The document compares WHMIS and OSHA labeling requirements to the Global Harmonized System (GHS) requirements and provides guidance on transitioning labels to the GHS. It reviews key label elements under each system such as signal words, pictograms, hazard and precautionary statements. It recommends starting to use GHS statements now where appropriate and adding any OSHA-specific information required to begin preparing labels for the GHS implementation.
2. Canadian Centre for Occupational Health and Safety www.ccohs.ca
Today’s Presentation
Review current WHMIS and OSHA supplier label
requirements
Compare WHMIS and OSHA label requirements to the
GHS label requirements
Provide some insight into how you can write WHMIS-
and OSHA-compliant labels today with an eye to
GHS implementation
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WHMIS Supplier Label
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New GHS Label Elements
Chemical identity (listing of
hazardous ingredients)
Signal word (Danger or Warning)
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WHMIS Hazard Symbols vs. GHS Pictograms
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“A statementstatement identifying a
hazardhazard that may arise
from the nature of the
controlled product or the
class, division or
subdivision of controlled
products.”
“A phrase assignedassigned to a
hazard class and category
that describes the nature
of the hazards of hazardous
product, including, where
appropriate, the degree of
hazard.”
WHMIS Risk Phrases GHS Hazard Statements
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“A statement identifying a
hazardhazard that may arise
from the nature of the
controlled product or the
class, division or
subdivision of controlled
products.”
“A phrase assignedassigned to a
hazard class and category
that describes the nature
of the hazards of hazardous
product, including, where
appropriate, the degree of
hazard.”
WHMIS Risk Phrases GHS Hazard Statements
It may be possible to use a GHS Hazard
Statement as your WHMIS Risk Phrase if it
accurately describes the product’s hazards.
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A product with a flash point (closed cup) of 65ºC is a WHMIS
“combustible liquid” AND a GHS “combustible liquid” (Cat. 4).
A product with a flash point (closed cup) of 50ºC is a WHMIS
“combustible liquid” AND a GHS “Flammable liquid and vapour” (Cat. 3).
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Using the GHS Hazard Statement “Fatal if swallowed” for a
product classified as WHMIS D1A (oral) will take you one
step closer to being GHS ready.
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WHMIS Precautionary
Measures
“Precautionary measures to
be followed when handling,
using or being exposed to the
controlled product.”
GHS Precautionary
Statements
“Recommended measures
that should be taken to
minimise or prevent
adverse effects resulting
from exposure to a
hazardous product, or
improper storage or
handling of a hazardous
product.”
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WHMIS Precautionary
Measures
WHMIS First Aid Measures
“Where appropriate, first aid
measures to be taken in case
of exposure to a controlled
product.”
GHS Precautionary
Statements
“Recommended measures
that should be taken to
minimise or prevent
adverse effects resulting
from exposure to a
hazardous product, or
improper storage or
handling of a hazardous
product.”
Statement Types:
1. General
2. Prevention
3. Response (fire, first aid,
accidental release)
4. Storage
5. Disposal
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GHS Precautionary Statements
Serious Eye Damage/Eye Irritation – Category 2(A)
Hazard Statement: Causes serious eye irritation.
Prevention: Wash…thoroughly after handling.
Wear eye protection/face protection.
Response: IF IN EYES: Rinse cautiously with water
for several minutes. Remove contact lenses, if
present and easy to do. Continue rinsing. If eye
irritation persists: Get medical advice/attention.
Storage: None recommended.
Disposal: None recommended.
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GHS Precautionary Statements
Gas Under Pressure – Compressed Gas
Prevention: None recommended
Response: None recommended
Storage: Protect from sunlight.
Store in a well-ventilated place.
Disposal: None recommended
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WHMIS Label Elements Not Required
by the GHS
Hatched border
Reference to MSDS
These elements must be
present on a WHMIS-
compliant label today.
It is not known if they will be
retained following
implementation of the GHS in
WHMIS.
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WHMIS Workplace Label
Product Identifier
Information for the safe handling of the product
A statement that the MSDS is available
There are no GHS specifications for a workplace
label.
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OSHA-Compliant Label
Identity of hazardous chemical
Name and address of responsible party
Appropriate hazard warnings
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ANSI Standard (Z129.1)
Identification of the chemical
product
Identification of its hazardous
component(s)
Name, address, telephone
number of the
manufacturer, importer or
other responsible party
Signal word (Danger,
Warning, Caution)
Statement(s) of hazard(s)
Precautionary measures
Instructions in case of
contact or exposure (first
aid)
Antidotes, and notes to
physician
Instructions in case of fire
Instructions in case of spill
or leak
Instructions for container
handling and storage
Reference(s) to additional
labeling/other documents
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OSHA permits the use of graphics:
pictures, symbols, or combination
thereof appearing on a label or other
appropriate form of warning which
convey the specific physical or health
hazard(s), including target organ
effects, of the chemical(s) in the
container(s).
Source: Fact Sheet #4 Labeling – OSHA vs.
GHS (Jan. 2010). Produced by SCHC-OSHA
Alliance GHS Information Sheet Workgroup.
Available at www.schc.org.
Pictograms
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OSHA Position
“… as long as the EU GHS label contains the
information required by the HCS, OSHA will
consider the EU GHS label sufficient.”
Source:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATI
ONS&p_id=27218
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Start using GHS Hazard and Precautionary
Statements now, as appropriate, adding any
OSHA-specific information required.
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Preparing for Change
• Compare the WHMIS and/or OSHA hazards of
your products to the GHS hazards.
• Start transitioning your label content as you
update or write new labels, as appropriate.