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Section 2: Hazards Identification
For obvious reasons, Section 2 of a GHS Safety data sheet is often considered the most important section.
It should contain:
The hazard classification of the hazardous substance or mixture.
The hazard communication elements which should appear - identically - on the label.
The details of any other hazards which may also apply but fall out of the scope of the European Union classification system.
2.1. Classification of the Substance or Mixture and any National or Regional Information
This subsection will contain the classification for the hazardous substance or mixture.
It should provide:
The hazard categories.
The hazard classes.
The hazard statements.
Please note: If you are dealing with an older substance or mixture's safety data sheet, it may contain information relating to the old CHIP regulations. In this case, this subsection should provide the indications of danger, the symbol letters and the risk phrases.
The hazard statements (or risk phrases) may be written out in full here in this subsection. However, if your supplier only includes the numerical codes here, they must write out the full hazard statements (or risk phrases) in Section 16.
Determination of the Hazard Classification
A system was designed to enable people to reliably classify the hazards we identify. To classify substances and mixtures, you can compare their physicochemical, toxicological and ecotoxicological properties against a set of classification criteria set out in the relevant regulations.
In cases where no data is available when trying to classify a mixture, then the classification can be determined by comparing the mixture to a similar mixture for which data is available, or it can be calculated based on the composition of the mixture.
There are a great many pure substances already listed in Part 3 of Annex VI of the CLP regulations. Classification is mandatory, but these classifications are only the minimum that is required.
When classifying a substance, only certain hazard classes are considered so suppliers of those substances must determine whether they present any additional hazards.
For any substances not already classified and listed in CLP, then the supplier must determine the classification of the substance for each potential hazard and then notify the ECHA. The ECHA will then place the information on the Classification and Labelling (C&L) Inventory.
It is very likely when searching through the C&L Inventory that you will come across many substances which have been given multiple classifications. This is because different suppliers are often working from different datasets, and as such come up with slightly different results.
However, the way the C&L Inventory is designed to work allows suppliers to discuss their results and eventually bring each substance down to only one classification by agreement.
You should understand that these hazards are inherent to the product. You cannot remove them. This information is vitally important, alongside how - and how much of - the substance is handled and its physical properties. It will allow you to determine the risks faced by your people and the environment.
Please note: As has been stated previously in this guide, the information provided in this section and other sections in an SDS is meant to assist you in your assessment of risk. However, the information itself does NOT constitute a risk assessment. A real risk assessment involves an assessment of the potential exposure determined from the processes and procedures involved.
Non-Classified Products
There are many substances and mixtures out there which are not classed as hazardous but have safety data sheets published for them anyway. There is no regulatory requirement to do so, but many suppliers will publish them anyway and attach the words 'not classified' or 'not classified under EC Directives or Regulations' to this subsection.
They publish these safety data sheets because the information provided in them can still be used to assist you in your risk assessment. Often, the ingredients in non-classified products do present hazards - they were just below the classification threshold and as such were deemed not hazardous.
However, you should still take precautions and properly risk assess the substance or mixture and your uses of it. This is especially important if the product wasn't classified solely due to a lack of data. In this case, the product may well be extremely hazardous.
M-Factors
In the case of environmentally hazardous substances, you will also notice 'M-Factors' written in this subsection. An M-Factor is the multiplication factor used to calculate the classification of mixtures containing substances which are known to cause damage to the environment.
The purpose of an M-Factor is to effectively lower the classification limits for significantly hazardous substances. It is not a legal requirement for suppliers to provide the M-Factor , but it is STRONGLY recommended.
M-Factors will assist you in classifying a formulation should you need to do so.
2.2. Label Elements, Including Precautionary Statements
Subsection 2.2 will contain all of the hazard communication elements that should be included on the label. This information should match - exactly - the information provided on the label and be consistent with the hazard classification provided in subsection 2.1.
For non-classified products, the supplier may still provide some precautionary statements to caution you of the actions which should be taken when using and handling the substance(s).
This subsection should contain:
Hazard pictograms.
Hazard statements.
Precautionary statements.
The signal words.
Obligatory additional labelling statements (e.g. supplementary hazard information).
Hazard Pictograms
The hazard pictograms are designed as red-framed diamonds with black illustrations to indicate which type of hazard they represent.
Precautionary Statements
Precautionary statements are statutorily defined phrases designed to give information on the necessary precautions to take with a substance or mixture.
There are five categories of precautionary statements:
Disposal.
General.
Prevention.
Response.
Storage.
Generally, you will only find approximately 6 precautionary statements listed in this subsection. However, if there are more which apply to the product, they will be included in the relevant sections of the safety data sheet.
Hazard Statements
Hazard statements are statutorily defined phrases which are designed to indicate specific hazards. To assign a hazard statement to a product, you must compare its data against the CLP classification criteria.
Hazard statements will often inform you of the route of entry into your body the substance or mixture can take. If the product is known for specific target organ toxicity, then organ(s) affected may also be included.
Signal Word
The majority of hazardous chemicals have a signal word attached to them. These signal words are assigned based on the severity of the hazard.
Substances which present the most dangerous hazards are assigned the signal word 'Danger', and those which present lesser hazards are assigned the signal word 'Warning'.
There are hazards which do not have an associated signal word (e.g. the less severe environmental categories).
Supplementary Hazard Information
When the Globally Harmonised System of Packaging and Labelling was introduced by the UN, some of the risk phrases from CHIP were dropped and no equivalent was included in the GHS.
Because of this, when the European Union were developing the CLP regulations, they include the old risk phrases and named them supplementary hazard statements.
Like the general hazard statements, they have a corresponding numerical code and have been used to carry over other labelling elements required by the CHIP regulations.
In the case of mixture where no data is available on a particular ingredient and its toxicity, then the label is required to include a statement similar to, "X% of the mixture consists of component(s) of unknown acute toxicity." If that percentage is 15% or higer, then the statement must also be included on the SDS.
Likewise, mixtures, where there is no data for their ingredient's acute and long-term hazards to the aquatic environment, must have a statement saying, "Contains X% of components with unknown hazards to the aquatic environment" on the label and the SDS.
Other Hazards Which do not Result in Classification
Where there are hazards which were not classified due to being out of the scope of the regulations, information on those additional hazards will be included in subsection 2.3. These types of hazard still present a risk to you and your workers, even if there was no classification.
The supplier is required to include whether their substance or mixture is Persistent Bioaccumulative Toxic (PBT) or very Persistent very Bioaccumulative (vPvB) in this subsection.
Product Labels
It's very important to remember to read the product label in conjunction with the relevant safety data sheet. Each element of classification on the label should matchb those provided in subsection 2.2.
If you find a product label which doesn't match it's safety, you are required to contact the supplier for clarification.
Please note: It is a legal requirement that suppliers include their name, address, telephone number, the nominal quantity, the product name (including the names of four ingredients which contribute to the product classification for the most serious health hazards, if the product is a mixture.)
Confused by the many pieces of information provided in your safety data sheets? Join the International Association for Chemical Safety's completely free health and safety academy now and take the Safety Data Sheet Awareness Certification™.
This article was originally published by the team over at Sevron Ltd and has been shared here with full permissions.