GHS
GHS Revision 6 is Coming!

Ch-Ch-Ch-Ch-Changes

David Bowie’s 1971 album “Hunky Dory” included the song “Changes” which was released in January 1972. While being recognized as one of Bowie’s most well-known songs, it never made it in into the “Top 40”. One of the lyrics from that song is

“Ch-ch-ch-ch-Changes / (Turn and face the strain) Ch-ch-Changes”.

Those lyrics are most appropriate given the release of the UN ECE Secretariat’s publication of the changes to the 5th Revised edition, which will lead to the creation of Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Sixth Revised Edition.

Here is the link to published changes document.

Six of the changes coming to Revision 6 are as follows:

  1. Desensitized Explosives. A new hazard class for Revision 6 which carries the definition of “solid or liquid explosive substances or mixtures which are phlegmatized to suppress their explosive properties in such a manner that they do not mass explode and do not burn too rapidly and therefore may be exempted from the hazard class “Explosives” (see Chapter 2.1; see also Note 2 to paragraph 2.1.2.2).”  This new class will have four categories and include its own label elements, H phrases and P phrases.
  2. Pyrophoric Gases. Chapter 2.2 entitled “Flammable Gases (Including Chemically Unstable Gases) is changing to “Flammable Gases”. While the title change is not necessarily newsworthy, the inclusion of the hazard class pyrophoric gases” is. This hazard class now comes with a standardized criteria, label elements and H/P phrases. NOTE: This is not a new hazard class for OSHA HazCom 2012.
  3. Section 9 Restructure. In Chapter 1.5 for Table 1.5.2, there is a new order format for Section 9’s Physical and Chemical Properties.The re-formatting “NOTE: The order of the physical and chemical properties presented in Section 9 may be followed on the SDS as shown in this table, but is not mandatory. The competent authority may decide to prescribe an order for Section 9 of the SDS, or they may leave it to the preparer of the SDS to re-order the properties, if deemed appropriate.”

    On the surface these seems to be a simple change in the order the order of properties which does not have to be followed. However, upon a closer inspection of Annex 4: Guidance on The Preparation of Safety Data Sheets, the real impact is seen. There are now THREE tables to consider.

  4. STOT SE Cat 3 Refinement. For many this category in regards to mixtures can be perplexing and to some – vague. When Revision 6 is published, a lone paragraph which further refines the extrapolation of the toxicity of the mixture, cut-off values/concentrations and “relevant ingredients” could help clarify many questions.
  5. Aspiration Category Revisions. Another Health Hazard that can be a challenge is the Aspiration Hazard especially in instances where classification of mixture is needed. Revision 6 completely revises Category 1 and Category 2 with the addition of “relevant ingredients” and the sum of ingredient concentrations. There is a paragraph now for the use of expert judgment and a revision to the “distinct layers” classification.
  6. Aquatic Toxicity M Factor adjustments. The use of M factors for Aquatic Toxicity also sees adjustment in Revision 6. In particular, the phrase “multiplied by their corresponding M factors” is now part of classification for Acute categories 1, 2 and 3. Those simple words could have far-reaching impacts when put to use.

The above are just a few of the changes for implementation with Revision 6 of the GHS. So consider Bowie’s words in the final chorus, “Ch-ch-Changes / Just gonna have to be a different man / Time may change me / But I can’t trace time”. <!–Be the first to order Revision 6 and be prepared for the changes.–>

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