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September 2013: NFPA 704 and the New OSHA Hazardous Material Labeling

You might have noticed that the Occupational Safety and Health Administration (OSHA) has been making a shift in labeling requirements for chemicals. The new system is the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). In 2011, OSHA implemented a three-year plan to incorporate the GHS system. Risk Logic does not often refer to OSHA, as our focus is on property protection; however, this change can lead to some confusion from a property protection perspective.

As chemical companies expanded into additional markets, they had a constantly increasing number of standards to follow that all seemed to have different requirements. This made proper labeling of these chemicals very difficult, as different labels were needed based upon the product's destination. In 1992, the United Nations Conference on Environment and Development (UNCED) passed a mandate to have a "globally harmonized hazard classification and compatible labeling system, including material safety data sheets and easily understandable symbols."

The goal was to have to have this system available by the year 2000. The International Labor Organization (ILO) determined that there were four major existing systems that needed to be harmonized for this global approach. Elements of other existing programs were taken into account as proposals were developed. The existing labeling and Material Safety Data Sheet (MSDS) requirements were evaluated to incorporate the necessary information for each agency and country. A best approach was determined, and the GHS was brought back to UNCED and endorsed in 2003.

The GHS is a voluntary system, but it is expected that it shall be applied to existing hazard communication regulatory schemes or used as a basis for countries that do not have an existing system. This system does still allow for different countries to consider different items hazardous and at different levels. In other words, if a certain element of a chemical is considered a hazard in one country, it would be listed on the label and in the MSDS for that country. However, if it is not considered a hazard in another country then it would not need to be listed on the label and in the MSDS for that country.

The benefits of all countries and agencies adopting this system are plentiful. Those that are helpful from a property protection standpoint are that hazard labels would look very similar (same symbols, same numbering systems, some instruction on how to respond to various emergencies with the chemical, etc.) no matter where you are, and MSDS would also be similar.

The GHS system identifies physical, environmental, and health hazards. The physical hazards include, but are not limited to: explosives, flammable liquids, flammable gases, flammable solids and oxidizers.

The GHS label is shaped in a rectangle that includes: the product name; identifying hazardous ingredients; using symbols (hazard pictograms) to convey health, physical and environmental hazard information that is assigned to a GHS hazard class and category; signaling words such as "danger" and "warning" to indicate the level of severity of the hazard; hazard statements that are assigned to a hazard class and category that describe the nature of the hazard; providing any supplemental information; and providing the name, address and phone number of the supplier. The GHS hazard category numbers have the highest numbers showing the lowest hazards, while the lowest numbers represent the highest hazards. A label format is not specific, so some label variation is likely.

The pictograms used in GHS labels are in Figures 1, 2, and 3 below.

Figure 1

GHS Pictograms and Hazard Classes

Description: Pictogram

Description: Pictogram

Description: Pictogram

§  Oxidizers

§ Flammables

§ Self Reactives

§ Pyrophorics

§ Self-Heating

§ Emits Flammable Gas

§ Organic Peroxides

§  Explosives

§  Self Reactives

§  Organic Peroxides

Description: Pictogram

Description: Pictogram

Description: Pictogram

§  Acute toxicity (severe)

§  Corrosives

§  Gases Under Pressure

Description: Pictogram

Description: Pictogram

Description: Pictogram

§  Carcinogen

§  Respiratory Sensitizer

§  Reproductive Toxicity

§  Target Organ Toxicity

§  Mutagenicity

§  Aspiration Toxicity

§  Environmental Toxicity

§  Irritant

§  Dermal Sensitizer

§  Acute toxicity (harmful)

§  Narcotic Effects

§  Respiratory Tract

§  Irritation


Figure 2

Transport "Pictograms"

Description: Pictogram

Description: Pictogram

Description: Pictogram

Flammable Liquid Flammable Gas Flammable Aerosol

Flammable solid Self-Reactive Substances

Pyrophorics (Spontaneously Combustible) Self-Heating Substances

Description: Pictogram

Description: Pictogram

Description: Pictogram

Substances, which in contact with water, emit flammable gases (Dangerous When Wet)

Oxidizing Gases Oxidizing Liquids Oxidizing Solids

Explosive Divisions 1.1, 1.2, 1.3

Description: Pictogram

Description: Pictogram

Description: Pictogram

Explosive Division 1.4

Explosive Division 1.5

Explosive Division 1.6

Description: Pictogram

Description: Pictogram

Description: Pictogram

Compressed Gases

Acute Toxicity (Poison): Oral, Dermal, Inhalation

Corrosive

Description: Pictogram

Description: Pictogram

Marine Pollutant

Organic Peroxides


Figure 3

ACUTE ORAL TOXICITY

 

Category 1

Category 2

Category 3

Category 4

Category 5

LD50

≤ 5 mg/kg

> 5 < 50 mg/kg

50 < 300 mg/kg

300 < 2000 mg/kg

2000 < 5000 mg/kg

Pictogram

Description: Pictogram

Description: Pictogram

Description: Pictogram

Description: Pictogram

No symbol

Signal word

Danger

Danger

Danger

Warning

Warning

Hazard statement

Fatal if swallowed

Fatal if swallowed

Toxic if swallowed

Harmful if swallowed

May be harmful if swallowed

The GHS system does include the information required in NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response. However, this information is presented in a different way.

The label that NFPA 704 uses is a diamond shape that is divided into four smaller diamonds. The top diamond is for the flammability hazard rating and it is shown in red. The left diamond is for the health hazard rating and it is shown in blue. The right diamond is the instability hazard rating that is shown in yellow and the bottom diamond is for any special hazards. The numbers in these diamonds have the lowest number showing the lowest hazards while the higher numbers identify higher hazards.

A significant challenge will be that the hazard number ratings are different for these two systems. The larger number means a higher hazard in NFPA 704 while the smaller number means a higher hazard in the GHS hazard category. The amount of divisions can vary, too. For example, NFPA 704 uses a scale from zero (least flammable) to four (most flammable) to measure the degree of flammability hazards. However GHS uses a scale of one (most flammable) to four (least flammable).

At this point, OSHA will require the GHS numbers to be in the MSDS, but not on labels. Additionally, there are no current plans to change the numbering system for NFPA 704 since emergency responders, employees, and the public in the United States have been using this system for over 50 years. As such, any changes would have to be carefully considered. However, NFPA and OSHA have developed a "Quick Card" to use to help minimize confusion. This Quick Card is available through NFPA at the following link: http://nfpatoday.blog.nfpa.org/2013/07/new-free-reference-card-compares-nfpa-704-diamond-and-osha-ghs-labels-.html

This Quick Card is also included in Figure 4 below for convenience.

If you have any questions, please feel free to contact Risk Logic for assistance with the new OSHA hazardous material labeling.