Benjamin Franklin once said, “In this world nothing can be said to be certain, except death and taxes.” I think that I would amend that to include regulatory changes. Ours is a world of change and while the rate of changes sometimes slows, it never really stops. I was reminded of this the other day when I was reviewing my list of country implementations and expected updates. Countries are remembering that while the UN continues to march ahead, they are being left behind.
In particular, the EU is looking at revising both the CLP and REACH Annex II, bringing in the updates made to revisions 6 and 7. OSHA has also announced that they are looking at updating Hazcom to meet the requirements of the latest edition (RIN: 1218-AC93). In keeping with North America, the Canadians announced plans to update to UN GHS revision 7. Travelling across the ocean we find ourselves in Japan and an update to the JIS standards to align it with UN GHS revision 6. To top it all off, we are expecting the UN to update the purple book this summer. We could go on, but the evidence is in….2019 is a year of change, or at least announced changes!
To prepare for all this, I’ve been dusting off my notes and previous versions of the purple book to remind myself of where we are and what we need to do. Remember that some of these countries are still on revision 3, there are quite a few changes to remember between that and revision 7.
Let’s run through the revisions and see where you can expect to see changes in the country regulations.
UN GHS Revision 4:
- Under labeling elements, the hazard pictogram for “corrosive to metals” can be removed from the label if:
- The product is packaged for consumer use, and it is not classified as corrosive to skin and/or eyes.
- New categories were added to the Flammable gasses class that defines Chemically unstable gases – Categories A and B.
- Aerosols – Category 3 has been added to account for non-flammable aerosols.
- Note that this change clarified that aerosols should not also be classified as Gases under pressure
- Additional information was given regarding classification of flammable aerosols when the material contains flammable substances but has not used the flammability classification procedures given in the purple book.
- The tables for Mutagens, Carcinogens, and Reproductive Toxicants was updated to give greater clarity on the cut-off levels for the sub-categories.
UN GHS Revision 5:
- This revision continued to clarify the aerosols chapter adding information to the classification criteria when there is more than 1% of flammable components or if their heat of combustion is at least 20kJ/g.
- Pictograms were given codes for reference purposes, but these are not expected to be included on labels or Section 2 of the SDS.
- The flowchart for explosives started to refer to Articles or Substance/Mixtures as opposed to only articles and substances.
- Oxidizing solids added the test method O.3 in Part III, sub-section 34.4.3 of the UN Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria to determine hazard classification.
- The skin corrosion/irritation chapter was re-written and gives better clarity around the use of different types of data for classification.
- Changes in terminology for hazardous to the aquatic environment, moving from short-term to acute and long-term to chronic.
- Annex 1 and Annex 2 have been combined into Annex 1. Annex 2 is now blank.
- In Annex 4 on the Guidance on the preparation of Safety Data Sheets, combustible dust information was added to Section 2 under the “Other hazards which do not result in classification sub-section and Section 5 under “Suitable extinguishing criteria”. In addition, text was added to Section 7 to address hazards that may be created while processing materials.
UN GHS Revision 6
- A new Pyrophoric category was created under Flammable Gases.
- A new hazard class, Desensitized explosive has been created.
- There are 4 hazard categories associated with this hazard class.
- For STOT Single Exposure – Category 3 a relevant ingredient threshold of >1% has been added when classifying based on component information.
- The Aspiration chapter has been re-written to clarify that when classifying for mixtures, it is looking at the sum of the components in the mixture above 1%.
- A clarification was made to the text for Hazardous to the aquatic environment indicating that when classifying based on mixture data, components classified as Category 1 should be multiplied by their corresponding M factor.
- Examples of labeling for small packages were given.
- Section 9 was re-written giving more details on the information that should be shown on the SDS as well as what was mandatory vs. recommended.
UN GHS Revision 7
- Flammable gas – Category 1 has been divided into subcategories 1A and 1B.
- Pyrophoric gas and Chemically unstable gases have been assigned to Category 1A.
- Section 14 was updated to include additional information for transport in bulk for solid and gas cargoes.
All these updates contain changes to the H & P Phrases. Remember that while you need to know the changes within the purple book, you should also check the country implementations once they are published. We know that some regulations, such as OSHA Hazcom, have made changes to some of the phrases and it is important to recognize these differences on your SDS.
While waiting for the various countries to update their legislation, look at the changes and your product lines. It will be helpful to understand how these changes might impact you ahead of the country publications so that you can manage the changes that are coming. While 2019 is a year of change, we can be prepared for it and still hope that maybe there will be a bit more harmonization in our future!