i)
Any pesticide as such term is defined in the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 136 et seq.), when subject to the labeling requirements of that Act and labeling regulations issued under that Act by the Environmental Protection Agency;

(b)(5)(ii)
Any chemical substance or mixture as such terms redefined in the Toxic Substances Control Act (15 U.S.C. 2601 et seq.), when subject to the labeling requirements of that Act and labeling regulations issued under that Act by the Environmental Protection Agency;

(b)(5)(iii)
Any food, food additive, color additive, drug, cosmetic,or medical or veterinary device or product, including materials intended for use as ingredients in such products (e.g. flavors and fragrances), as such terms are defined in the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 301et seq.) or the Virus-Serum-Toxin Act of 1913 (21 U.S.C. 151 et seq.), and regulations issued under those Acts, when they are subject to the labeling requirements under those Acts by either the Food and Drug Administration or the Department of Agriculture;

(b)(5)(iv)
Any distilled spirits (beverage alcohols), wine, or malt beverage intended for non industrial use, as such terms are defined in the Federal Alcohol Administration Act (27 U.S.C. 201 et seq.) and regulations issued under that Act, when subject to the labeling requirements of that Act and labeling regulations issued under that Act by the Bureau of Alcohol,Tobacco, and Firearms;

(b)(5)(v)
Any consumer product or hazardous substance as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, when subject to a consumer product safety standard or labeling requirement of those Acts, or regulations issued under those Acts by the Consumer Product Safety Commission; and,

(b)(5)(vi)
Agricultural or vegetable seed treated with pesticides and labeled in accordance with the Federal Seed Act (7 U.S.C. 1551 et seq.) and the labeling regulations issued under that Act by the Department of Agriculture.

(b)(6)
This section does not apply to:

(b)(6)(i)
Any hazardous waste as such term is defined by the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act of 1976, as amended (42 U.S.C. 6901 et seq.), when subject to regulations issued under that Act by the Environmental Protection Agency;

(b)(6)(ii)
Any hazardous substance as such term is defined by the Comprehensive Environmental Response, Compensation and Liability ACT (CERCLA)(42 U.S.C. 9601 et seq.) when the hazardous substance is the focus of remedial or removal action being conducted under CERCLA in accordance with the Environmental Protection Agency regulations.

(b)(6)(iii)
Tobacco or tobacco products;

(b)(6)(iv)
Wood or wood products, including lumber which will not be processed, where the chemical manufacturer or importer can establish that the only hazard they pose to employees is the potential for flammability or combustibility (wood or wood products which have been treated with a hazardous chemical covered by this standard, and wood which may be subsequently sawed or cut, generating dust, are not exempted);

(b)(6)(v)
Articles (as that term is defined in paragraph (c) of this section);

(b)(6)(vi)
Food or alcoholic beverages which are sold, used, or prepared in a retail establishment (such as a grocery store, restaurant, or drinking place), and foods intended for personal consumption by employees while in the workplace;

(b)(6)(vii)
Any drug, as that term is defined in the Federal Food,Drug, and Cosmetic Act (21 U.S.C. 301 et seq.), when it is in solid, final form for direct administration to the patient (e.g., tablets or pills); drugs which are packaged by the chemical manufacturer for sale to consumers in a retail establishment (e.g., over-the-counter drugs); and drugs intended for personal consumption by employees while in the workplace (e.g., first aid supplies);

(b)(6)(viii)
Cosmetics which are packaged for sale to consumers in a retail establishment, and cosmetics intended for personal consumption by employees while in the workplace;

(b)(6)(ix)
Any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.)and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively,where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended;

(b)(6)(x)
Nuisance particulates where the chemical manufacturer or importer can establish that they do not pose any physical or health hazard covered under this section;

(b)(6)(xi)
Ionizing and nonionizing radiation; and,

(b)(6)(xii)
Biological hazards.		 1.1.2 Scope

1.1.2.1The GHS includes the following elements:

(a)  harmonized criteria for classifying substances and mixtures according to their health, environmental and physical hazards;and

(b)harmonized hazard communication elements, including requirements for labeling and safety data sheets.

1.1.2.2  This document describes the classification criteria and the hazard communication elements by type of hazard (e.g. acute toxicity; flammability). In addition, decision logics for each hazard have been developed. Some  examples of classification of chemicals in the text, as well as in Annex 7, illustrate how to apply the criteria. There is also some discussion about issues that were raised during the development of the system where additional guidance was thought to be necessary to implement the system.

1.1.2.3  The scope of the GHS is based on the mandate from the 1992 United Nations Conference on Environment and Development (UNCED)for development of such a system as stated in paragraphs26 and 27  of the Agenda 21, Chapter19, Program Area B, reproduced below:
"26. Globally harmonized hazard classification and labeling systems are not yet available to promote the safe use of chemicals, inter alia, at the workplace or in the home. Classification of chemicals can be made for different purposes and is a particularly important tool in establishing labeling systems. There is a need to develop harmonized hazard classification and labeling systems,building on ongoing work;

27. A globally harmonized hazard classification and compatible labeling system, including material safety data sheets and easily understandable symbols, should be available, if feasible, by the year 2000."

This mandate was later analyzed and refined in the harmonization process to identify the parameters of the GHS. As a result, the following clarification was adopted by the Interorganization Program for the Sound Management of Chemicals (IOMC) Coordinating Group to ensure that participants were aware of the scope of the effort:

"The work on harmonization of hazard classification and labeling focuses on a harmonized system for all chemicals, and mixtures of chemicals. The application of the components of the system may vary by type of product or stage of the life cycle. Once a chemical is classified, the likelihood of adverse effects may be considered in deciding what informational or other steps should be taken for a given product or use setting. Pharmaceuticals, food additives, cosmetics, and pesticide residues in food will not be covered by the GHS in terms of labeling at the point of intentional intake. However, these types of chemicals would be covered where workers may be exposed, and, in transport if potential exposure warrants. The Coordinating Group for the Harmonization of Chemical Classification Systems (CG/HCCS) recognizes that further discussion will be required to address specific application issues for some product use categories which may require the use of specialized expertise.

1.1.2.5 In developing this clarification, the CG/HCCS carefully considered many different issues with regard to the possible application of the GHS. There were concerns raised about whether certain sectors or products should be exempted, for example, or about whether or not the system would be applied at all stages of the life cycle of a chemical. Three parameters were agreed in this discussion, and are critical to application of the system in a country or region. These are described below:

a) Parameter 1: The GHS covers all hazardous chemicals. The mode of application of the hazard communication components of the GHS (e.g. labels, safety data sheets) may vary by product category or stage in the life cycle. Target audiences for the GHS include consumers, workers, transport workers, and emergency responders

(i) Existing hazard classification and labeling systems address potential exposures to all potentially hazardous chemicals in all types of use situations, including production, storage, transport,workplace use, consumer use, and presence in the environment. They are intended to protect people, facilities, and the environment. The most widely applied requirements in terms of chemicals covered are generally found in the parts of existing systems that apply to the workplace or transport. It should be noted that the term chemical is used broadly in the UNCED agreements and subsequent documents to include substances, products, mixtures, preparations,or any other terms that may be used in existing systems to denote coverage.

(ii) Since all chemicals and chemical products in commerce are made in a workplace (including consumer products),handled during shipment and transport by workers, and often used by workers,there are no complete exemptions from the scope of the GHS for any particular type of chemical or product. In some countries, for example, pharmaceuticals are currently covered by workplace and transport requirements in the manufacturing, storage, and transport stages of the life cycle. Workplace requirements may also be applied to employees involved in the administration of some drugs, or clean-up of spills and other types of potential exposures in health care settings. SDSs and training must be available for these employees under some systems. It is anticipated that the GHS would be applied to pharmaceuticals in a similar fashion.

(iii) At other stages of the life cycle for these same products, the GHS may not be applied at all. For example, at the point of intentional human intake or ingestion, or intentional application to animals, products such as human or veterinary pharmaceuticals are generally not subject to hazard labeling under existing systems. Such requirements would not normally be applied to these products as a result of the GHS. (It should be noted that the risks to subjects associated with the medical use of human or veterinary pharmaceuticals are generally addressed in package inserts and are not part of this harmonization process.) Similarly, products such as foods that may have trace amounts of food additives or pesticides in them are not currently labeled to indicate the presence or hazard of those materials. It is anticipated that application of the GHS would not require them to be labeled as such.

b)Parameter 2: The mandate for development of a GHS does not include establishment of uniform test methods or promotion of further testing to address adverse health outcomes.

(i) Tests that determine hazardous properties, which are conducted according to internationally recognized scientific principles, can be used for purposes of a hazard determination for health and environmental hazards. The GHS criteria for determining health and environmental hazards are test method neutral, allowing different approaches as long as they are scientifically sound and validated according to international procedures and criteria already referred to in existing systems for the hazard class of concern and produce mutually acceptable data. While the

OECD is the lead organization for development of harmonized health hazard criteria, the GHS is not tied to the OECD Test Guidelines Program. For example, drugs are tested according to agreed criteria developed under the auspices of the World Health Organization (WHO). Data generated in accordance with these tests would be acceptable under the GHS. Criteria for physical hazards under the UNSCETDG are linked to specific test methods for hazard classes such as flammability and explosivity.

(ii) The GHS is based on currently available data. Since the harmonized classification criteria are developed on the basis of existing data, compliance with these criteria will not require retesting of chemicals for which accepted test data already exists.

(c) Parameter  3: In addition to animal data and valid in vitro testing, human experience, epidemiological data, and clinical testing provide important information that should be considered in application of the GHS.

Most of the current systems acknowledge and make use of ethically obtained human data or available human experience. Application of the GHS should not prevent the use of such data, and the GHS explicitly acknowledges the existence and use of all appropriate and relevant information concerning hazards or the likelihood of harmful effects (i.e.risk).

1.1.2.6 Other scope limitations
1.1.2.6.1 The GHS is not intended to harmonize risk assessment procedures or risk management decisions (such as establishment of a permissible exposure limit for employee exposure), which generally require some risk assessment in addition to hazard classification. In addition,chemical inventory requirements in various countries are not related to the GHS.


Application
Comparison
Implementing the GHS will require the HCS to make decisions concerning the application of the building blocks for physical and health hazard classes and hazard categories. See the individual health &physical endpoints for details. For other Competent Authority decisions see GHS Competent Authority Allowances & Building Block Discussion section.
OSHAHCS 29CFR1910.12001 GHS2
Comment: The HCS is a performance -- oriented regulation. The GHS is a specification oriented. Implementation of the GHS will require changes to the performance-oriented nature of the HCS. These changes will include required label elements and a required MSDS format, as well as criteria changes.

Although the GHS has the building block approach, changes to the HCS are expected. The HCS may not implement all hazard classes, e.g., hazardous for the environment. Even within some hazard classes the HCS may not regulate all hazard categories, e.g., acute toxicity. Many hazard classes will require some type of change to the HCS.		 1.1.3 Application of the GHS

1.1.3.1 Harmonization of the application of the GHS

1.1.3.1.1 The goal of the GHS is to identify the intrinsic hazards found in chemical substances and  mixtures and to convey hazard information about these hazards. The criteria for hazard classification are harmonized. Hazard statements, symbols and signal words have been  standardized and harmonized and now foreman integrated hazard communication system. The GHS will allow the hazard communication elements of the existing systems to converge.  Competent authorities will decide how to apply the various elements of the GHS based on the needs of the competent authority and the target audience. (See also Hazard Communication: Labeling (Chapter 1.4,paragraph 1.4.10.5.4.2) and Consumer Product Labeling Based on the Likelihood of Injury, Annex 4.)

1.1.3.1.2 For transport, it is expected that application of the GHS will be similar to application of current transport requirements. Containers of dangerous goods will be marked with pictograms that address acute toxicity, physical hazards, and environmental hazards. As is true for workers in other sectors workers in the transport sector will be trained. The elements of the GHS that address such elements as signal word sand hazard statements are not expected to be adopted in the transport sector.

1.1.3.1.3 In the workplace, it is expected that all of the GHS elements will be adopted, including labels that have the harmonized core information under the GHS, and safety data sheets. It is also anticipated that this will be supplemented by employee training to help ensure effective communication.

1.1.3.1.4 For the consumer sector, it is expected that labels will be the primary focus of GHS application. These labels will include the core elements of the GHS, subject to some sector-specific considerations in certain systems. (See also Hazard Communication: Labeling (Chapter 1.4, paragraph 1.4.10.5.4.2) and Consumer Product Labeling Based on the Likelihood of Injury, Annex 4)

1.1.3.1.5 Building block approach

1.1.3.1.5.1 Consistent with the building block approach, countries are free to determine which of the building blocks will be applied in different parts of their systems. However,where a system covers something that is in the GHS, and implements the GHS,that coverage should be consistent. For example, if a system covers the carcinogenicity of a chemical, it should follow the harmonized classification scheme and the harmonized label elements.

1.1.3.1.5.2 In examining the requirements of existing systems, it was noted that coverage of hazards may vary by the perceived needs of the target audience for information. In particular, the transport sector focuses on acute health effects and physical hazards, but has not to date covered chronic effects due to the types of exposures expected to be encountered in that setting. But there may be other differences as well, with countries choosing not to cover all of the effects addressed by the GHS in each use setting.

1.1.3.1.5.3 The harmonized elements of the GHS may thus be seen as a collection of building blocks from which to form a regulatory approach. While the full range is available to everyone, and should be used if a country or organization chooses to cover a certain effect when it adopts the GHS, the full range does not have to be adopted. While physical hazards are important in the workplace and transport sectors, consumers may not need to know some of the specific physical hazards in the type of use they have for a product. As long as the hazards covered by a sector or system are covered consistently with the GHS criteria and requirements, it will be considered appropriate implementation of the GHS. Not withstanding the fact that an exporter needs to comply with importing countries GHS implementation,it is hoped that the application of the GHS worldwide will eventually lead to a fully harmonized situation.


Definitions
Comparison
The HCS will need to add definitions and some existing HCS definitions will need to be changed. The above definitions illustrate some of the key changes to be considered Substance, chemical, liquid and gas are some differences. In The HCS physical hazards have definitions. The GHS has criteria for physical hazards.
OSHAHCS 29CFR1910.12001

29 CFR 1910.1200 (c) Definitions		 GHS2

Chapter 1.2 Definitions and abbreviations
"Chemical" means any element, chemical compound or mixture of elements and/or compounds. Substance means chemical elements and their compounds in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurities deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition;
"Chemical name" means the scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name which will clearly identify the chemical for the purpose of conducting a hazard evaluation.

"Specific chemical identity" means the chemical name, Chemical Abstracts Service (CAS) Registry Number, or any other information that reveals the precise chemical designation of the substance.		 Chemical identity means a name that will uniquely identify a chemical. This can be a name that is in accordance with the nomenclature systems of the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS), or a technical name;
"Combustible liquid" means any liquid having a flagship at or above 100 deg. F (37.8 deg. C), but below 200 deg. F (93.3deg. C), except any mixture having components with flash points of 200 deg. F(93.3 deg. C), or higher, the total volume of which make up 99 percent or more of the total volume of the mixture. See flammable liquid hazard categories.
"Common name" means any designation or identification such as code name, code number, trade name, brand name or generic name used to identify a chemical other than by its chemical name. No GHS definition
"Compressed gas" means:

(i) A gas or mixture of gases having, in a container, an absolute pressure exceeding 40 psi at 70 deg. F (21.1 deg. C); or

(ii) A gas or mixture of gases having, in a container, an absolute pressure exceeding 104 psi at 130 deg. F (54.4 deg. C) regardless of the pressure at 70 deg. F (21.1 deg. C); or

(iii) A liquid having a vapor pressure exceeding 40 psi at100 deg. F (37.8 deg. C) as determined by ASTM D-323-72.		 "Compressed gas": A gas which when packaged under pressure is entirely gaseous at -50 °C;including all gases with a critical temperature <-50 °C.
No HCS definition. Corrosive to metal means a substance or a mixture which by chemical action will materially damage, or even destroy, metals;
"Explosive" means a chemical that causes a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature. Explosive article means an article containing one or more explosive substances;

Explosive substance means a solid or liquid substance (or mixture of substances) which is in itself capable by chemical reaction of producing gas at such a temperature and pressure and at such a speed as to cause damage to the surroundings. Pyrotechnic substances are included even when they do not evolve gases;
"Flammable" means a chemical that falls into one of the following categories:

(i) "Aerosol, flammable" means an aerosol that,when tested by the method described in 16 CFR 1500.45, yields a flame projection exceeding 18 inches at full valve opening, or a flashback (a flame extending back to the valve) at any degree of valve opening;

(ii) "Gas, flammable" means: (A) A gas that, at ambient temperature and pressure, forms a flammable mixture with air at a concentration of thirteen (13) percent by volume or less; or

(B) A gas that, at ambient temperature and pressure, forms a range of flammable mixtures with air wider than twelve (12) percent by volume, regardless of the lower limit;

(iii) "Liquid, flammable" means any liquid having a flashpoint below 100 deg. F (37.8 deg. C), except any mixture having components with flash points of 100 deg. F (37.8 deg. C) or higher, the total of which make up 99 percent or more of the total volume of the mixture.

(iv) "Solid, flammable" means a solid, other than a blasting agent or explosive as defined in 1910.109(a), that is liable to cause fire through friction, absorption of moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious hazard. A chemical shall be considered to be a flammable solid if, when tested by the method described in 16 CFR 1500.44, it ignites and burns with a self-sustained flame at a rate greater than one-tenth of an inch per second along its major axis.		 "Flammable gas": A gas having a flammable range with air at 20 C and a standard pressure of 101.3 kPa.

"Flammable Liquid": A flammable liquid means a liquid having a flash point of not more than93 C.

"Flammable Solid": A flammable solid is a solid which is readily combustible, or may cause or contribute to fire through friction.

"Aerosols" means any non-refillable receptacles made of metal, glass or plastics and containing a gas compressed, liquefied or dissolved under pressure, with or without a liquid, paste or powder, and fitted with a release device allowing the contents to be ejected as solid or liquid particles in suspension in a gas,as a foam, paste or powder or in a liquid state or in a gaseous state.  Aerosol includes aerosol dispensers;

"Readily Combustible Solid": Readily combustible solids are powdered, granular, or pasty substances which are dangerous if they can be easily ignited by brief contact with an ignition source, such as a burning match, and if the flame spreads rapidly.
"Flashpoint" means the minimum temperature at which a liquid gives off a vapor in sufficient concentration to ignite when tested as follows:

(i) Tagliabue Closed Tester (See American National Standard Method of Test for Flash Point by Tag Closed Tester, Z11.24-1979(ASTM D 56-79)) for liquids with a viscosity of less than 45 Saybolt Universal Seconds (SUS) at 100 deg. F (37.8 deg. C), that do not contain suspended solids and do not have a tendency to form a surface film under test; or

(ii) Pensky-Martens Closed Tester (see American National Standard Method of Test for Flash Point by Pensky-Martens Closed Tester,Z11.7-1979 (ASTM D 93-79)) for liquids with a viscosity equal to or greater than 45 SUS at 100 deg. F (37.8 deg. C), or that contain suspended solids, or that have a tendency to form a surface film under test; or

(iii) Setaflash Closed Tester (see American National Standard Method of Test for Flash Point by Setaflash Closed Tester (ASTM D3278-78)).		 "Flash point"  means the lowest temperature (corrected to a standard pressure of 101.3 kPa) at which the application of an ignition source causes the vapors of a liquid to ignite under specified test conditions;
No HCS definition
 Gas means a substance which (i) at50 °C has a vapor pressure greater than 300 kPa; or (ii) is completely gaseous at 20 °C  at a standard pressure of 101.3 kPa;

Dissolved gas means a gas which when packaged under pressure is dissolved in a liquid phase solvent;

Liquefied gas means a gas which when packaged under pressure, is partially liquid at temperatures above -50 °C. A distinction is made between:

(i) High pressure liquefied gas: a gas with a critical temperature between -50 °C and +65°C; and
(ii) Low pressure liquefied gas: a gas with a critical temperature above +65 °C;

"Refrigerated liquefied gas": A gas which when packaged is made partially liquid because of its low temperature.
"Health hazard" means a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term "health hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes. Appendix A provides further definitions and explanations of the scope of health hazards covered by this section, and Appendix B describes the criteria to be used to determine whether or not a chemical is to be considered hazardous for purposes of this standard. (See appendix for criteria.) Hazard category means the division of criteria within each hazard class,.e.g. oral acute toxicity includes five hazard categories and  flammable liquids includes four hazard categories. These categories compare hazard severity within a hazard class and should not be taken as a comparison of hazard categories more generally;

Hazard class means the nature of the physical, health or environmental hazard,e.g. flammable solid carcinogen,oral acute toxicity; 
"Hazard warning" means any words, pictures,symbols, or combination thereof appearing on a label or other appropriate form of warning which convey the specific physical and health hazard(s), including target organ effects, of the chemical(s) in the container(s). (See the definitions for "physical hazard" and "health hazard" to determine the hazards which must be covered.) Hazard statement means 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;

"Signal word": A signal word means a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label.   The GHS uses 'Danger' and 'Warning'.

"Pictogram": A pictogram means a composition that may include a symbol plus other graphic elements, such as a border, background pattern or color that is intended to convey specific information.

"Precautionary statement": A precautionary statement means a phrase (and/or pictogram)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.

"Supplemental Label Element": A supplemental label element means any additional non-harmonized type of information supplied on the container of a hazardous product that is not required or specified under the GHS. In some cases this information may be required by other competent authorities or it may be additional information provided at the discretion of the manufacturer/distributor.

"Symbol": A symbol means a graphical element intended to succinctly convey information.
"Label" means any written, printed, or graphic material displayed on or affixed to containers of hazardous chemicals. Label means an appropriate group of written, printed or graphic information elements concerning a hazardous product, selected as relevant to the target sector (s), that is affixed to,printed on, or attached to the immediate container of a hazardous product, or to the outside packaging of a hazardous product;

Label element means one type of information that has been harmonized for use in a label, e.g. pictogram,signal word;
No HCS definition Liquid means a substance or mixture which at 50 °C has a vapor pressure of not more than300 kPa (3 bar), which is not completely gaseous at 20 °C and at a standard pressure of 101.3 kPa, and which has a melting point or initial melting point of 20 °C or less at a standard pressure of 101.3 kPa. A viscous substance or mixture for which a specific melting point cannot be determined shall be subjected to the ASTM D 4359-90 test; or to the test for determining fluidity (penetrometer test) prescribed in section 2.3.4 of Annex A of the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR);
"Mixture" means any combination of two or more chemicals if the combination is not, in whole or in part, the result of a chemical reaction. Mixture means a mixture or a solution composed of two or more substances in which they do not react;

Alloy means a metallic material,homogeneous on a macroscopic scale, consisting of two or more elements so combined that they cannot be readily separated by mechanical means. Alloys are considered to be mixtures for the purpose of classification under the GHS.;
"Oxidizer" means a chemical other than a blasting agent or explosive as defined in 1910.109(a), that initiates or promotes combustion in other materials, thereby causing fire either of itself or through the release of oxygen or other gases. Oxidizing gas means any gas which may, generally by providing oxygen, cause or contribute to the combustion of other material more than air does;

Oxidizing liquid means a liquid which, while in itself not necessarily combustible, may, generally by yielding oxygen, cause, or contribute to, the combustion of other material;

Oxidizing solid means a solid which, while in itself not necessarily combustible,may, generally by yielding oxygen, cause, or contribute to, the combustion of other material;
"Organic peroxide" means an organic compound that contains the bivalent -O-O-structure and which may be considered to be a structural derivative of hydrogen peroxide where one or both of the hydrogen atoms has been replaced by an organic radical. Organic peroxide means a liquid or solid organic substance which contains the bivalent -0-0- structure and maybe considered a derivative of hydrogen peroxide, where one or both of the hydrogen atoms have been replaced by organic radicals. The term also includes organic peroxide formulation (mixtures); 
"Identity" means any chemical or common name which is indicated on the material safety data sheet (MSDS) for the chemical.The identity used shall permit cross-references to be made among the required list of hazardous chemicals, the label and the MSDS. "Product identifier": A product identifier means the name or number used for a hazardous product on a label or in the SDS.  It provides a unique means by which the product user can identify the substance or mixture within the particular use setting e.g. transport, consumer or workplace.
"Pyrophoric" means a chemical that will ignite spontaneously in air at a temperature of 130 deg. F (54.4 deg. C) or below. "Pyrophoric Liquid": A pyrophoric liquid is a liquid which, even in small quantities, is liable to ignite within five minutes after coming into contact with air.

"Pyrophoric Solid": A pyrophoric solid is a solid which, even in small quantities, is liable to ignite within five minutes after coming into contact with air.

"Pyrotechnic substance": A substance or mixture of substances designed to produce an effect by heat, light, sound, gas or smoke or a combination of these as the result of non-detonative self-sustaining exothermic chemical reactions.
No HCS definition "Technical name":A name that is generally used in commerce, regulations and codes to identify a substance or mixture, other than the IUPAC or CAS name, and that is recognized by the scientific community. Examples of technical names include those used for complex mixtures (e.g., petroleum fractions or natural products), pesticides (e.g., ISO or ANSI systems), dyestuffs (Color Index system) and minerals.
"Trade secret" means any confidential formula,pattern, process, device, information or compilation of information that is used in an employer's business, and that gives the employer an opportunity to obtain an advantage over competitors who do not know or use it. Appendix D sets out the criteria to be used in evaluating trade secrets. CBI means "confidential business information";
"Unstable (reactive)" means a chemical which in the pure state, or as produced or transported, will vigorously polymerize,decompose, condense, or will become self-reactive under conditions of shocks,pressure or temperature.



"Pyrophoric" means a chemical that will ignite spontaneously in air at a temperature of 130 deg. F (54.4 deg. C) or below.		 "Self-Heating Substance": A self-heating substance is a solid or liquid substance, other than a pyrophoric substance, which, by reaction with air and without energy supply,is liable to self-heat; this substance differs from a pyrophoric substance in that it will ignite only when in large amounts (kilograms) and after long periods of time (hours or days).
"Unstable (reactive)" means a chemical which in the pure state, or as produced or transported, will vigorously polymerize,decompose, condense, or will become self-reactive under conditions of shocks,pressure or temperature. "Self-reactive Substance":  Self-reactive substances are thermally unstable liquid or solid substances liable to undergo a strongly exothermic decomposition even without participation of oxygen (air). This definition excludes substances or mixtures classified under the GHS as explosive,organic peroxides or as oxidizing.
"Water-reactive" means a chemical that reacts with water to release a gas that is either flammable or presents a health hazard "Substances which, in contact with water, emit flammable gases" are solid or liquid substances which, by interaction with water, are liable to become spontaneously flammable or to give off flammable gases in dangerous quantities.


Hazard Determination/Classification
Comparison
A significant difference between the HCS and GHS is the evaluation of mixtures. The GHS criteria for mixtures varies by hazard class. See individual end points for details. The HCS allows test data on mixtures to be used for all hazard classes. The GHS allows test data on carcinogens, mutagens & reproductive toxins on a case-by-case basis. The GHS expectation of physical test data for mixtures is another difference.

The HCS "floor" of hazardous chemicals is a difference and one which is likely helpful to small businesses. Guidance on how IARC, NTP and OSHA carcinogens fit with the GHS cancer classification scheme could also be useful guidance.
OSHAHCS 29CFR1910.12001 GHS2
1910.1200(d) Hazard Determination

(d)(1)

Chemical manufacturers and importers shall evaluate chemicals produced in their work places or imported by them to determine if they are hazardous. Employers are not required to evaluate chemicals unless they choose not to rely on the evaluation performed by the chemical manufacturer or importer for the chemical to satisfy this requirement.

(d)(2)

Chemical manufacturers, importers or employers evaluating chemicals shall identify and consider the available scientific evidence concerning such hazards. For health hazards, evidence which is statistically significant and which is based on at least one positive study conducted in accordance with established scientific principles is considered to be sufficient to establish a hazardous effect if the results of the study meet the definitions of health hazards in this section. Appendix A shall be consulted for the scope of health hazards covered, and Appendix B shall be consulted for the criteria to be followed with respect to the completeness of the evaluation, and the data to be reported.

(d)(3)

The chemical manufacturer, importer or employer evaluating chemicals shall treat the following sources as establishing that the chemicals listed in them are hazardous:

(d)(3)(i)

29CFR part 1910, subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration (OSHA); or,

(d)(3)(ii)

"Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment," American Conference of Governmental Industrial Hygienists(ACGIH) (latest edition). The chemical manufacturer, importer, or employer is still responsible for evaluating the hazards associated with the chemicals in these source lists in accordance with the requirements of this standard.

(d)(4)

Chemical manufacturers, importers and employers evaluating chemicals shall treat the following sources as establishing that a chemical is a carcinogen or potential carcinogen for hazard communication purposes:

(d)(4)(i)

National Toxicology Program (NTP), "Annual Report on Carcinogens" (latest edition);

(d)(4)(ii)

International Agency for Research on Cancer (IARC) "Monographs" (latest editions); or

(d)(4)(iii)

29CFR part 1910, subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration.

(d)(5)

The chemical manufacturer, importer or employer shall determine the hazards of mixtures of chemicals as follows:

(d)(5)(i)

If a mixture has been tested as a whole to determine its hazards, the results of such testing shall be used to determine whether the mixture is hazardous;

(d)(5)(ii)

If a mixture has not been tested as a whole to determine whether the mixture is a health hazard, the mixture shall be assumed to present the same health hazards as do the components which comprise one percent (by weight or volume)or greater of the mixture, except that the mixture shall be assumed to present a carcinogenic hazard if it contains a component in concentrations of0.1 percent or greater which is considered to be a carcinogen under paragraph(d)(4) of this section;

(d)(5)(iii)

If a mixture has not been tested as a whole to determine whether the mixture is a physical hazard, the chemical manufacturer, importer, or employer may use whatever scientifically valid data is available to evaluate the physical hazard potential of the mixture; and,		 1.3.2 General considerations on the GHS
1.3.2.1 Scope of the System
1.3.2.1.1 The GHS applies to pure chemical substances, their dilute solutions and to mixtures of chemical substances."Articles" as defined in the Hazard Communication Standard (29 CFR 1910.1200) of the US Occupational Safety and Health Administration, or by similar definition, are outside the scope of the system.

1.3.2.1.2 One objective of the GHS is for it to be simple and transparent with a clear distinction between classes and categories in order to allow for "self classification" as far as possible. For many hazard classes the criteria are semi-quantitative or qualitative and expert judgment is required to interpret the data for classification purposes. Furthermore, for some hazard classes  (e.g. eye irritation,explosives or self-reactive substances) a decision tree approach is provided to enhance ease of use.

1.3.2.2 Concept of "Classification" 1.3.2.2.1 The GHS uses the term "hazard classification" to indicate that only the intrinsic hazardous properties of substances or mixtures are considered.

1.3.2.2.2 Hazard classification incorporates only 3steps, i.e.:

(a) identification of relevant data regarding the hazards of a substance or mixture;

(b) subsequent review of those data to ascertain the hazards associated with the substance or mixture; and

(c) a decision on whether the substance or mixture will be classified as a hazardous substance or mixture and the degree of hazard, where appropriate, by comparison of the data with agreed hazard classification criteria.

1.3.2.2.3 As noted in IOMC Description and Further Clarification of the Anticipated Application of the GHS text in the Purpose,Scope and Application (Chapter 1.1, paragraph

1.3.2.3 Classification criteria (mixtures)
The classification criteria for substances and mixtures are presented in Parts 2and 3 of this document, each of which is for a specific hazard class or a group of closely related hazard classes. The recommended process of classification of mixtures is based on the following sequence:

(a) Where test data are available for the complete mixture, the classification of the mixture will always be based on that data;

(b) Where test data are not available for the mixture itself, then bridging principles included and explained in each specific chapter should be considered to see whether they permit classification of the mixture;

In addition, for the health and environmental classes,

(c) If (i)test data are not available for the mixture itself, and (ii) the available information is not sufficient to allow application of the above mentioned bridging principles, then the agreed method(s) described in each chapter for estimating the hazards based on the information known will be applied to classify the mixture.

1.3.1.2 UNCETDG/ILO Working Group on Physical Hazards
The UNCETDG/ILO Working Group for Physical Hazards used a similar process to the OECD Task Force on HCL. The work involved a comparison of the major classification systems, identification of similar or identical elements and for the elements, which were dissimilar, development of a consensus on a compromise.For physical hazards, however, the transport definitions, test methods and classification criteria were used as a basis for the work since they were already substantially harmonized. The work proceeded through examination of the scientific basis for the criteria, gaining consensus on the test methods,data interpretation and on the criteria. For most hazard classes, the existing schemes were already in place and being used by the transport sector. On this basis, a portion of the work focused on ensuring that workplace, environment and consumer safety issues were adequately addressed.

Seethe individual health hazard classes for mixture considerations.


Labels
Comparison
The HCS label requirements will now have to be specified. GHS labels have pictograms,as well as specified signal words, and hazard statements. See pictogram table and label element comparison. The HCS provision for no component disclosure on labels is accommodated in the GHS. The use of transport pictograms in non-transport settings is an option, as is the use of a black border for GHS pictograms in domestic settings. See competent authority allowance discussions.
OSHAHCS 29CFR1910.12001 GHS2
1910.1200(f) Labels and Other Forms of Warning

(f)(1)
The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following information:

(f)(1)(i)
Identity of the hazardous chemical(s);

(f)(1)(ii)
Appropriate hazard warnings; and

(f)(1)(iii)
Name and address of the chemical manufacturer, importer, or other responsible party.

(f)(4)
If the hazardous chemical is regulated by OSHA in a substance-specific health standard, the chemical manufacturer, importer, distributor or employer shall ensure that the labels or other forms of warning used are in accordance with the requirements of that standard.

(f)(6)
The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(5) of this section to be on a label. The written materials shall be readily accessible to the employees in their work area throughout each work shift.

(f)(7)
The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. For purposes of this section, drugs which are dispensed by a pharmacy to a health care provider for direct administration to a patient are exempted from labeling.

(f)(11)
Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within three months of becoming aware of the new information. Labels on containers of hazardous chemicals shipped after that time shall contain the new information. If the chemical is not currently produced or imported, the chemical manufacturer, importers,distributor, or employer shall add the information to the label before The chemical is shipped or introduced into the workplace again.		 1.4.6.2 Application of standardization in the harmonized system

For labels, the hazard symbols, signal words and hazard statements have all been standardized and assigned to each of the hazard categories. These standardized elements should not be subject to variation, and should appear on the GHS label as indicated in the Chapters for each hazard class in this document. For safety data sheets, the chapter Hazard Communication: Safety Data Sheets (Chapter1.5) provides a standardized format for the presentation of information. Whilst precautionary information was considered for standardization, there was insufficient time to develop detailed proposals. However, there are examples of precautionary statements and pictograms in Annex 3 and it remains a goal to develop them into fully standardized label elements.

1.4.6.3 Use of non-standardized or supplemental information
1.4.6.3.1 There are many other label elements which may appear on a label which have not been standardized in the harmonized system. Some of these clearly need to be included on the label, for example precautionary statements. Competent authorities may require additional information, or suppliers may choose to add supplementary information on their own initiative. In order to ensure that the use of non-standardized information does not lead to unnecessarily wide variation in information or undermine GHS information, the use of supplementary information should be limited to the following circumstances:

(a) the supplementary information provides further detail and does not contradict or cast doubt on the validity of the standardized hazard information; or;

(b) the supplementary information provides information about hazards not yet incorporated into the GHS.

In either instance, the supplementary information should not lower standards of protection.

1.4.6.3.2 The labeler should have the option of providing supplementary information related to the hazard, such as physical state or route of exposure, with the hazard statement rather than in the supplementary information section on the label, see also paragraph1.4.10.5.4.1.

1.4.10 Labeling procedures
1.4.10.1 Scope
The following sections describe the procedures for preparing labels in the GHS, comprising the following:

(a)Allocation of label elements;

(b)Reproduction of the symbol;

(c)Reproduction of the hazard pictogram;

(d)Signal words;

(e)Hazard statements;

(f)Precautionary statements and pictograms;

(g)Product and supplier identification;

(h)Multiple hazards and precedence of information;

(i)Arrangements for presenting the GHS label elements;

(j)Special Labeling arrangements.

1.4.10.2 Label elements
The tables in the individual Chapters for each hazard class detail the label elements (symbol,signal word, hazard statement) that have been assigned to each of the hazard categories of the GHS. Hazard categories reflect the harmonized classification criteria. A summary of the allocation of label elements is provided in Annex 1. There are special arrangements, which apply to the use of certain mixture concentrations in the GHS to take account of the information needs of different target audiences. These are further described in paragraph 1.4.10.5.4

1.4.10.5.2 Information required on a GHS label

(a) Signal words
A signal word means a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used in the GHS are "Danger" and "Warning". "Danger" is used for the more severe hazard categories (i.e. in the main for hazard categories 1 and 2), while "Warning"is used for the less severe. The tables in the individual Chapters for each hazard class detail the signal words that have been assigned to each of the hazard categories of the GHS.

(b) Hazard statements
A hazard statement means a phrase 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. The tables of label elements in the individual Chapters for each hazard class detail the hazard statements that have been assigned to each of the hazard categories of the GHS.

(c)Precautionary statements and pictograms
A precautionary statement means a phrase (and/or pictogram) that describes recommended measures that should betaken to minimize or prevent adverse effects resulting from exposure to a hazardous product, or improper storage or handling of a hazardous product.The GHS label should include appropriate precautionary information, the choice of which is with the labeler or the competent authority. Annex 3contains examples of precautionary statements, which can be used, and also examples of precautionary pictograms, which can be used where allowed by the Competent Authority.

(d)Product identifier

(i)A product identifier should be used on a GHS label and it should match the product identifier used on the SDS. Where a substance or mixture is covered by the UN Model Regulations on the Transport of Dangerous Goods, the UN proper shipping name should also be used on the package;

(ii)The label for a substance should include the chemical identity of the substance. For mixtures or alloys, the label should include the chemical identities of all ingredients or alloying elements that contribute to acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity,reproductive toxicity, skin or respiratory sensitization, or Target Organ Systemic Toxicity (TOST), when these hazards appear on the label. Alternatively, the Competent Authority may require the inclusion of all ingredients or alloying elements that contribute to the hazard of the mixture or alloy;

(iii)Where a substance or mixture is supplied exclusively for workplace use, the Competent authority may choose to give suppliers discretion to include chemical identities on the SDS, in lieu of including them on labels;

(iv)The competent authority rules for CBI take priority over the rules for product identification. This means that where an ingredient would normally be included on the label, if it meets the competent authority criteria for CBI,its identity does not have to be included on the label.

(e)Supplier identification

1.4.10.5.4 Arrangements for presenting the GHS label elements
1.4.10.5.4.1 Location of GHS information on the label
The GHS hazard pictograms, signal word and hazard statements should be located together on the label. The Competent Authority may choose to provide a specified layout for the presentation of these and for the presentation of precautionary information, or allow supplier discretion. Specific guidance and examples are provided in the Chapters on individual hazard classes.


Workplace Labeling
Comparison
The HCS workplace labeling option is allowed in the GHS. This option is a common practice in many USA workplaces. See competent authority allowance discussion.
OSHAHCS 29CFR1910.12001 GHS2
1910.1200(f) (6)-(7) Workplace Labeling

(f)(6)
The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(5) of this section to be on a label. The written materials shall be readily accessible to the employees in their work area throughout each work shift.

(f)(7)
The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. For purposes of this section, drugs which are dispensed by a pharmacy to a health care provider for direct administration to a patient are exempted from labeling.		 1.4.10.5.5.1 Workplace labeling

Products falling within the scope of the GHS will carry the GHS label at the point where they are supplied to the workplace, and that label should be maintained on the supplied container in the workplace. The GHS label or label elements should also be used for workplace containers. However, the competent authority can allow employers to use alternative means of giving workers the same information in a different written or displayed format when such a format is more appropriate to the workplace and communicates the information as effectively as the GHS label. For example, label information could be displayed in the work area, rather than on the individual containers.

Alternative means of providing workers with the information contained in GHS labels are needed usually where hazardous chemicals are transferred from an original supplier container into a workplace container or system, or where chemicals are produced in a workplace but are not packaged in containers intended for sale or supply. Chemicals that are produced in a workplace may be contained or stored in many different ways such as: small samples collected for testing or analysis, piping systems including valves, process or reaction vessels,ore cars, conveyer systems or free-standing bulk storage of solids. In batch manufacturing processes, one mixing vessel may be used to contain a number of different chemical mixtures.

In many situations, it is impractical to produce a complete GHS label and attach it to the container, due, for example, to container size limitations or lack of access to a process container. Some examples of workplace situations where chemicals may be transferred from supplier containers include: containers for laboratory testing or analysis, storage vessels, piping or process reaction systems or temporary containers where the chemical will be used by one worker within a short time frame. Decanted chemicals intended for immediate use could be labeled with the main components and directly refer the user to the supplier label information and SDS.

All such systems should ensure that there is clear hazard communication. Workers should be trained to understand the specific communication methods used in a workplace. Examples of alternative methods include: use of product identifiers together with GHS symbols and other pictograms to describe precautionary measures; use of process flow charts for complex systems to identify chemicals contained in pipes and vessels with links to the appropriate SDS; use of displays with GHS symbols, color and signal words in piping systems and processing equipment; use of permanent placarding for fixed piping; use of batch tickets or recipes for labeling batch mixing vessels and use of piping bands with hazard symbols and product identifiers.


Updating Labels
Comparison
The current HCS requirements for updating labels are accommodated by the GHS. Other options could be considered for the purpose of harmonization. See competent authority allowances discussion.
OSHAHCS 29CFR1910.12001 GHS2
1910.1200(f)(11) updating labels

(f)(11)

Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within three months of becoming aware of the new information. Labels on containers of hazardous chemicals shipped after that time shall contain the new information. If the chemical is not currently produced or imported, the chemical manufacturer, importers,distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.

 1.4.7 Updating information

All systems should specify a means of responding in an appropriate and timely manner to new information and updating labels and SDS information accordingly. The following are examples of how this could be achieved.

1.4.7.2 General guidance on updating of information
1.4.7.2.1 Suppliers should respond to "new and significant" information they receive about a chemical hazard by updating the label and safety data sheet for that chemical. New and significant information is any information that changes the GHS classification of the substance or mixture and leads to a resulting change in the information provided on the label or any information concerning the chemical and appropriate control measures that may affect the SDS. This could include, for example, new information on the potential adverse chronic health effects of exposure as a result of recently published documentation or test results, even if a change in classification may not yet be triggered.

1.4.7.2.2 Updating should be carried out promptly on receipt of the information that necessitates the revision. The competent authority may choose to specify a time limit within which the information should be revised. This applies only to labels and SDS for products that are not subject to an approval mechanism such as pesticides. In pesticide labeling systems, where the label is part of the product approval mechanism, suppliers cannot update the supply label on their own initiative. However when the products are subject to the transport of dangerous goods requirements, the label used should be updated on receipt of the new information, as above.

1.4.7.2.3 Suppliers should also periodically review the information on which the label and safety data sheet for a substance or mixture is based, even if no new and significant information has been provided to them in respect of that substance or mixture. This will require e.g. a search of chemical hazard databases for new information. The competent authority may choose to specify a time (typically 3 -- 5 years) from the date of original preparation, within which suppliers should review the labels and SDS information.


MSDS/SDS
Comparison
The performance orientation of the HCS MSDS will need to be changed. The GHS requires a 16 section MSDS format with specified sequence and minimum required contents. See separate table for more detailed comparison of MSDS sections/information.

Based on requirements in existing systems, there is some discretion in the GHS for determining when an MSDS is required. The hazard pictogram/symbol can be graphically reproduced on the MSDS or the name of the symbol may be provided instead. The level of hazardous components can be given as ranges or concentrations.
OSHAHCS 29CFR1910.12001 GHS2
1910.1200(g) MSDS

(g)(2)
Each material safety data sheet shall be in English (although the employer may maintain copies in other languages as well), and shall contain at least the following information:

(g)(2)(i)
The identity used on the label, and, except as provided for in paragraph (i) of this section on trade secrets:

(g)(2)(i)(A)
If the hazardous chemical is a single substance, its chemical and common name(s);

(g)(2)(i)(B)
If the hazardous chemical is a mixture which has been tested as a whole to determine its hazards, the chemical and common name(s) of the ingredients which contribute to these known hazards, and the common name(s) of the mixture itself; or,

(g)(2)(i)(C)
If the hazardous chemical is a mixture which has not been tested as a whole:

(g)(2)(i)(C)(1)
The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise 1% or greater of the composition, except that chemicals identified as carcinogens under paragraph (d) of this section shall be listed if the concentrations are 0.1% or greater; and,

(g)(2)(i)(C)(2)
The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise less than 1% (0.1% for carcinogens) of the mixture, if there is evidence that the ingredient(s) could be released from the mixture in concentrations which would exceed an established OSHA permissible exposure limit or ACGIH Threshold Limit Value, or could present a health risk to employees; and,

(g)(2)(i)(C)(3)
The chemical and common name(s) of all ingredients which have been determined to present a physical hazard when present in the mixture;

(g)(2)(ii)
Physical and chemical characteristics of the hazardous chemical (such as vapor pressure, flash point);

(g)(2)(iii)
The physical hazards of the hazardous chemical, including the potential for fire,explosion, and reactivity;

(g)(2)(iv)
The health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical;

(g)(2)(v)
The primary route(s) of entry;

(g)(2)(vi)
The OSHA permissible exposure limit, ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the material safety data sheet, where available;

(g)(2)(vii)
Whether the hazardous chemical is listed in the National Toxicology Program (NTP)Annual Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer(IARC) Monographs (latest editions), or by OSHA;

(g)(2)(viii)
Any generally applicable precautions for safe handling and use which are known to the chemical manufacturer, importer or employer preparing the material safety data sheet, including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for clean-up of spills and leaks;

(g)(2)(ix)
Any generally applicable control measures which are known to the chemical manufacturer, importer or employer preparing the material safety data sheet,such as appropriate engineering controls, work practices, or personal protective equipment;

(g)(2)(x)
Emergency and first aid procedures;

(g)(2)(xi)
The date of preparation of the material safety data sheet or the last change to it; and,

(g)(2)(xii)
The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures,if necessary.

(g)(3)
If no relevant information is found for any given category on the material safety data sheet, the chemical manufacturer, importer or employer preparing the material safety data sheet shall mark it to indicate that no applicable information was found.

(g)(5) [MSDS Updating]
The chemical manufacturer, importer or employer preparing the material safety data sheet shall ensure that the information recorded accurately reflects the scientific evidence used in making the hazard determination. If the chemical manufacturer, importer or employer preparing the material safety data sheet becomes newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards, this new information shall be added to the material safety data sheet within three months. If the chemical is not currently being produced or imported the chemical manufacturer or importer Shall add the information to the material safety data sheet before the chemical is introduced into the workplace again.

(g)(10) [MSDS Format]
Material safety data sheets may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual hazardous chemicals. However, the employer shall ensure that in all cases the required information is provided for each hazardous chemical, and is readily accessible during each work shift to employees when they are in their work area(s).		 Table 1.5.2 Minimum information for an SDS

(1) Product and company identification
-   GHS product identifier
-   Other means of identification.
-   Recommended use of the chemical and restrictions on use.
-   Supplier's details (including name, address,phone number etc).
-   Emergency phone number

(2) Hazards identification
-   GHS classification of the substance/mixture and any regional information.
-   GHS label elements, including precautionary statements.  (Hazard symbols may be provided as a graphical reproduction of the symbols in black and white or the name of the symbol e.g. flame, skull and crossbones.)
-   Other hazards which do not result in classification (e.g. dust explosion hazard) or are not covered by the GHS.

(3)Composition/ Information On Ingredients
Substance
-   Chemical identity
-   Common name, synonyms etc.
-   CAS number, EC number etc.
-   Impurities and stabilizing additives which are themselves classified and which contribute to the classification of the substance
Mixture
-   The chemical identity and concentration or concentration ranges of all ingredients which are hazardous within the meaning of the GHS and are present above their cut-off levels.
-   Cutoff level for reproductive toxicity,carcinogenicity and category 1 mutagenicity is > 0.1%
-   Cutoff level for all other hazard classes is > 1%

Note: For information on ingredients, the competent authority rules for CBI take priority over the rules for product identification.

(4) First-aid measures
• Description of necessary measures, subdivided according to the different routes of exposure, i.e. inhalation, skin and eye contact and ingestion.
• Most important symptoms/effects, acute and delayed.

• Indication of immediate medical attention and special treatment needed, if necessary

(5) Fire-fighting measures
Suitable (and unsuitable) extinguishing media. Specific hazards arising from the chemical (e.g. nature of any hazardous combustion products).
• Special protective equipment and precautions for fire-fighters

(6) Accidental release measures
-   Personal precautions, protective equipment and emergency procedures.
-   Environmental precautions.
-   Methods and materials for containment and cleaning up.

(7) Handling and storage
• Precautions for safe handling.
• Conditions for safe storage, including any incompatibilities

(8) Exposure controls/personal protection
-   Control parameters e.g. occupational exposure limit values or biological limit values.
-   Appropriate engineering controls.
-   Individual protection measures, such as personal protective equipment

(9)Physical and chemical properties
-   Appearance (physical state, color etc)
-   Odor
-   Odor threshold
-   pH
-   melting point/freezing point
-   initial boiling point and boiling range
-   flash point:
-   evaporation rate
-   flammability (solid, gas)
-   upper/lower flammability or explosive limits
-   vapor pressure
-   vapor density
-   relative density:
-   solubility(ies)
-   partition coefficient: n-octanol/water:
-   auto-ignition temperature decomposition temperature

(10) Stability and reactivity-   Chemical stability.
-   Possibility of hazardous reactions.
-   Conditions to avoid (e.g. static discharge,shock or vibration)
-   Incompatible materials
-   Hazardous decomposition products

(11) Toxicological information
Concise but complete and comprehensible description of the various toxicological(health) effects and the available data used to identify those effects,including:
-   information on the likely routes of exposure(inhalation, ingestion, skin and eye contact);
-   Symptoms related to the physical, chemical and toxicological characteristics;
-   Delayed and immediate effects and also chronic effects from short- and long-term exposure.
-   Numerical measures of toxicity (such as acute toxicity estimates).

(12) Ecological information
-   Ecotoxicity (aquatic and terrestrial, where available).
-   Persistence and degradability
-   Bioaccumulative potential
-   Mobility in soil
-   Other adverse effects

(13) Disposal considerations
• Description of waste residues and information on their safe handling and methods of disposal, including any contaminated packaging.

(14) Transport information
• UN number
• UN Proper shipping name.
• Transport Hazard class(es).
• Packing group, if applicable.
• Marine pollutant (Yes/No).
• Special precautions which a user needs to be aware of or needs to comply with in connection with transport or conveyance either within or outside their premises.

(15) Regulatory information
• Safety, health and environmental regulations specific for the product in question.

(16) Other information
• Other information including information on  preparation and revision of the SDS

1.5.2 Criteria for determining whether an SDS should be produced
An SDS should be produced for all substances and mixtures which meet the harmonized criteria for physical,health or environmental hazards under the GHS and for all mixtures which contain substances that meet the criteria for carcinogenic, toxic to reproduction or target organ systemic toxicity in concentrations exceeding the cut-off limits for SDS specified by the criteria for mixtures (see paragraph 6)The competent authority may choose also to require SDSs for mixtures not meeting the criteria for classification as hazardous but which contain hazardous substances in certain concentrations (see paragraph 6).

An SDS should be provided based on the following generic cut-off /concentration limits:

> 1% for acute toxicity, skin corrosion/irritation, serious damage to eyes/eye irritation, respiratory/skin sensitization, mutagenicity category 2, target organ toxicity (single & repeat) exposures, and hazardous to the environment; and

> 0.1% for mutagenicity category 1, carcinogenicity and reproductive toxicity.

As noted in the Classification of Hazardous Substances and Mixtures (Chapter 1.2,paragraphs 28-31), there may be some cases when the available hazard data may justify classification on the basis of other cut-off-limits than the generic ones specified in the health and environment hazard class chapters (Chapters 3.2 to 3.10). When such specific cut-offs are used for classification, they should also apply to the obligation to compile an SDS.

Some competent authorities (CA) may require SDSs to be compiled for mixtures which are not classified for acute toxicity or aquatic toxicity as a result of application of the additivity formula, but which contain acutely toxic substances or substances toxic to the aquatic environment in concentrations equal to or greater than 1 %.

In accordance with the building block principle, some competent authorities may choose not to regulate certain categories within a hazard class. In such situations, there would be no obligation to compile a SDS.

(The above 4 paragraphs are not part of the agreed text on hazard communication including SDSs developed by the ILO  Working  Group on Hazard Communication, but have been provided here as additional guidance on the compiling of an SDS).

Once it is clear that a SDS is required for a substance or a mixture then the information required to be included in the SDS should in all cases be provided in accordance with GHS requirements.


MSDS/SDS Component Disclosure
Comparison
The values for component disclosure in mixtures vary by end point. Some changes will be required on MSDS component disclosure. The level of hazardous components can be given as ranges or concentrations in the MSDS.
OSHA HCS 29CFR1910.12001 GHS2
(g)(2)(i)
The identity used on the label, and,except as provided for in paragraph (i) of this section on trade secrets:

(g)(2)(i)(A)
If the hazardous chemical is a single substance, its chemical and common name(s);

(g)(2)(i)(B)
If the hazardous chemical is a mixture which has been tested as a whole to determine its hazards, the chemical and common name(s) of the ingredients which contribute to these known hazards, and the common name(s) of the mixture itself; or,

(g)(2)(i)(C)
If the hazardous chemical is a mixture which has not been tested as a whole:

(g)(2)(i)(C)(1)
The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise 1% or greater of the composition, except that chemicals identified as carcinogens under paragraph (d) of this section shall be listed if the concentrations are 0.1% or greater; and,

(g)(2)(i)(C)(2)
The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise less than 1% (0.1% for carcinogens) of the mixture, if there is evidence that the ingredient(s) could be released from the mixture in concentrations which would exceed an established OSHA permissible exposure limit or ACGIH Threshold Limit Value, or could present a health risk to employees; and,

(g)(2)(i)(C)(3)
The chemical and common name(s) of all ingredients which have been determined to present a physical hazard when present in the mixture;		 Table 1.5.2 Minimum information for an SDS3.
Composition/information on ingredients
Substance
• Chemical identity.
• Common name, synonyms, etc.
• CAS number, EC number, etc.
• Impurities and stabilizing additives which are themselves classified and which contribute to the classification of the substance
Mixture
• The chemical identity and concentration or concentration ranges of all ingredients which are hazardous within the meaning of the GHS and are present above their cut-off levels.
NOTE: For information on ingredients, The competent authority rules for CBI take priority over the rules for product identification.

1.5.2 Criteria for determining whether an SDS should be produced
An SDS should be produced for all substances and mixtures which meet the harmonized criteria for physical, health or environmental hazards under the GHS and for all mixtures which contain substances that meet the criteria for carcinogenic, toxic to reproduction or target organ systemic toxicity in concentrations exceeding the cut-off limits for SDS specified by the criteria for mixtures (see paragraph1.5.3.1). The competent authority may choose also to require SDSs for mixtures not meeting the criteria for classification as hazardous but which contain hazardous substances in certain concentrations (seeparagraph1.5.3.1).

1.5.3 General guidance for compiling a Safety Data Sheet
1.5.3.1 Cut-off values/concentration limits
1.5.3.1.1 An SDS should be provided based on the generic cut-off values/concentration limit

> 1% for acute toxicity, skin corrosion/irritation,serious damage to eyes/eye irritation, respiratory/skin sensitization,mutagenicity category 2, target organ toxicity (single & repeat)exposures, and hazardous to the environment; and

> 0.1% for mutagenicity category 1, carcinogenicity and reproductive toxicity, (sensitizes).

1.5.3.1.2 As noted in the Classification of Hazardous Substances and Mixtures (see 1.3.3.2), there may be some cases when the available hazard data may justify classification on the basis of other cut-off values/concentration limits than the generic ones specified in the health and environment hazard class chapters (Chapters 3.2 to 3.10). When such specific cut-off values are used for classification, they should also apply to the obligation to compile an SDS.

1.5.3.1.3 Some competent authorities (CA) may require SDSs to be compiled for mixtures which are not classified for acute toxicity or aquatic toxicity as a result of application of the additivity formula, but which contain acutely toxic substances or substances toxic to the aquatic environment in concentrations equal to or greater than 1 %.

1.5.3.1.4 In accordance with the building block principle, some competent authorities may choose not to regulate certain categories within a hazard class. In such situations, there would be no obligation to compile an SDS.

(The paragraphs 1.5.3.1 -- 1.5.3.4 are not part of the agreed text on hazard communication including SDSs developed by the ILO Working Group on Hazard Communication, but have been provided here as additional guidance on the compiling of an SDS).

1.5.3.1.5 Once it is clear that an SDS is required for a substance or a mixture then the information required to be included in the SDS should in all cases be provided in accordance with GHS requirements.


Updating MSDS/SDS
Comparison
The current HCS requirements for updating MSDS are accommodated by the GHS. Other options could be considered for the purpose oh harmonization.
OSHAHCS 29CFR1910.12001 GHS2
1910.1200(g)(5) updating MSDS

(g)(5) [MSDS Updating]

The chemical manufacturer, importer or employer preparing the material safety data sheet shall ensure that the information recorded accurately reflects the scientific evidence used in making the hazard determination. If the chemical manufacturer, importer or employer preparing the material safety data sheet becomes newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards, this new information shall be added to the material safety data sheet within three months. If the chemical is not currently being produced or imported the chemical manufacturer or importer shall add the information to the material safety data sheet before the chemical is introduced into the workplace again.		 1.4.7 Updating information
All systems should specify a means of responding in an appropriate and timely manner to new information and updating labels and SDS information accordingly. The following are examples of how this could be achieved.

1.4.7.2 General guidance on updating of information
1.4.7.2.1 Suppliers should respond to "new and significant" information they receive about a chemical hazard by updating the label and safety data sheet for that chemical. New and significant information is any information that changes the GHS classification of the substance or mixture and leads to a resulting change in the information provided