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See attached **files (2)** – ## UnitVIIIJournal.docx – ## UnitVIII.pdf **## UnitVIIIJournal.docx** Your company is looking to purchase a small chemical company in Southern California. The company produces commodity organic chemicals that are used as building blocks to synthesize complex molecules fo…
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See attached
**files (2)**
– ## UnitVIIIJournal.docx
– ## UnitVIII.pdf
**## UnitVIIIJournal.docx**
Your company is looking to purchase a small chemical company in Southern California. The company produces commodity organic chemicals that are used as building blocks to synthesize complex molecules for use in the pharmaceutical industry. Identify the air quality management districts in Southern California and the requirements of state implementation plans (SIP) that you find that are in effect for the small company. Make a recommendation to management to go forward with the acquisition or to consider other options in their growth strategy.
Your journal entry must be at least 200 words in length. No references or citations are necessary.
**## UnitVIII.pdf**
OSH 2302, Introduction to Regulatory Compliance 1
Course Learning Outcomes for Unit VIII
Upon completion of this unit, students should be able to:
1. Summarize important environmental safety and health-related laws.
1.1 Apply information from the Global Harmonized System of Classification and Labelling of
Chemicals (GHS) to a given scenario.
2. Discuss the primary responsibilities of environmental health and safety regulatory services.
2.1 Analyze a safety data sheet (SDS).
2.2 Recommend the proper procedures for handling a hazardous substance.
2.3 Discuss the measures that should be taken when using a hazardous substance in a
manufacturing operation.
Required Unit Resources
Chapter 6: Hazard Communication and Right-to-Know Regulations
In order to access the following resource, click the link below.
The document below is the GHS that was referenced in the unit lesson. Please read Chapters 1.1 through 1.5
(the Introduction section). It will give you an overview of this important document and help you complete the
assignment for this unit.
United Nations. (2011). Globally harmonized system of classification and labelling of chemicals (GHS) (4th
Rev. ed.).
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=e000xna&AN=387589&site=ehost-live&scope=site
Unit Lesson
Introduction
Chemicals are regulated by the Environmental Protection Agency (EPA) because they have the potential to
adversely impact human health and the environment. The environmental regulations are designed to
minimize exposure. The purpose of this unit is to present the hazard classification scheme and to show the
criteria used to measure hazard categories. The hazards are classified, which allows those coming into
contact with the chemicals to understand their threat and to have the necessary information to determine if
the chemical can be used safely in the facility.
Chemical Classifications
As the markets for chemicals grew and as workers, consumers, and the environment began to experience
adverse effects from their use, countries around the world began to implement chemical programs to manage
toxic chemicals and their hazards. Each country set up its own system for classifications, labeling, and the
definitions they applied to toxic, hazardous, dangerous, safe, etc. What was classified as hazardous in one
country was toxic in another, and what was considered to be safe in one place was restricted and controlled
in another. When trade in chemicals and their products experienced an upsurge in world markets, it was
impossible for regulators, customs, and end users to understand and make sense of the hazards identified on
product labels. The United Nations recognized that international trade would become restricted unless a
common and consistent international safety standard was used across the globe to classify chemicals and to
UNIT VIII STUDY GUIDE
Chemical Classifications and
the Communications of Hazards
[https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site](https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site)
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OSH 2302, Introduction to Regulatory Compliance 2
UNIT x STUDY GUIDE
Title
represent their hazards. This classification system became known as the Globally Harmonized System of
Classification and Labeling of Chemicals (GHS) and also included requirements for safety data sheets (SDSs)
and container labels (Occupational Safety and Health Administration [OSHA], n.d.).
The GHS classification system categorizes hazards into the following three categories:
1. physical/chemical hazards;
2. human and mammalian toxicity; and
3. environmental toxicity.
There are more than 28 categories of hazards that are aligned with nine hazard pictograms (United Nations
Economic Commission for Europe [UNECE], 2017). The GHS is reviewed by a United Nations committee
every 2 years at which time new hazard categories and criteria are implemented. While the GHS is intended
to be a unifying system that harmonizes the identification and communication of hazards, it has not
accomplished this in its roll out. The GHS is voluntary, and countries that want to participate in international
trade are choosing to adopt it into their national laws. Countries are not required to adopt all of the GHS
system as they can pick and choose what elements of GHS they want to incorporate into their national
regulations.
For example, Europe, China, and Japan have adopted all elements of the GHS, whereas the United States
and Canada have not adopted the environmental elements of the GHS. In Europe, it is easy to identify
products that are harmful to the environment. However, in the United States, environmental hazards are not
mentioned because only OSHA agreed to adopt the GHS, and the elements affecting worker safety became a
part of the U.S. standard. The EPA did not agree to adopt the environmental elements of GHS because this
would conflict with current programs that the EPA had in place. Canada followed the U.S. lead. Health
Canada adopted the same elements as the U.S. OSHA while Environment Canada followed the lead of the
U.S. EPA.
Examples of physical hazard include the categories of explosives, flammable solids and liquids, self-reacting,
and heating substances and mixtures. Examples of health hazards include acute toxicity; skin and eye
corrosion/irritation; skin and respiratory sensitizer; and carcinogen, mutagen, and reproductive toxicant.
Environmental hazards include the categories of acute and chronic aquatic toxicity and hazardous to the
ozone layer (UNECE, 2017). Each of these categories have defined criteria that are used to classify the
hazards of a chemical or mixture.
Communication of Hazards
The hazards of a product are communicated via the SDS and the container label. The SDS is a 16-section
document starting with the identity of the chemical and the manufacturer. Section 2 identifies the product
hazards. It lists the GHS categories and subcategories for each of the applicable 28 hazards. The applicable
pictogram is provided along with a signal word indicating danger or warning (UNECE, 2017). Hazard
statements are also provided that list the specific hazard indicated by the pictograms. It takes all three
elements (pictogram, signal word, and hazard statement) to understand the hazards of each product.
Following the designation of the hazards, precautionary statements follow that help to define the safe use of
the product and, if implemented, will help to mitigate the hazards of the product.
Section 3 of the SDS lists the individual chemical substances and complexes that contribute to the product
classification (UNECE, 2017). For products that are mixtures of chemicals, it is not uncommon to see multiple
chemicals listed in Section 3 along with their Chemical Abstract Service (CAS) number and their approximate
percentage in the product.
Other sections of the SDS cover first aid measures, firefighting measures, accidental release measures, and
handling and storage precautions. The storage section contains warnings that require the separation of acids
and bases as well as the separation of oxidizers and reducing agents. For very dangerous chemicals, a
recommendation is often made to quarantine these and lock them into a limited access area. Section 8 of the
SDS contains important information for the site industrial hygienist. Chemical substances in the mixture that
have an OSHA exposure standard are listed with the allowable exposure value. These standards can be time
OSH 2302, Introduction to Regulatory Compliance 3
UNIT x STUDY GUIDE
Title
weighted averages, short-term exposure levels, permissible exposure limits, and any state-specific standards
published for their list of chemicals of concern (UNECE, 2017).
The industrial hygiene lead can reference these exposure limits to set up monitoring for employees and the
facility to measure exposure levels against the standards. If any recommended level is exceeded,
administrative controls, engineering controls, and personal protective equipment can be put into place to
protect the employee. It is not uncommon to see enhanced ventilation and equipment in enclosures that put a
barrier between the chemical and the employee. Section 8 also lists supplier recommendations from the
manufacturer. These include recommendations for face shields, chemical-resistant gloves, long-sleeve
clothing, and chemical-resistant sleeves that keep clothing dry and clean (UNECE, 2017). No one wants to
expose their family to chemical hazards when they take contaminated clothing home to be washed.
Section 9 lists the physical/chemical properties of the substance (UNECE, 2017). Vapor density will indicate if
it is a chemical that will sink to the floor or rise into the air; imagine crawling along the floor to avoid smoke
from a fire only to be fully exposed to a toxic chemical that has a density heavier than air. Section 9 will
indicate if a chemical is water-soluble. In the event of a spill, hoses are often used to wash material into a
floor drain. A water-soluble chemical that dissolves in the wash water is carried down the floor drain to an
onsite treatment system ultimately making its way into a river where the chemical can have adverse effects on
aquatic life for years to come. Section 10 discusses the stability and reactivity of the chemical. It is in this
section that the rationale for putting chemicals into segregated storage are explained (UNECE, 2017).
Sections 11 and 12 of the SDS provide toxicity data for individual chemicals (UNECE, 2017). If the
manufacturer has tested the product and has toxicity data, this is where it is included. However, testing is
expensive, and for low-volume products, testing cannot be justified. There is website from the European
Chemicals Agency (ECHA) that contains a wealth of information on the chemicals from European
manufacturers and importers who have completed mandatory testing protocols to support a chemical
registration. Section 12 is a similar section that provides environmental data and effects (UNECE, 2017).
Section 13 covers disposal considerations, but because of a multitude of local laws and requirements, most
SDS will advise companies seeking to dispose of product as a waste to consult local authorities and comply
with local regulations (UNECE, 2017).
Section 14 summarizes transport information for ground, air, and sea (UNECE, 2017). Transport
classifications are aligned with GHS classifications because this was intentionally done in United Nations
committees that developed the hazard classifications for GHS. Shippers can reference the information in
Section 14 to identify packaging, volume limitations, and placarding requirements (Canadian Centre for
Occupational Health and Safety, 2017).
Section 15 addresses regulatory requirements that may apply to the chemicals (UNECE, 2017). For example,
if the chemical has a reportable quantity (RQ) where an immediate notification is to be made to responsible
authorities, the RQ value is given in this section. Finally, Section 16 is a catchall section where manufacturers
can put additional information that may be important to their customers or in the markets were the product is
sold (UNECE, 2017).
Besides the SDS, the container label is a snapshot of the SDS because it is meant to give a shipper,
warehouse worker, firefighter, or other person coming into contact with the chemical a visual of the hazards
by simply glancing at the label. The pictograms indicate the type of hazard that is associated with the product
giving a warning that the product may be an explosive, a health hazard, or that it is harmful to the
environment. The supplemental text on the label provides additional details but not at the level given in the
SDS. The elements on the label are chosen to present the most important hazard information and mitigation
recommendations to those who come into contact with multiple products and containers throughout the day.
The United Nations committee that developed the GHS would like to have every product tested for each of
the hazard categories. They recognized that there are not enough testing facilities and that the cost would
keep many products and innovations from reaching the market. The committee took the step to conservatively
classify products based on individual chemical ingredients. For example, if a chemical contains an impurity
that is a carcinogen, it must be considered in the product classification if it exists in the product at a level of
0.1% (UNECE, 2017). The entire product is subsequently classified as a carcinogen. Similarly, if a chemical
contains an acid at a level >3% in the product, the entire product will be classified as a corrosive to skin and
[https://echa.europa.eu/information-on-chemicals](https://echa.europa.eu/information-on-chemicals)
[https://echa.europa.eu/information-on-chemicals](https://echa.europa.eu/information-on-chemicals)
OSH 2302, Introduction to Regulatory Compliance 4
UNIT x STUDY GUIDE
Title
eyes (UNECE, 2017). If the manufacturer or importer makes the effort to test the product, the test results will
often indicate that the product is not a corrosive but an irritant. By being conservative in the assumptions used
to classify a product, the market decides when testing is necessary to adjust the product classification to meet
specifications of key customers. However, to remove a carcinogen classification, the testing is very expensive
and of long durations. In this situation, the carcinogen classification becomes a driver for companies to invest
in research and development to find a greener, less-toxic chemical that still fulfills the performance
requirements for the product.
Conclusion
In summary, having information about the chemical hazards of a product allows a hazard assessment to be
done to determine if the product will fit into the manufacturing facility with its current level of engineering
controls and personal protective equipment used by workers. If the hazards require additional levels of
protection, additional controls and ventilation can be incorporated into the manufacturing operations. To
minimize the need for these protections, it is still best to find ways to reformulate and redesign products to
minimize the use of toxic chemicals and to eliminate hazards from the facility.
References
Canadian Centre for Occupational Health and Safety. (2017). OSH answers fact sheets: Transportation of
dangerous goods (TDG) – classification. Government of Canada.
https://www.ccohs.ca/oshanswers/legisl/tdg/tdg_classification.html
Occupational Safety and Health Administration. (n.d.). The globally harmonized system for hazard
communication. United States Department of Labor. https://www.osha.gov/dsg/hazcom/global.html
United Nations. (2017). Globally Harmonized System of Classification and Labelling of Chemicals (GHS) (7th
Rev. ed.). United Nations Economic Commission for Europe.
https://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev07/English/ST_SG_AC10_30_R
ev7e.pdf
Suggested Unit Resources
In order to access the following resource, click the link below.
The GHS was discussed in detail in the unit lesson, and you read the overview as part of the required reading
for this unit. It is important to be familiar with this document, so take a few minutes to peruse it in its entirety.
United Nations. (2011). Globally harmonized system of classification and labelling of chemicals (GHS) (4th
Rev. ed.).
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=e000xna&AN=387589&site=ehost-live&scope=site
Learning Activities (Nongraded)
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
Scenario: You are cleaning out your shed and find an unopened bottle of a cleaning product. As you read the
list of ingredients on the label, you see that the product contains benzene. Using the internet, find a safety
data sheet (SDS) for benzene (CAS 71-43-2). Read through the hazards in Section 2, and list the hazards
associated with benzene. Based on your list, what hazard concerns you most? Will you choose to use the
product or dispose of it as a waste? Find a product in your storage area, and repeat this exercise for the
ingredients on the label. Note: to find the CAS number, use the internet to search for it. For example, you can
Google the CAS number for phenol.
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– Course Learning Outcomes for Unit VIII
– Required Unit Resources
– Unit Lesson
– Introduction
– Chemical Classifications
– Communication of Hazards
– Conclusion
– References
– Suggested Unit Resources
– Learning Activities (Nongraded)
**## UnitVIII.pdf**
OSH 2302, Introduction to Regulatory Compliance 1
Course Learning Outcomes for Unit VIII
Upon completion of this unit, students should be able to:
1. Summarize important environmental safety and health-related laws.
1.1 Apply information from the Global Harmonized System of Classification and Labelling of
Chemicals (GHS) to a given scenario.
2. Discuss the primary responsibilities of environmental health and safety regulatory services.
2.1 Analyze a safety data sheet (SDS).
2.2 Recommend the proper procedures for handling a hazardous substance.
2.3 Discuss the measures that should be taken when using a hazardous substance in a
manufacturing operation.
Required Unit Resources
Chapter 6: Hazard Communication and Right-to-Know Regulations
In order to access the following resource, click the link below.
The document below is the GHS that was referenced in the unit lesson. Please read Chapters 1.1 through 1.5
(the Introduction section). It will give you an overview of this important document and help you complete the
assignment for this unit.
United Nations. (2011). Globally harmonized system of classification and labelling of chemicals (GHS) (4th
Rev. ed.).
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=e000xna&AN=387589&site=ehost-live&scope=site
Unit Lesson
Introduction
Chemicals are regulated by the Environmental Protection Agency (EPA) because they have the potential to
adversely impact human health and the environment. The environmental regulations are designed to
minimize exposure. The purpose of this unit is to present the hazard classification scheme and to show the
criteria used to measure hazard categories. The hazards are classified, which allows those coming into
contact with the chemicals to understand their threat and to have the necessary information to determine if
the chemical can be used safely in the facility.
Chemical Classifications
As the markets for chemicals grew and as workers, consumers, and the environment began to experience
adverse effects from their use, countries around the world began to implement chemical programs to manage
toxic chemicals and their hazards. Each country set up its own system for classifications, labeling, and the
definitions they applied to toxic, hazardous, dangerous, safe, etc. What was classified as hazardous in one
country was toxic in another, and what was considered to be safe in one place was restricted and controlled
in another. When trade in chemicals and their products experienced an upsurge in world markets, it was
impossible for regulators, customs, and end users to understand and make sense of the hazards identified on
product labels. The United Nations recognized that international trade would become restricted unless a
common and consistent international safety standard was used across the globe to classify chemicals and to
UNIT VIII STUDY GUIDE
Chemical Classifications and
the Communications of Hazards
[https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site](https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site)
[https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site](https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site)
OSH 2302, Introduction to Regulatory Compliance 2
UNIT x STUDY GUIDE
Title
represent their hazards. This classification system became known as the Globally Harmonized System of
Classification and Labeling of Chemicals (GHS) and also included requirements for safety data sheets (SDSs)
and container labels (Occupational Safety and Health Administration [OSHA], n.d.).
The GHS classification system categorizes hazards into the following three categories:
1. physical/chemical hazards;
2. human and mammalian toxicity; and
3. environmental toxicity.
There are more than 28 categories of hazards that are aligned with nine hazard pictograms (United Nations
Economic Commission for Europe [UNECE], 2017). The GHS is reviewed by a United Nations committee
every 2 years at which time new hazard categories and criteria are implemented. While the GHS is intended
to be a unifying system that harmonizes the identification and communication of hazards, it has not
accomplished this in its roll out. The GHS is voluntary, and countries that want to participate in international
trade are choosing to adopt it into their national laws. Countries are not required to adopt all of the GHS
system as they can pick and choose what elements of GHS they want to incorporate into their national
regulations.
For example, Europe, China, and Japan have adopted all elements of the GHS, whereas the United States
and Canada have not adopted the environmental elements of the GHS. In Europe, it is easy to identify
products that are harmful to the environment. However, in the United States, environmental hazards are not
mentioned because only OSHA agreed to adopt the GHS, and the elements affecting worker safety became a
part of the U.S. standard. The EPA did not agree to adopt the environmental elements of GHS because this
would conflict with current programs that the EPA had in place. Canada followed the U.S. lead. Health
Canada adopted the same elements as the U.S. OSHA while Environment Canada followed the lead of the
U.S. EPA.
Examples of physical hazard include the categories of explosives, flammable solids and liquids, self-reacting,
and heating substances and mixtures. Examples of health hazards include acute toxicity; skin and eye
corrosion/irritation; skin and respiratory sensitizer; and carcinogen, mutagen, and reproductive toxicant.
Environmental hazards include the categories of acute and chronic aquatic toxicity and hazardous to the
ozone layer (UNECE, 2017). Each of these categories have defined criteria that are used to classify the
hazards of a chemical or mixture.
Communication of Hazards
The hazards of a product are communicated via the SDS and the container label. The SDS is a 16-section
document starting with the identity of the chemical and the manufacturer. Section 2 identifies the product
hazards. It lists the GHS categories and subcategories for each of the applicable 28 hazards. The applicable
pictogram is provided along with a signal word indicating danger or warning (UNECE, 2017). Hazard
statements are also provided that list the specific hazard indicated by the pictograms. It takes all three
elements (pictogram, signal word, and hazard statement) to understand the hazards of each product.
Following the designation of the hazards, precautionary statements follow that help to define the safe use of
the product and, if implemented, will help to mitigate the hazards of the product.
Section 3 of the SDS lists the individual chemical substances and complexes that contribute to the product
classification (UNECE, 2017). For products that are mixtures of chemicals, it is not uncommon to see multiple
chemicals listed in Section 3 along with their Chemical Abstract Service (CAS) number and their approximate
percentage in the product.
Other sections of the SDS cover first aid measures, firefighting measures, accidental release measures, and
handling and storage precautions. The storage section contains warnings that require the separation of acids
and bases as well as the separation of oxidizers and reducing agents. For very dangerous chemicals, a
recommendation is often made to quarantine these and lock them into a limited access area. Section 8 of the
SDS contains important information for the site industrial hygienist. Chemical substances in the mixture that
have an OSHA exposure standard are listed with the allowable exposure value. These standards can be time
OSH 2302, Introduction to Regulatory Compliance 3
UNIT x STUDY GUIDE
Title
weighted averages, short-term exposure levels, permissible exposure limits, and any state-specific standards
published for their list of chemicals of concern (UNECE, 2017).
The industrial hygiene lead can reference these exposure limits to set up monitoring for employees and the
facility to measure exposure levels against the standards. If any recommended level is exceeded,
administrative controls, engineering controls, and personal protective equipment can be put into place to
protect the employee. It is not uncommon to see enhanced ventilation and equipment in enclosures that put a
barrier between the chemical and the employee. Section 8 also lists supplier recommendations from the
manufacturer. These include recommendations for face shields, chemical-resistant gloves, long-sleeve
clothing, and chemical-resistant sleeves that keep clothing dry and clean (UNECE, 2017). No one wants to
expose their family to chemical hazards when they take contaminated clothing home to be washed.
Section 9 lists the physical/chemical properties of the substance (UNECE, 2017). Vapor density will indicate if
it is a chemical that will sink to the floor or rise into the air; imagine crawling along the floor to avoid smoke
from a fire only to be fully exposed to a toxic chemical that has a density heavier than air. Section 9 will
indicate if a chemical is water-soluble. In the event of a spill, hoses are often used to wash material into a
floor drain. A water-soluble chemical that dissolves in the wash water is carried down the floor drain to an
onsite treatment system ultimately making its way into a river where the chemical can have adverse effects on
aquatic life for years to come. Section 10 discusses the stability and reactivity of the chemical. It is in this
section that the rationale for putting chemicals into segregated storage are explained (UNECE, 2017).
Sections 11 and 12 of the SDS provide toxicity data for individual chemicals (UNECE, 2017). If the
manufacturer has tested the product and has toxicity data, this is where it is included. However, testing is
expensive, and for low-volume products, testing cannot be justified. There is website from the European
Chemicals Agency (ECHA) that contains a wealth of information on the chemicals from European
manufacturers and importers who have completed mandatory testing protocols to support a chemical
registration. Section 12 is a similar section that provides environmental data and effects (UNECE, 2017).
Section 13 covers disposal considerations, but because of a multitude of local laws and requirements, most
SDS will advise companies seeking to dispose of product as a waste to consult local authorities and comply
with local regulations (UNECE, 2017).
Section 14 summarizes transport information for ground, air, and sea (UNECE, 2017). Transport
classifications are aligned with GHS classifications because this was intentionally done in United Nations
committees that developed the hazard classifications for GHS. Shippers can reference the information in
Section 14 to identify packaging, volume limitations, and placarding requirements (Canadian Centre for
Occupational Health and Safety, 2017).
Section 15 addresses regulatory requirements that may apply to the chemicals (UNECE, 2017). For example,
if the chemical has a reportable quantity (RQ) where an immediate notification is to be made to responsible
authorities, the RQ value is given in this section. Finally, Section 16 is a catchall section where manufacturers
can put additional information that may be important to their customers or in the markets were the product is
sold (UNECE, 2017).
Besides the SDS, the container label is a snapshot of the SDS because it is meant to give a shipper,
warehouse worker, firefighter, or other person coming into contact with the chemical a visual of the hazards
by simply glancing at the label. The pictograms indicate the type of hazard that is associated with the product
giving a warning that the product may be an explosive, a health hazard, or that it is harmful to the
environment. The supplemental text on the label provides additional details but not at the level given in the
SDS. The elements on the label are chosen to present the most important hazard information and mitigation
recommendations to those who come into contact with multiple products and containers throughout the day.
The United Nations committee that developed the GHS would like to have every product tested for each of
the hazard categories. They recognized that there are not enough testing facilities and that the cost would
keep many products and innovations from reaching the market. The committee took the step to conservatively
classify products based on individual chemical ingredients. For example, if a chemical contains an impurity
that is a carcinogen, it must be considered in the product classification if it exists in the product at a level of
0.1% (UNECE, 2017). The entire product is subsequently classified as a carcinogen. Similarly, if a chemical
contains an acid at a level >3% in the product, the entire product will be classified as a corrosive to skin and
[https://echa.europa.eu/information-on-chemicals](https://echa.europa.eu/information-on-chemicals)
[https://echa.europa.eu/information-on-chemicals](https://echa.europa.eu/information-on-chemicals)
OSH 2302, Introduction to Regulatory Compliance 4
UNIT x STUDY GUIDE
Title
eyes (UNECE, 2017). If the manufacturer or importer makes the effort to test the product, the test results will
often indicate that the product is not a corrosive but an irritant. By being conservative in the assumptions used
to classify a product, the market decides when testing is necessary to adjust the product classification to meet
specifications of key customers. However, to remove a carcinogen classification, the testing is very expensive
and of long durations. In this situation, the carcinogen classification becomes a driver for companies to invest
in research and development to find a greener, less-toxic chemical that still fulfills the performance
requirements for the product.
Conclusion
In summary, having information about the chemical hazards of a product allows a hazard assessment to be
done to determine if the product will fit into the manufacturing facility with its current level of engineering
controls and personal protective equipment used by workers. If the hazards require additional levels of
protection, additional controls and ventilation can be incorporated into the manufacturing operations. To
minimize the need for these protections, it is still best to find ways to reformulate and redesign products to
minimize the use of toxic chemicals and to eliminate hazards from the facility.
References
Canadian Centre for Occupational Health and Safety. (2017). OSH answers fact sheets: Transportation of
dangerous goods (TDG) – classification. Government of Canada.
https://www.ccohs.ca/oshanswers/legisl/tdg/tdg_classification.html
Occupational Safety and Health Administration. (n.d.). The globally harmonized system for hazard
communication. United States Department of Labor. https://www.osha.gov/dsg/hazcom/global.html
United Nations. (2017). Globally Harmonized System of Classification and Labelling of Chemicals (GHS) (7th
Rev. ed.). United Nations Economic Commission for Europe.
https://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev07/English/ST_SG_AC10_30_R
ev7e.pdf
Suggested Unit Resources
In order to access the following resource, click the link below.
The GHS was discussed in detail in the unit lesson, and you read the overview as part of the required reading
for this unit. It is important to be familiar with this document, so take a few minutes to peruse it in its entirety.
United Nations. (2011). Globally harmonized system of classification and labelling of chemicals (GHS) (4th
Rev. ed.).
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=e000xna&AN=387589&site=ehost-live&scope=site
Learning Activities (Nongraded)
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
Scenario: You are cleaning out your shed and find an unopened bottle of a cleaning product. As you read the
list of ingredients on the label, you see that the product contains benzene. Using the internet, find a safety
data sheet (SDS) for benzene (CAS 71-43-2). Read through the hazards in Section 2, and list the hazards
associated with benzene. Based on your list, what hazard concerns you most? Will you choose to use the
product or dispose of it as a waste? Find a product in your storage area, and repeat this exercise for the
ingredients on the label. Note: to find the CAS number, use the internet to search for it. For example, you can
Google the CAS number for phenol.
[https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site](https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site)
[https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site](https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site)
– Course Learning Outcomes for Unit VIII
– Required Unit Resources
– Unit Lesson
– Introduction
– Chemical Classifications
– Communication of Hazards
– Conclusion
– References
– Suggested Unit Resources
– Learning Activities (Nongraded)
**## UnitVIIIJournal.docx**
Your company is looking to purchase a small chemical company in Southern California. The company produces commodity organic chemicals that are used as building blocks to synthesize complex molecules for use in the pharmaceutical industry. Identify the air quality management districts in Southern California and the requirements of state implementation plans (SIP) that you find that are in effect for the small company. Make a recommendation to management to go forward with the acquisition or to consider other options in their growth strategy.
Your journal entry must be at least 200 words in length. No references or citations are necessary.
**## UnitVIII.pdf**
OSH 2302, Introduction to Regulatory Compliance 1
Course Learning Outcomes for Unit VIII
Upon completion of this unit, students should be able to:
1. Summarize important environmental safety and health-related laws.
1.1 Apply information from the Global Harmonized System of Classification and Labelling of
Chemicals (GHS) to a given scenario.
2. Discuss the primary responsibilities of environmental health and safety regulatory services.
2.1 Analyze a safety data sheet (SDS).
2.2 Recommend the proper procedures for handling a hazardous substance.
2.3 Discuss the measures that should be taken when using a hazardous substance in a
manufacturing operation.
Required Unit Resources
Chapter 6: Hazard Communication and Right-to-Know Regulations
In order to access the following resource, click the link below.
The document below is the GHS that was referenced in the unit lesson. Please read Chapters 1.1 through 1.5
(the Introduction section). It will give you an overview of this important document and help you complete the
assignment for this unit.
United Nations. (2011). Globally harmonized system of classification and labelling of chemicals (GHS) (4th
Rev. ed.).
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=e000xna&AN=387589&site=ehost-live&scope=site
Unit Lesson
Introduction
Chemicals are regulated by the Environmental Protection Agency (EPA) because they have the potential to
adversely impact human health and the environment. The environmental regulations are designed to
minimize exposure. The purpose of this unit is to present the hazard classification scheme and to show the
criteria used to measure hazard categories. The hazards are classified, which allows those coming into
contact with the chemicals to understand their threat and to have the necessary information to determine if
the chemical can be used safely in the facility.
Chemical Classifications
As the markets for chemicals grew and as workers, consumers, and the environment began to experience
adverse effects from their use, countries around the world began to implement chemical programs to manage
toxic chemicals and their hazards. Each country set up its own system for classifications, labeling, and the
definitions they applied to toxic, hazardous, dangerous, safe, etc. What was classified as hazardous in one
country was toxic in another, and what was considered to be safe in one place was restricted and controlled
in another. When trade in chemicals and their products experienced an upsurge in world markets, it was
impossible for regulators, customs, and end users to understand and make sense of the hazards identified on
product labels. The United Nations recognized that international trade would become restricted unless a
common and consistent international safety standard was used across the globe to classify chemicals and to
UNIT VIII STUDY GUIDE
Chemical Classifications and
the Communications of Hazards
[https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site](https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site)
[https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site](https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site)
OSH 2302, Introduction to Regulatory Compliance 2
UNIT x STUDY GUIDE
Title
represent their hazards. This classification system became known as the Globally Harmonized System of
Classification and Labeling of Chemicals (GHS) and also included requirements for safety data sheets (SDSs)
and container labels (Occupational Safety and Health Administration [OSHA], n.d.).
The GHS classification system categorizes hazards into the following three categories:
1. physical/chemical hazards;
2. human and mammalian toxicity; and
3. environmental toxicity.
There are more than 28 categories of hazards that are aligned with nine hazard pictograms (United Nations
Economic Commission for Europe [UNECE], 2017). The GHS is reviewed by a United Nations committee
every 2 years at which time new hazard categories and criteria are implemented. While the GHS is intended
to be a unifying system that harmonizes the identification and communication of hazards, it has not
accomplished this in its roll out. The GHS is voluntary, and countries that want to participate in international
trade are choosing to adopt it into their national laws. Countries are not required to adopt all of the GHS
system as they can pick and choose what elements of GHS they want to incorporate into their national
regulations.
For example, Europe, China, and Japan have adopted all elements of the GHS, whereas the United States
and Canada have not adopted the environmental elements of the GHS. In Europe, it is easy to identify
products that are harmful to the environment. However, in the United States, environmental hazards are not
mentioned because only OSHA agreed to adopt the GHS, and the elements affecting worker safety became a
part of the U.S. standard. The EPA did not agree to adopt the environmental elements of GHS because this
would conflict with current programs that the EPA had in place. Canada followed the U.S. lead. Health
Canada adopted the same elements as the U.S. OSHA while Environment Canada followed the lead of the
U.S. EPA.
Examples of physical hazard include the categories of explosives, flammable solids and liquids, self-reacting,
and heating substances and mixtures. Examples of health hazards include acute toxicity; skin and eye
corrosion/irritation; skin and respiratory sensitizer; and carcinogen, mutagen, and reproductive toxicant.
Environmental hazards include the categories of acute and chronic aquatic toxicity and hazardous to the
ozone layer (UNECE, 2017). Each of these categories have defined criteria that are used to classify the
hazards of a chemical or mixture.
Communication of Hazards
The hazards of a product are communicated via the SDS and the container label. The SDS is a 16-section
document starting with the identity of the chemical and the manufacturer. Section 2 identifies the product
hazards. It lists the GHS categories and subcategories for each of the applicable 28 hazards. The applicable
pictogram is provided along with a signal word indicating danger or warning (UNECE, 2017). Hazard
statements are also provided that list the specific hazard indicated by the pictograms. It takes all three
elements (pictogram, signal word, and hazard statement) to understand the hazards of each product.
Following the designation of the hazards, precautionary statements follow that help to define the safe use of
the product and, if implemented, will help to mitigate the hazards of the product.
Section 3 of the SDS lists the individual chemical substances and complexes that contribute to the product
classification (UNECE, 2017). For products that are mixtures of chemicals, it is not uncommon to see multiple
chemicals listed in Section 3 along with their Chemical Abstract Service (CAS) number and their approximate
percentage in the product.
Other sections of the SDS cover first aid measures, firefighting measures, accidental release measures, and
handling and storage precautions. The storage section contains warnings that require the separation of acids
and bases as well as the separation of oxidizers and reducing agents. For very dangerous chemicals, a
recommendation is often made to quarantine these and lock them into a limited access area. Section 8 of the
SDS contains important information for the site industrial hygienist. Chemical substances in the mixture that
have an OSHA exposure standard are listed with the allowable exposure value. These standards can be time
OSH 2302, Introduction to Regulatory Compliance 3
UNIT x STUDY GUIDE
Title
weighted averages, short-term exposure levels, permissible exposure limits, and any state-specific standards
published for their list of chemicals of concern (UNECE, 2017).
The industrial hygiene lead can reference these exposure limits to set up monitoring for employees and the
facility to measure exposure levels against the standards. If any recommended level is exceeded,
administrative controls, engineering controls, and personal protective equipment can be put into place to
protect the employee. It is not uncommon to see enhanced ventilation and equipment in enclosures that put a
barrier between the chemical and the employee. Section 8 also lists supplier recommendations from the
manufacturer. These include recommendations for face shields, chemical-resistant gloves, long-sleeve
clothing, and chemical-resistant sleeves that keep clothing dry and clean (UNECE, 2017). No one wants to
expose their family to chemical hazards when they take contaminated clothing home to be washed.
Section 9 lists the physical/chemical properties of the substance (UNECE, 2017). Vapor density will indicate if
it is a chemical that will sink to the floor or rise into the air; imagine crawling along the floor to avoid smoke
from a fire only to be fully exposed to a toxic chemical that has a density heavier than air. Section 9 will
indicate if a chemical is water-soluble. In the event of a spill, hoses are often used to wash material into a
floor drain. A water-soluble chemical that dissolves in the wash water is carried down the floor drain to an
onsite treatment system ultimately making its way into a river where the chemical can have adverse effects on
aquatic life for years to come. Section 10 discusses the stability and reactivity of the chemical. It is in this
section that the rationale for putting chemicals into segregated storage are explained (UNECE, 2017).
Sections 11 and 12 of the SDS provide toxicity data for individual chemicals (UNECE, 2017). If the
manufacturer has tested the product and has toxicity data, this is where it is included. However, testing is
expensive, and for low-volume products, testing cannot be justified. There is website from the European
Chemicals Agency (ECHA) that contains a wealth of information on the chemicals from European
manufacturers and importers who have completed mandatory testing protocols to support a chemical
registration. Section 12 is a similar section that provides environmental data and effects (UNECE, 2017).
Section 13 covers disposal considerations, but because of a multitude of local laws and requirements, most
SDS will advise companies seeking to dispose of product as a waste to consult local authorities and comply
with local regulations (UNECE, 2017).
Section 14 summarizes transport information for ground, air, and sea (UNECE, 2017). Transport
classifications are aligned with GHS classifications because this was intentionally done in United Nations
committees that developed the hazard classifications for GHS. Shippers can reference the information in
Section 14 to identify packaging, volume limitations, and placarding requirements (Canadian Centre for
Occupational Health and Safety, 2017).
Section 15 addresses regulatory requirements that may apply to the chemicals (UNECE, 2017). For example,
if the chemical has a reportable quantity (RQ) where an immediate notification is to be made to responsible
authorities, the RQ value is given in this section. Finally, Section 16 is a catchall section where manufacturers
can put additional information that may be important to their customers or in the markets were the product is
sold (UNECE, 2017).
Besides the SDS, the container label is a snapshot of the SDS because it is meant to give a shipper,
warehouse worker, firefighter, or other person coming into contact with the chemical a visual of the hazards
by simply glancing at the label. The pictograms indicate the type of hazard that is associated with the product
giving a warning that the product may be an explosive, a health hazard, or that it is harmful to the
environment. The supplemental text on the label provides additional details but not at the level given in the
SDS. The elements on the label are chosen to present the most important hazard information and mitigation
recommendations to those who come into contact with multiple products and containers throughout the day.
The United Nations committee that developed the GHS would like to have every product tested for each of
the hazard categories. They recognized that there are not enough testing facilities and that the cost would
keep many products and innovations from reaching the market. The committee took the step to conservatively
classify products based on individual chemical ingredients. For example, if a chemical contains an impurity
that is a carcinogen, it must be considered in the product classification if it exists in the product at a level of
0.1% (UNECE, 2017). The entire product is subsequently classified as a carcinogen. Similarly, if a chemical
contains an acid at a level >3% in the product, the entire product will be classified as a corrosive to skin and
[https://echa.europa.eu/information-on-chemicals](https://echa.europa.eu/information-on-chemicals)
[https://echa.europa.eu/information-on-chemicals](https://echa.europa.eu/information-on-chemicals)
OSH 2302, Introduction to Regulatory Compliance 4
UNIT x STUDY GUIDE
Title
eyes (UNECE, 2017). If the manufacturer or importer makes the effort to test the product, the test results will
often indicate that the product is not a corrosive but an irritant. By being conservative in the assumptions used
to classify a product, the market decides when testing is necessary to adjust the product classification to meet
specifications of key customers. However, to remove a carcinogen classification, the testing is very expensive
and of long durations. In this situation, the carcinogen classification becomes a driver for companies to invest
in research and development to find a greener, less-toxic chemical that still fulfills the performance
requirements for the product.
Conclusion
In summary, having information about the chemical hazards of a product allows a hazard assessment to be
done to determine if the product will fit into the manufacturing facility with its current level of engineering
controls and personal protective equipment used by workers. If the hazards require additional levels of
protection, additional controls and ventilation can be incorporated into the manufacturing operations. To
minimize the need for these protections, it is still best to find ways to reformulate and redesign products to
minimize the use of toxic chemicals and to eliminate hazards from the facility.
References
Canadian Centre for Occupational Health and Safety. (2017). OSH answers fact sheets: Transportation of
dangerous goods (TDG) – classification. Government of Canada.
https://www.ccohs.ca/oshanswers/legisl/tdg/tdg_classification.html
Occupational Safety and Health Administration. (n.d.). The globally harmonized system for hazard
communication. United States Department of Labor. https://www.osha.gov/dsg/hazcom/global.html
United Nations. (2017). Globally Harmonized System of Classification and Labelling of Chemicals (GHS) (7th
Rev. ed.). United Nations Economic Commission for Europe.
https://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev07/English/ST_SG_AC10_30_R
ev7e.pdf
Suggested Unit Resources
In order to access the following resource, click the link below.
The GHS was discussed in detail in the unit lesson, and you read the overview as part of the required reading
for this unit. It is important to be familiar with this document, so take a few minutes to peruse it in its entirety.
United Nations. (2011). Globally harmonized system of classification and labelling of chemicals (GHS) (4th
Rev. ed.).
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=e000xna&AN=387589&site=ehost-live&scope=site
Learning Activities (Nongraded)
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
Scenario: You are cleaning out your shed and find an unopened bottle of a cleaning product. As you read the
list of ingredients on the label, you see that the product contains benzene. Using the internet, find a safety
data sheet (SDS) for benzene (CAS 71-43-2). Read through the hazards in Section 2, and list the hazards
associated with benzene. Based on your list, what hazard concerns you most? Will you choose to use the
product or dispose of it as a waste? Find a product in your storage area, and repeat this exercise for the
ingredients on the label. Note: to find the CAS number, use the internet to search for it. For example, you can
Google the CAS number for phenol.
[https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site](https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site)
[https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site](https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site)
– Course Learning Outcomes for Unit VIII
– Required Unit Resources
– Unit Lesson
– Introduction
– Chemical Classifications
– Communication of Hazards
– Conclusion
– References
– Suggested Unit Resources
– Learning Activities (Nongraded)
**## UnitVIIIJournal.docx**
Your company is looking to purchase a small chemical company in Southern California. The company produces commodity organic chemicals that are used as building blocks to synthesize complex molecules for use in the pharmaceutical industry. Identify the air quality management districts in Southern California and the requirements of state implementation plans (SIP) that you find that are in effect for the small company. Make a recommendation to management to go forward with the acquisition or to consider other options in their growth strategy.
Your journal entry must be at least 200 words in length. No references or citations are necessary.
**## UnitVIII.pdf**
OSH 2302, Introduction to Regulatory Compliance 1
Course Learning Outcomes for Unit VIII
Upon completion of this unit, students should be able to:
1. Summarize important environmental safety and health-related laws.
1.1 Apply information from the Global Harmonized System of Classification and Labelling of
Chemicals (GHS) to a given scenario.
2. Discuss the primary responsibilities of environmental health and safety regulatory services.
2.1 Analyze a safety data sheet (SDS).
2.2 Recommend the proper procedures for handling a hazardous substance.
2.3 Discuss the measures that should be taken when using a hazardous substance in a
manufacturing operation.
Required Unit Resources
Chapter 6: Hazard Communication and Right-to-Know Regulations
In order to access the following resource, click the link below.
The document below is the GHS that was referenced in the unit lesson. Please read Chapters 1.1 through 1.5
(the Introduction section). It will give you an overview of this important document and help you complete the
assignment for this unit.
United Nations. (2011). Globally harmonized system of classification and labelling of chemicals (GHS) (4th
Rev. ed.).
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=e000xna&AN=387589&site=ehost-live&scope=site
Unit Lesson
Introduction
Chemicals are regulated by the Environmental Protection Agency (EPA) because they have the potential to
adversely impact human health and the environment. The environmental regulations are designed to
minimize exposure. The purpose of this unit is to present the hazard classification scheme and to show the
criteria used to measure hazard categories. The hazards are classified, which allows those coming into
contact with the chemicals to understand their threat and to have the necessary information to determine if
the chemical can be used safely in the facility.
Chemical Classifications
As the markets for chemicals grew and as workers, consumers, and the environment began to experience
adverse effects from their use, countries around the world began to implement chemical programs to manage
toxic chemicals and their hazards. Each country set up its own system for classifications, labeling, and the
definitions they applied to toxic, hazardous, dangerous, safe, etc. What was classified as hazardous in one
country was toxic in another, and what was considered to be safe in one place was restricted and controlled
in another. When trade in chemicals and their products experienced an upsurge in world markets, it was
impossible for regulators, customs, and end users to understand and make sense of the hazards identified on
product labels. The United Nations recognized that international trade would become restricted unless a
common and consistent international safety standard was used across the globe to classify chemicals and to
UNIT VIII STUDY GUIDE
Chemical Classifications and
the Communications of Hazards
[https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site](https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site)
[https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site](https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=e000xna&AN=387589&site=ehost-live&scope=site)
OSH 2302, Introduction to Regulatory Compliance 2
UNIT x STUDY GUIDE
Title
represent their hazards. This classification system became known as the Globally Harmonized System of
Classification and Labeling of Chemicals (GHS) and also included requirements for safety data sheets (SDSs)
and container labels (Occupational Safety and Health Administration [OSHA], n.d.).
The GHS classification system categorizes hazards into the following three categories:
1. physical/chemical hazards;
2. human and mammalian toxicity; and
3. environmental toxicity.
There are more than 28 categories of hazards that are aligned with nine hazard pictograms (United Nations
Economic Commission for Europe [UNECE], 2017). The GHS is reviewed by a United Nations committee
every 2 years at which time new hazard categories and criteria are implemented. While the GHS is intended
to be a unifying system that harmonizes the identification and communication of hazards, it has not
accomplished this in its roll out. The GHS is voluntary, and countries that want to participate in international
trade are choosing to adopt it into their national laws. Countries are not required to adopt all of the GHS
system as they can pick and choose what elements of GHS they want to incorporate into their national
regulations.
For example, Europe, China, and Japan have adopted all elements of the GHS, whereas the United States
and Canada have not adopted the environmental elements of the GHS. In Europe, it is easy to identify
products that are harmful to the environment. However, in the United States, environmental hazards are not
mentioned because only OSHA agreed to adopt the GHS, and the elements affecting worker safety became a
part of the U.S. standard. The EPA did not agree to adopt the environmental elements of GHS because this
would conflict with current programs that the EPA had in place. Canada followed the U.S. lead. Health
Canada adopted the same elements as the U.S. OSHA while Environment Canada followed the lead of the
U.S. EPA.
Examples of physical hazard include the categories of explosives, flammable solids and liquids, self-reacting,
and heating substances and mixtures. Examples of health hazards include acute toxicity; skin and eye
corrosion/irritation; skin and respiratory sensitizer; and carcinogen, mutagen, and reproductive toxicant.
Environmental hazards include the categories of acute and chronic aquatic toxicity and hazardous to the
ozone layer (UNECE, 2017). Each of these categories have defined criteria that are used to classify the
hazards of a chemical or mixture.
Communication of Hazards
The hazards of a product are communicated via the SDS and the container label. The SDS is a 16-section
document starting with the identity of the chemical and the manufacturer. Section 2 identifies the product
hazards. It lists the GHS categories and subcategories for each of the applicable 28 hazards. The applicable
pictogram is provided along with a signal word indicating danger or warning (UNECE, 2017). Hazard
statements are also provided that list the specific hazard indicated by the pictograms. It takes all three
elements (pictogram, signal word, and hazard statement) to understand the hazards of each product.
Following the designation of the hazards, precautionary statements follow that help to define the safe use of
the product and, if implemented, will help to mitigate the hazards of the product.
Section 3 of the SDS lists the individual chemical substances and complexes that contribute to the product
classification (UNECE, 2017). For products that are mixtures of chemicals, it is not uncommon to see multiple
chemicals listed in Section 3 along with their Chemical Abstract Service (CAS) number and their approximate
percentage in the product.
Other sections of the SDS cover first aid measures, firefighting measures, accidental release measures, and
handling and storage precautions. The storage section contains warnings that require the separation of acids
and bases as well as the separation of oxidizers and reducing agents. For very dangerous chemicals, a
recommendation is often made to quarantine these and lock them into a limited access area. Section 8 of the
SDS contains important information for the site industrial hygienist. Chemical substances in the mixture that
have an OSHA exposure standard are listed with the allowable exposure value. These standards can be time
OSH 2302, Introduction to Regulatory Compliance 3
UNIT x STUDY GUIDE
Title
weighted averages, short-term exposure levels, permissible exposure limits, and any state-specific standards
published for their list of chemicals of concern (UNECE, 2017).
The industrial hygiene lead can reference these exposure limits to set up monitoring for employees and the
facility to measure exposure levels against the standards. If any recommended level is exceeded,
administrative controls, engineering controls, and personal protective equipment can be put into place to
protect the employee. It is not uncommon to see enhanced ventilation and equipment in enclosures that put a
barrier between the chemical and the employee. Section 8 also lists supplier recommendations from the
manufacturer. These include recommendations for face shields, chemical-resistant gloves, long-sleeve
clothing, and chemical-resistant sleeves that keep clothing dry and clean (UNECE, 2017). No one wants to
expose their family to chemical hazards when they take contaminated clothing home to be washed.
Section 9 lists the physical/chemical properties of the substance (UNECE, 2017). Vapor density will indicate if
it is a chemical that will sink to the floor or rise into the air; imagine crawling along the floor to avoid smoke
from a fire only to be fully exposed to a toxic chemical that has a density heavier than air. Section 9 will
indicate if a chemical is water-soluble. In the event of a spill, hoses are often used to wash material into a
floor drain. A water-soluble chemical that dissolves in the wash water is carried down the floor drain to an
onsite treatment system ultimately making its way into a river where the chemical can have adverse effects on
aquatic life for years to come. Section 10 discusses the stability and reactivity of the chemical. It is in this
section that the rationale for putting chemicals into segregated storage are explained (UNECE, 2017).
Sections 11 and 12 of the SDS provide toxicity data for individual chemicals (UNECE, 2017). If the
manufacturer has tested the product and has toxicity data, this is where it is included. However, testing is
expensive, and for low-volume products, testing cannot be justified. There is website from the European
Chemicals Agency (ECHA) that contains a wealth of information on the chemicals from European
manufacturers and importers who have completed mandatory testing protocols to support a chemical
registration. Section 12 is a similar section that provides environmental data and effects (UNECE, 2017).
Section 13 covers disposal considerations, but because of a multitude of local laws and requirements, most
SDS will advise companies seeking to dispose of product as a waste to consult local authorities and comply
with local regulations (UNECE, 2017).
Section 14 summarizes transport information for ground, air, and sea (UNECE, 2017). Transport
classifications are aligned with GHS classifications because this was intentionally done in United Nations
committees that developed the hazard classifications for GHS. Shippers can reference the information in
Section 14 to identify packaging, volume limitations, and placarding requirements (Canadian Centre for
Occupational Health and Safety, 2017).
Section 15 addresses regulatory requirements that may apply to the chemicals (UNECE, 2017). For example,
if the chemical has a reportable quantity (RQ) where an immediate notification is to be made to responsible
authorities, the RQ value is given in this section. Finally, Section 16 is a catchall section where manufacturers
can put additional information that may be important to their customers or in the markets were the product is
sold (UNECE, 2017).
Besides the SDS, the container label is a snapshot of the SDS because it is meant to give a shipper,
warehouse worker, firefighter, or other person coming into contact with the chemical a visual of the hazards
by simply glancing at the label. The pictograms indicate the type of hazard that is associated with the product
giving a warning that the product may be an explosive, a health hazard, or that it is harmful to the
environment. The supplemental text on the label provides additional details but not at the level given in the
SDS. The elements on the label are chosen to present the most important hazard information and mitigation
recommendations to those who come into contact with multiple products and containers throughout the day.
The United Nations committee that developed the GHS would like to have every product tested for each of
the hazard categories. They recognized that there are not enough testing facilities and that the cost would
keep many products and innovations from reaching the market. The committee took the step to conservatively
classify products based on individual chemical ingredients. For example, if a chemical contains an impurity
that is a carcinogen, it must be considered in the product classification if it exists in the product at a level of
0.1% (UNECE, 2017). The entire product is subsequently classified as a carcinogen. Similarly, if a chemical
contains an acid at a level >3% in the product, the entire product will be classified as a corrosive to skin and
[https://echa.europa.eu/information-on-chemicals](https://echa.europa.eu/information-on-chemicals)
[https://echa.europa.eu/information-on-chemicals](https://echa.europa.eu/information-on-chemicals)
OSH 2302, Introduction to Regulatory Compliance 4
UNIT x STUDY GUIDE
Title
eyes (UNECE, 2017). If the manufacturer or importer makes the effort to test the product, the test results will
often indicate that the product is not a corrosive but an irritant. By being conservative in the assumptions used
to classify a product, the market decides when testing is necessary to adjust the product classification to meet
specifications of key customers. However, to remove a carcinogen classification, the testing is very expensive
and of long durations. In this situation, the carcinogen classification becomes a driver for companies to invest
in research and development to find a greener, less-toxic chemical that still fulfills the performance
requirements for the product.
Conclusion
In summary, having information about the chemical hazards of a product allows a hazard assessment to be
done to determine if the product will fit into the manufacturing facility with its current level of engineering
controls and personal protective equipment used by workers. If the hazards require additional levels of
protection, additional controls and ventilation can be incorporated into the manufacturing operations. To
minimize the need for these protections, it is still best to find ways to reformulate and redesign products to
minimize the use of toxic chemicals and to eliminate hazards from the facility.
References
Canadian Centre for Occupational Health and Safety. (2017). OSH answers fact sheets: Transportation of
dangerous goods (TDG) – classification. Government of Canada.
https://www.ccohs.ca/oshanswers/legisl/tdg/tdg_classification.html
Occupational Safety and Health Administration. (n.d.). The globally harmonized system for hazard
communication. United States Department of Labor. https://www.osha.gov/dsg/hazcom/global.html
United Nations. (2017). Globally Harmonized System of Classification and Labelling of Chemicals (GHS) (7th
Rev. ed.). United Nations Economic Commission for Europe.
https://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev07/English/ST_SG_AC10_30_R
ev7e.pdf
Suggested Unit Resources
In order to access the following resource, click the link below.
The GHS was discussed in detail in the unit lesson, and you read the overview as part of the required reading
for this unit. It is important to be familiar with this document, so take a few minutes to peruse it in its entirety.
United Nations. (2011). Globally harmonized system of classification and labelling of chemicals (GHS) (4th
Rev. ed.).
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=e000xna&AN=387589&site=ehost-live&scope=site
Learning Activities (Nongraded)
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
Scenario: You are cleaning out your shed and find an unopened bottle of a cleaning product. As you read the
list of ingredients on the label, you see that the product contains benzene. Using the internet, find a safety
data sheet (SDS) for benzene (CAS 71-43-2). Read through the hazards in Section 2, and list the hazards
associated with benzene. Based on your list, what hazard concerns you most? Will you choose to use the
product or dispose of it as a waste? Find a product in your storage area, and repeat this exercise for the
ingredients on the label. Note: to find the CAS number, use the internet to search for it. For example, you can
Google the CAS number for phenol.
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– Course Learning Outcomes for Unit VIII
– Required Unit Resources
– Unit Lesson
– Introduction
– Chemical Classifications
– Communication of Hazards
– Conclusion
– References
– Suggested Unit Resources
– Learning Activities (Nongraded)