| Last time I watched “Ice Road Truckers” on TV, I noticed part of the filming was in Winnipeg, Manitoba, Canada. I went to high school in Canada; Selkirk, Manitoba to be more precise, which is 60 miles due north of Winnipeg. It was an outbound school, 2 week dog runs, 700 mile canoe trips and 50 mile snowshoe races. I loved it. I didn’t always excel in the classroom, but I really loved the outdoor programs.
1974
Back then, in school we were all required to learn both English and French. Canada has a rich French history. The French were the first Europeans to paddle and dogsled across its vast unknowns. Our school celebrated that spirit and history by retracing their hiking, portaging, canoeing, snowshoeing and dog sledding across pristine lakes, wild rapids and long forgotten, frozen, overgrown winter roads.
FRENCH
By law, French-speaking Canadians were required to be taught English and English-speaking Canadians were to be taught French. In addition, the Canadian government required all public information to be displayed in both French and English. So, no matter one’s primary language or attention span during French class, any important public information could always be equally understood.
This was also the plan under the international United Nations Global Harmonization System (GHS). Can you imagine how hard it would be to prepare a hazardous chemical’s international SDS and its container labels for shipments to France, Germany, Spain, and Italy (and that would just be for just your European customers)?
UN GHS NUMERICAL SYSTEM
Well, that’s why in the international GHS, the UN recommended including a numerical cross-reference system on the international GHS container labels. That’s right, the UN’s GHS recommended including a numerical cross-reference alongside the written hazard communication information on the container labels, so that regardless of the language on the labels, employees could simply look up the information in their own language using the P or H numbers instead of the written words on the labels. For example, Keep away from heat is number P210, Combustible liquid is H227, wear eye protection is number P280 and Use personal protective equipment is number P281.
INTERNATIONAL EMERGENCY RESPONSE GUIDE
This is very similar to the way the the international UN Numbers are displayed on trucks and bulk containers inside the orange panel or placards under the DOT Hazardous Materials Regulations and UN Dangerous Goods Recommendations. The UN numbers are used with the International Emergency Response Guide (ERG), which is compiled by Argentinian, Mexican, Canadian and the US governments and is printed in English, French and Spanish. In this way, the UN number can be cross-referenced with the emergency response information regardless of the emergency responder’s native language.
REGULATIONS AND RECOMMENDATIONS
Unfortunately, OSHA did not adopt the UN’s GHS in its entirety. OSHA only aligned with some of the international GHS Hazard Communication Recommendations. That’s because the UN can only recommend requirements, not promulgate or enforce them. That’s why they are called “recommendations.” It would have been nice if OSHA had decided to adopt all of it. But OSHA decided not include the International P and H numerical cross-references, the international marine pollutant tests, and the 5th Hazard Category.
SIMILAR BUT NOT THE SAME
So when you see the tiny red marine pollutant pictograms, the numerical cross-references on international GHS container labels or Category #5 on international SDSs coming in from other countries around the world, relax. Just tell your boss even though it may be a DOT marine pollutant domestically on the shipping paper and the side of the drum (as listed in 49 CFR Appendix B to the 172.101 Hazardous Material Table), it is not under OSHA. OSHA refused to adopt the UN GHS marine pollutant requirements because OSHA’s authority is not to protect aquatic life, just human life.
NO WE DIDN’T
First, OSHA didn’t adopt the UN GHS Marine Pollutant testing recommendations. Second, DOT shipping regulations for marine pollutants are based on container sizes, the mode of transportation and their percentages inside each container as listed in Appendix B. And third, the UN GHS, in addition to their marine pollutant list, has an additional requirement to test or at the very least deploy bridging principles for classification of marine pollutants.
BUY THIS BOOK
If you were to secure a copy of the UN GHS Recommendations you would see there is a Category #5, which does not exist under the OSHA GHS; domestically OSHA only has Categories #1 through #4. You should see for yourself the international numerical cross-references on their container labels, which are not required domestically under OSHA’s 29 CFR 1910.1200 Hazard Communication Regulations.
READY OR NOT
I hope you have been trying to update your old Material Safety Data Sheets (MSDS) to meet the new GHS Safety Data Sheet (SDS) Requirements. As of June 1, 2015, the new SDS format is required and container labels must be affixed by the responsible parties. Don’t worry, I have seen very few companies whose SDSs and container labels are 100% OSHA GHS compliant, as I am sure that OSHA is aware.
ONE MORE TIME
I said it once and I am going to say it again, there are very few changes under OSHA’s “new” 1910.1200 Hazard Communication Regulations. Really the only major change between the old and the new OSHA GHS is that OSHA added the brand new Appendix A Heath Hazards, Appendix B Physical Hazards, Appendix C Allocation of Label Elements, and Appendix D SDS Format Requirements.
RELAX
So don’t freak out if someone’s international GHS SDS looks a little different than your domestic SDS under OSHA. If you’re SDS is not exactly the same as one you received from France, that may just mean it is correct under OSHA .If you just copy the mandatory information in SDS Section #1 Identification and Section #2 Hazard(s) Identification onto your container labels, you will meet most of the new GHS requirements.
This is all we do, so if you’re SDS looks like it’s “in a different language” or you have any questions on hazardous materials, hazardous waste, hazardous chemicals or hazardous substances compliance, give us a call, or better yet sign up for our next seminar when we’re in your town. We are sure you will be glad that you did. Thank you for your readership and support |
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