14 years, 7 revisions later – Catching up with UN GHS Revision 7

What’s New in GHS Rev 7?

Key Changes in GHS Rev 7Whenever a new revision to the UN GHS purple book comes out I always take some time to understand how this revision compares to previous revisions. It’s also good for any business impacted by GHS to understand the changes as well. This is because the UN GHS purple book is the true north from which the competent authorities that have adopted GHS will most likely base the changes to classification criteria and GHS label elements. By reviewing the revisions to GHS a company can have an idea of how the regulations they are trying to comply with could potentially change in the coming years. This allows companies to get ahead of the regulatory curve and anticipate how their products could be impacted. With that said, keep in mind that various regulatory bodies update their regulations using different methods which take different amounts of time to get to a finalized and enforceable regulation. For example – the EU has updated their regulations adopting GHS, called the EU CLP (Classification Labeling and Packaging) to keep pace with the revisions of GHS that have been published. Whereas in contrast the US and OSHA have not moved beyond their initial GHS adoption which was based on UN GHS Rev. 3. We all want to get ahead of the regulatory curve so without further delay, here are the changes in GHS Rev 7:

Revised criteria for categorization of flammable gases within Category 1

This is the most significant and in my opinion a much needed revision to the criteria. There was much room for interpretation for how the categories provided in the flammable gas chapter were applied prior to this revision. This was because there were three classification criteria charts in the flammable gas chapter so it was unclear on how the categories should be applied – is only one category from the flammable gas chapter applied to a material at a time or can multiple categories be applied? Do you represent the classifications separately as Flammable Gases Category 1 and Chemically Unstable Gases Category A or together as Flammable/Chemically Unstable Gases Category 1A?

Here are the Rev. 6 and Rev. 7 flammable gas classification criteria in a side by side comparison. Although the criteria is undoubtedly clearer in the new revision it appears to me that there is still could be some interpretation needed in terms of practical application for how to represent the sub-categories listed under 1A on an SDS.

Flammable Gas Classifcation Criteria

Clarifications to definitions for some health hazard classes

  • Acute toxicity – minor changes to the ATE dosage chart; 3.1.2.3 – now mentions the use of data from human experience and that it should be considered in a weight of evidence approach. Although this is interesting, it is of no impact to companies doing business in regions with regulations that have adopted GHS.
  • Skin corrosion/Irritation – minor changes to some of the descriptions at the beginning of the chapter, but nothing that impacts how substances and mixtures would be classified.
  • Serious Eye Damage/Eye Irritation – minor change to definition of eye irritation in the beginning of the chapter, but again no impact on how a substance or mixture would be classified.

Additional guidance to extend the coverage of section 14 of the Safety Data Sheets to all bulk cargoes transported under instruments of the International Maritime Organisation (IMO), regardless of their physical state

Now includes guidance on specific information for each physical form (liquid, solid, liquefied gas) that would be expected for materials transported in bulk. Guidance also includes which IMO instrument to reference to find this information.

Revised and further rationalized precautionary statements in Annex 3.

Changes to the precautionary statements themselves include the following:

Changes to the text of P103 – UN GHS Rev. 6 lists Read label before use but UN GHS Rev 7 lists Read carefully and follow all instructions.

New P503 added – Refer to manufacturer/supplier… for information on disposal/recovery/recycling.

Annex 3, Section 3 – new A 3.3.1.2, A 3.3.1.6-8

A3.3.2 is now Flexibility in the use of precautionary statements with the first heading under that being Omission of precautionary statements where the advices is not relevant – the phrase “store locked up” comes to mind here for me as many hazard communication professionals are of the opinion that this just simply does not make sense.

Beyond that there were a lot of points added under the new 3.3.2 that as a hazard communication professional I think are worth a review.

New example in Annex 7 on using a fold-out label for small packages. Here is a summary of that information –

This is example 9. It specifies that the front page of the fold-out label should contain at least the following GHS information:

  • Product identifier
  • Hazard pictograms
  • Signal Word
  • Supplier identification (name, address and telephone number)

It would also be expected that the front page would have a symbol to let the user know that the label can be opened out to get more information on the inside pages. On the inside pages the following information would be included:

  • Product identifier (components as applicable)
  • Signal word
  • Hazard Statements
  • Precautionary statements
  • Any additional information

On the back page (the part of the label that is attached to the container) the following information would be expected –

  • Product identifier
  • Hazard pictograms
  • Signal Word
  • Supplier identification (name, address and telephone number)

That concludes the changes to UN GHS included in the latest revision.  All in all for businesses that are not selling flammable gases this revision is of little impact in terms of changes to the classifications, and label elements that would apply to products being sold.  As with any change to UN GHS the world will wait to see how these will be applied by the various competent authorities, but at least businesses can somewhat prepare for what the changes could look like.

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