Sunday, May 27, 2012

GHS...We Have A Problem Here - Part 2

Let's look at the DOT label for a chemical product which contains "methyl ethyl ketone peroxide" and "cumene hydroperoxide."  According to the supplier, this material is regulated by DOT/IATA as follows:

This material would be shipped with this DOT/IATA label:

Under the GHS classification system, an "organic peroxide" is defined as:

"Exothermic self-accelerating decomposition" & "explosive" & "sensitive to impact/friction" makes this stuff a concern wouldn't you say?  So it is easy to teach anyone who may come in contact with this material to be careful if they see the DOT label with the red top, yellow bottom and the number "5.2"


Now let's look at how the new GHS labeling system conveys the hazard of a container of organic peroxide Type D shipped in a box:


Which, for our material, the manufacturer identifies all the required information as follows:

If an organic peroxide is a chemical substance that may undergo "exothermic self-accelerating decomposition" shouldn't that little bit of important information be the first thing the person picking up the product understands about the stuff in the container?

The GHS pictogram for an organic peroxide is:

That's the same pictogram used by DOT to describe a flammable liquid, flammable solid, dangerous when wet, spontaneous combustible, and an organic peroxide.


Only DOT uses color and a number to differentiate between the different hazards.

I wish I would have recognized this earlier.  Here is what I recommend as a fix:

Scrap the GHS pictograms and use a DOT label - including color - in its place for those hazards where a DOT Class 1 through Class 8 label is currently in place.


Because DOTs system of warning = color, symbol, and number - is easy to understand and it works.

Don't believe me?  Try this experiment.  Show the following labeled and ask the person to tell you what the hazard is of the material inside.

I'll bet at least 8 out of 10 get it right.

DOT labels work because they communicate the hazard and can be easily taught and understood.


GHS...We Have A Problem Here - Part 1

(Work has kept me on the road and an in a hotel, so my blog time has been interrupted.)

I'll get back to the RCRA "In The Beginning" posts in a bit.  They involve reading the Federal Register and that ain't a lot of fun to do on a holiday weekend.

I'm in the process of teaching a bunch of military guys.  Each year I try to change it up a bit and work on a different "theme."  This year we are looking at the DoD's new "Chemical Comparability System" which is a method of determining which chemical products can be stored together.  As part of this training I developed an exercise whereby they break into groups and using MSDS and labels, place the chemical container into the correct Hazard Characteristic Code "HCC" group.

One of the chemicals I chose uses the new Globally Harmonized System's (GHS) "Safety Data Sheet" or "SDS" which is going to replace the OHSA "MSDS."  Gotta love acronyms to be in this business!

This particular SDS also gave the new GHS label that was to appear on the container.  "Cool," I thought.  "I'll put that label on my mock chemical container and see if they can determine the HCC."  Only to make it challenging, I did not give them the SDS.

Now the way the DOD's HCC is designed is to have one of 63 HCCs assigned to every chemical product used by the military so they can be placed into one of 10 primary Hazardous Storage Areas and then segregated further - if required.

The goal is to have this code placed on the MSDS/SDS in the "Physical/Chemical Properties" section.

HCC is identified by supplier as "D3"
Well since it is not an OSHA or GHS requirement, it is going to take a bit of time for each manufactures or supplier to get this info their MSDS/SDS currently used by the troops and support personnel.

If the MSDS/SDS does not identify the HCC, the person can then look at the DOT transportation label and assign it a "suggested temporary HCC:"

It's not a bad system, but it relies on the HCC being correctly assigned by the supplier (something the exercise superstitiously discovered) or the container has the DOT shipping label.  But small containers are often shipped in a larger shipping container and do not have the DOT label when removed and placed into facility storage.

In this case, the container must be labeled to meet OSHA standards (U.S.) - which does not require a pictograph - and soon the new GHS label standards - which does.


And this is where the breakdown of communication starts.  Can a regular Joe/Jane determine what the hazard of a chemical is from the new GHS label?  According to my exercise, 3 out of the 4 teams can, but it is not because of the label.

Next post: GHS...We Have A Problem Here - Part 2