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This presentation is intended for use by trainers with a working knowledge of the GHS and older labelling and classification systems in Australia.

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Presentation on theme: "This presentation is intended for use by trainers with a working knowledge of the GHS and older labelling and classification systems in Australia."— Presentation transcript:

1 This presentation is intended for use by trainers with a working knowledge of the GHS and older labelling and classification systems in Australia

2 The Globally Harmonized System of Classification and Labelling of Chemicals
This presentation is released under the Creative Commons Attribution 3.0 Australia Licence and may be reused and redistributed free of charge. For more information see

3 Part 2: Classifying Hazardous Chemicals to the GHS
The relationship between the GHS, the ADG Code and the NOHSC Approved Criteria

4 Part 2: Classifying chemicals according to the GHS (1 hour)
What is classification? Where do I get information to help me classify Cut-off limits Practical Example classifications Single chemical Mixtures Questions (feel free to ask at any time).

5 What this workshop will teach you
This session is aimed at providing you with the information to enable you to re-classify chemicals which have a classification under the older Australian Regulatory frameworks to the requirements of the GHS under the WHS legislation. In order to gain the most from this session, you need to have a basic understanding of the GHS, its hazard classes, pictograms and other labelling elements and previous regulatory frameworks for chemical classification. What this workshop won’t teach you Epidemiological assessments, weight of evidence classifications or interpreting data from animal or other studies to obtain a classification. Bridging principles for classifying mixtures. Although classification of mixtures is discussed, bridging principles for the classification of health effects of mixtures will not be. They can be complex and their usefulness is not always clear Because the approved criteria are based on the EU Dangerous Substances Directive (67/548/EEC), chemicals which are classified to this directive can be considered to be equivalently classified under the approved criteria. The bridging principles often offer limited value in classifying mixtures, especially if the hazard classifications of all the mixture’s ingredients are known. The easiest ways to classify a mixture are to: Directly translate the classification (depending on cut-off limits for classification) Classify it by obtaining the GHS classification of all components of the mixture, then apply the principles and cut-off limits of the GHS to classify the mixture; or Obtain testing data on mixture itself (this can be time consuming and expensive).

6 What you will need for this workshop
A copy of: Guidance on the Classification of Hazardous Chemicals Under the WHS Regulations and Code of Practice: Labelling of Workplace Hazardous Chemicals, or Code of Practice: Preparation of Safety Data Sheets for Hazardous Chemicals, or Classification and labelling for workplace hazardous chemicals poster and Acute toxicity hazard categories and ATE values from GHS – table in GHS text optionally the GHS, 3rd Revised Edition (The Purple Book).

7 Classification What is classification?
Classification is the process of determining the intrinsic physical, health and environmental hazards of a chemical. The GHS provides pre-defined hazard classes and appropriate sub-categories. Obtaining correct classification is important – for labelling and SDS. Label and safety data sheet follow. It is also a requirement under the WHS Regulations The systems used prior to GHS are based on two separate (but related), systems. Dangerous Goods - ADG Code, 7th Edition Physical hazards, acute toxicity, corrosion and environmental hazards Hazardous Substances - NOHSC approved criteria (AC) Health hazards Also included physical hazards and environmental hazards The correct classification dictates what goes on the label and certain sections of the label. This is what is seen and is used by workers. It is important that the classification done correctly. There is some overlap between the older systems. The GHS now provides harmonised criteria for physical, health and environmental hazards.

8 (Re)-Classification There is close alignment of most GHS classes with the ADG Code and the AC. GHS physical hazards are (almost) the same as the ADG Code. GHS health hazards have a great deal of overlap with the AC. Because this close alignment exists, the classification of chemicals under the ADG Code and the AC can be translated to a GHS classification. Guidance on the Classification of Hazardous Chemicals under the WHS Regulations Provides a translation for most ADG Code / AC to GHS classes. There are some overlaps between these systems for some health effects and physicochemcial effects. The GHS removes these overlaps and gives a single set of classification criteria for workplace chemicals. If you have actual data on a chemical, it should be used for classification.

9 Converting ADG Code  GHS classification
e.g. Class 3  Flammable Liquids & Division 4.1  Flammable Solids The transport classification can be found on the safety data sheet in section 14. A substance or mixture with an ADG classification is (essentially) already classified for GHS physical hazards. The GHS Physical Hazards Criteria is based on the United Nations Recommendations on the Transport of Dangerous Goods (UNRTDG) Model Regulations; with some exceptions. The criteria used in each category is the same (or very similar) in most cases. For Flammable liquids GHS ADG Cat. 1 fp<23°C and bp≤35°C PG I bp≤35°C Cat. 2 fp<23°C and bp>35°C PGII fp<23°C and bp>35°C Cat. 3 fp≥23°C and ≤60°C PGIII fp≥23°C and ≤60°C and bp>35°C Cat. 4 fp >60°C and ≤93°C C1 fp>60.5°C and ≤150°C (from AS 1940) The GHS does not provide classifications for Infectious Substances (Division 6.2) or Radioactive Materials (Class 7) and some Class 9 chemicals (elevated temperature or genetically modified materials).

10 Conversion of Approved Criteria  GHS Classification
e.g. R23 Toxic by inhalation  Acute toxicity - inhalation R-phrase to H-statement conversion GHS health hazards have a broadly similar scope to the Approved Criteria There are some differences to be aware of. There are a few overlaps and differences which can make classification slightly more difficult or onerous. There are also some differences in the physical hazards in the AC, compared to the GHS, however, physical data like flashpoint are easy to translate to the GHS. The LD50 values of some toxicity classes classes in the AC are different to those in the GHS. Units for inhalation of gases are also different and may need conversion (mg/m3 into ppmV) Some classifications in the Approved Criteria have no direct translation. However, in these cases this would be already captured by the Dangerous Goods classifications, so a classification can be derived.

11 Some issues with health hazards translation
Not all of the end-points for classification are the same and there is some overlap. 20 0.5 2 10 Cat. 1 Cat. 2 Cat. 3 Cat. 4 T, R23 T+, R26 Xn, R20 GHS App. Crit. Acute toxicity (vapours) - inhalation Direct translation of some health categories works on the principle of “minimum classification”. This means some existing chemicals may be under-classified by translation. For the majority of existing chemicals, translation would result in correct classification and for those which fall into the gap, there is often existing data (often can be found in the SDS) that can allow the classification to be adjusted. If no further data are available, then use the minimum classification as provided in the guidance until data can be generated. Example: A chemical normally liquid at room temperature is classified as Xn/R20. This translates to Acute toxicity (Inhalation) Category 4. However, the SDS gives data on the LC50 for inhalation of its vapour as being 7.5 mg/l. This would classify the chemical into Acute Toxicity (Inhalation) Category 3 according to the GHS. Always check the SDS for further useful information and cross-check with the Acute Toxicity Estimate table in the GHS (p. 109). Always check for data on SDS on toxicological information (usually section 11). Become familiar with the Acute Toxicity table in the GHS (p. 109).

12 Environmental Hazard Classification
e.g. R50/53  Acute/chronic aquatic toxicity Under the WHS Regulations, it is not mandatory to classify a chemical’s environmental hazard(s). However, it is considered best practice that if the information is available, then the classification should be given and appropriate label elements provided. Classification of some environmental hazards is mandatory for transport purposes. Environmental classification can usually be found in the SDS (sections 14 and 15).

13 GHS Hazard Classes The WHS Regulations refers specifically to the 3rd revision of the GHS All hazard classes except the following are included in the WHS Regulations: Acute toxicity – oral/dermal/inhalation: Category 5 Skin corrosion/irritation: Category 3 Serious eye damage/irritation: Category 2B Aspiration hazard: Category 2 Flammable gases: Category 2 Acute hazard to the aquatic environment: Categories 1 – 3 (all) Chronic hazard to the aquatic environment: Categories 1 – 4 (all) Hazardous to the ozone layer However, can use these hazard classes and associated label elements if they do not cast doubt upon the correct classification. Building block approach. Some hazard classes have been excluded to more closely align with current regulatory requirements. Environmental hazards are not mandated under WHS Regulations, however, if you have a classification, it would be considered good practice to include it on labelling and safety data sheets for the chemical(s). Some jurisdictions incorporate categories not in the WHS Regulations into their requirements. You may see chemical labels and safety data sheets with these classifications.

14 Supplementary Australian Hazard Classes
In addition to the GHS Hazard Classes, several additional classification have been adopted in Australia. AUH001 – Explosive when dry AUH006 – Explosive with or without contact with air AUH014 – Reacts violently with water AUH018 – In use may form flammable/explosive vapour/air mixture AUH029 – Contact with water liberates toxic gas AUH031 – Contact with acid liberates toxic gas AUH032 – Contact with acid liberates very toxic gas AUH044 – Risk of explosion if heated under confinement AUH066 – Repeated exposure may cause skin dryness and cracking AUH070 – Toxic by eye contact AUH071 – Corrosive to the respiratory tract Criteria found in the Classification Guide Appendices E&F and Codes of Practice for Labelling and Safety Data Sheets There are no labelling elements associated with these hazards Most of these categories are also in the Approved Criteria (except AUH070 and AUH071) For these additional hazard classes, there is no associated pictograms or precautionary statements. These hazard statements should appear on labelling and safety data sheets when applicable. These are the same additional hazard classifications as in the EU CLP regulations. Look out for possible future addition of these into the GHS. Some chemicals that might require these AUH-statements include: sodium cyanide (AUH032 and possibly AUH070), sodium hypochlorite (AUH031), acetyl chloride (AUH014), diethyl ether (AUH066), etc.

15 Classification Where can I get the information to allow re-classification? For the majority of chemicals currently used in Australia, a classification under the ADG / AC will likely already exist. Labelling Safety data sheets – relevant information to consult includes: R-phrases / hazard symbols Transport information (Dangerous Goods Classification / UN numbers) Physical and chemical properties mp / bp / fp / pH / LEL and UELs, etc. Toxicological information LD50 / LC50 for oral / dermal / inhalation routes of exposure Carcinogenicity / mutagenicity information Sensitisation / skin and eye corrosion / target organs, etc. Ecological information (for environmental hazards) Reactivity / stability data (may assist with non-GHS hazard classes)

16 Classification Where can I get the information to allow re-classification? Overseas classifications Beware: there are some differences in the “building blocks” between some countries. Countries are free to choose “building blocks”. If a building block in another country is not covered by the WHS Regulations then it does not need classifying into that category in Australia.

17 Classification Where can I get the information to allow re-classification? Online database and tools are also available to assist you in classifying workplace hazardous chemicals. Chemical suppliers’ websites Annex VI to CLP (http://esis.jrc.ec.europa.eu) Online translation tools (e.g. HSIS (http://hsis.safeworkaustralia.gov.au) eChemportal (http://www.echemportal.org) GREAT (http://great.cla.gov.tw/ENG/index.aspx) Further information available on our website: Other manufacturers and suppliers may have already classified to the GHS The classifications given in Annex VI to the CLP are mandatory in the EU HSIS gives recommended classifications for over 4700 chemicals. These can be translated using Safe Work Australia classification guidance. eChemportal provides classification information on chemicals substances from numerous national governments’ systems. GREAT (GHS Reference Exchange and Tool) offers translation of GHS label elements from English into over 30 different languages.

18 Classification – Single substances – and (some) mixtures
Process for classification using translation of R-phrase to H-statement Chemical needing classification Does the chemical have a classification under ADG/AC or (EU dir)? Gather all information available Use translation tables to derive classifications Classify the chemical Is testing data available? Possibly not hazardous Can’t classify. Need further information to proceed. Classify the chemical If the chemical has been classified under the ADG/AC (or has a classification under EU directive), these can be translated to equivalent classification in the GHS. Take note of any available toxicity data and any conflicts that may be present. If there is no data available, the material cannot be classified. You should contact the supplier for more information or obtain testing data to allow classification.

19 Classification of mixtures
For mixtures the translation process will provide adequate classification in the majority of cases – if cut-off limits are not a problem. The translation of physical hazards should be straightforward. However, changes to some cut-off concentrations and the way in which chemicals in some categories contribute to the classification may affect some cases. You need to be aware of the cut-off limits under the GHS vs. the AC. Beware! If the GHS cut-off limit is lower than its equivalent in the AC, direct translation could result in non-classification. If the GHS cut-off limit is higher than its equivalent in the AC, direct translation could result in over-classification. Specified cut-off limits in HSIS do not apply under WHS Regulations! Physical hazards are usually based on physical testing data or prediction models, so the direct translation can be done confidently. On the basis that most existing mixtures do not have testing, then, depending on cut-off limits, a translation will be valid. Cut-off concentrations apply only to health hazards. The translation of health hazards can be more difficult, due to some differences in the classification criteria and cut-off concentrations. Care should be taken when translating these classifications. HSIS contains several cut-off limits which have been specified and are different to those given the Approved Criteria. For example, sodium hydroxide and phosphoric acid solutions need careful attention when classifying.

20 Classification of mixtures
Cut-off limit comparison  reproductive toxicity Cut-off limits and special instructions can be found in each health hazard chapter of the GHS. Further, the WHS Regulations implements some specific cut-off concentrations. These changes are detailed Schedule 6 of the WHS Regulations or in Appendix G of the Classification Guidance Document Follow the decision logic in each chapter of the GHS. There are some gaps which could lead to non-classification if relative cut-off concentrations are not considered. Most problems are likely to occur for the following GHS categories: Skin or respiratory sensitisers: Category 1A Reproductive toxicity Skin corrosion/irritation Serious eye damage/irritation Conversely, there are some approved criteria cut-off concentrations which are lower than the GHS equivalent. This means that there are some mixtures classified under the AC which would not require classification to the GHS. If a translation is done, this would result in over-classification – which would not be considered an issue.

21 Classification of mixtures
Mixtures not classified under AC which would be under GHS You need to be aware of the cut-off limits under the GHS vs. the AC. Manufacturer should be able to supply the information needed to classify properly.

22 Classification of mixtures
Acute Toxicity Estimate To estimate the toxicity of components in a mixture, the GHS provides a formula 𝟏𝟎𝟎 𝑨𝑻𝑬𝒎𝒊𝒙 = 𝒏 𝒊 𝑪𝒊 𝑨𝑻𝑬𝒊 Where: ATEmix = Acute toxicity estimate of mixture ATEi = Acute toxicity estimate of ingredient Ci = concentration of ingredient n = number of ingredients from 1 to i Only need to consider components which are greater than 1 % w/w, unless it is known there is a health effect at a lower level.

23 Classification of mixtures (where cut-offs are close)
Process for classification Can’t classify mixture – contact supplier to obtain more information Mixture needing classification Use known and/or derived GHS classification of individual components Gather all information available Test data on similar mixtures? Is hazard data available for some or all components? Is testing data available? Can bridging principles be applied? Classify the mixture – according to cut-off limits As with any other hazardous chemical, if the testing data for the mixture is available, this should be used to classify the chemical. Some chapters contain information on bridging principles (apply to health/environmental hazards only) that can be applied to mixtures to assist in classification if data on a similar mixture exists, e.g. Dilution, batching, concentration, interpolation, substantially similar mixtures. This process can be complicated and usefulness not always clear. It is outside the scope of this material. Often best to derive the individual classification of each component and work out the overall classification from there. Classify the according to the more severe hazards first. This often means you do not need to consider hazards of the same class but in a lower category. Classify the mixture Classify the mixture

24 Classification examples
9 examples of reclassifying substances or mixtures according to the GHS For each example, provide label elements: Hazard classes and categories; Signal word; Pictograms; Hazard statements. Use reference materials to assist you assigning the label elements. Return for discussion and answer session

25 Classification – Single substances
Example 1: pH Indicator A laboratory chemicals supplier is re-classifying its products to the GHS. The regulatory compliance officer extracted the following salient data on its classification. What would the classification be under the GHS? Provide the associated signal words, pictograms and H-statements? Data from SDS / Labelling GHS Classification Transport information: Div. 6.1 PG III Acute toxicity: Cat. 3 (oral, dermal, inhalation?) Risk phrases: R25 – Toxic if swallowed R40 – Limited evidence of a carcinogenic effect Acute toxicity – Oral: Cat. 3 Carcinogenicity: Cat. 2 Other useful information: LD50 oral – rat – 200 mg/kg mp = 111°C Acute toxicity – Oral: Cat. 3 The first step is to gather relevant data from suitable sources. Often information on the SDS/labelling is enough. Once this information has been gathered, use the translation tables in the Safe Work Australia Classification Guidance to convert ADG and AC classifications into GHS classifications. Once the hazard classifications have been derived, the appropriate Signal Words, Pictograms and Hazard Phrases can be retrieved from the relevant sections in the Labelling or SDS Codes of Practice.

26 Classification Example 1: pH Indicator: Answer GHS Classification
Acute toxicity – Oral: Cat. 3 Carcinogenicity: Cat. 2 Signal Word: DANGER H301 Toxic if swallowed H351 Suspected of causing cancer Pictograms: + WARNING Once a classification is obtained, this is used to obtain the labelling elements. Each hazard class is associated with certain Signal Words, Hazard Phrases, Pictograms and Precautionary Phrases. Signal word: Either DANGER or WARNING. If your hazard classes give both DANGER and WARNING, only display DANGER. This should be on the label and the SDS. Hazard statements: Each hazard class and category derived gives a specific hazard phrase to put on to the label / SDS. Note that the H-codes are not to appear on labels but they can be displayed on SDS. Pictogram: Each hazard class is associated with a specific pictograms displaying the potential hazards. These should be on the label and can be displayed on the SDS. Precautionary statements: These provide information on handling, storing and using the chemical – prevention, response, storage, disposal. Not shown here for reasons of clarity. Recommended that only 6-10 appear on label/SDS, so there may be a need to cull or combine some phrases. 26

27 Classification Example 2: Disinfecting agent Data from SDS / Labelling
A manufacturer of a solid disinfecting chemical agent is re-classifying from ADG/AC to comply with the requirements of the GHS under the WHS Regulations. The following ADG/AC classification information is available. What would the classification of this compound be under the GHS? Data from SDS / Labelling GHS Classification Transport information: Div 5.1 PG II Oxidising solids: Cat. 2 Risk phrases: R8 – contact with combustible material may cause fire R22 – harmful if swallowed R50/53 – very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment No translation possible (but covered by DG classification) Acute toxicity – Oral: Cat. 4 Acute aquatic toxicity: Cat. 1 Chronic aquatic toxicity: Cat.1 Classifying environmental effects is not mandatory under WHS Regulations. Acute/chronic aquatic toxicity – Cat. 3 is not classifiable under the ADG code for transport purposes as a dangerous good. Toxicity data on a SDS is usually a good measure of confirming or modifying acute toxicity classifications. Other useful information: LD50 oral – rat – 1090 mg/kg Acute toxicity – Oral: Cat. 4

28 Classification Example 2: Disinfecting agent: Answer
GHS Classification Oxidising solids: Cat. 2 Acute toxicity – Oral: Cat. 4 Signal Word: DANGER H272 May intensify fire; oxidiser H302 Harmful if swallowed Pictograms: Acute aquatic toxicity: Cat. 1 Chronic aquatic toxicity: Cat. 1 H400 Very toxic to aquatic life H410 Very toxic to aquatic life with long lasting effects H410 Very toxic to aquatic life with long lasting effects Where hazard statements have repeat information or can be combined without casting doubt, then it is permissible to condense the information. The GHS text and Code of Practice gives information on how this is done. Note, for workplace purposes that environmental classification is not compulsory and so the environmental categories do not need to be put on labels or in the classification section on the SDS. However, the classification would be required for transport purposes. Good practice to put environmental classification on labels.

29 Classification Example 3: Plastics starting material
A safety officer at a plastics manufacturer is reviewing the classifications of its products and raw materials to comply with the GHS requirements of the WHS Regulations. After extracting the necessary information from the SDS and labelling, this chemical was reclassified. What should the classification be? Data from SDS / Labelling GHS Classification Div. 6.1 (3) PG II Acute toxicity: Cat. 2 (plus Flammable liquid) R45 – may cause cancer R23/24/25 – toxic by inhalation, in contact with skin and if swallowed R10 – flammable R34 – causes burns R43 – may cause sens. by skin contact Carcinogenicity: Cat.1B Acute toxicity – Inhalation: Cat. 2 (use vapour) Acute toxicity – Dermal/Oral: Cat. 3 Flammable liquids: Cat. 3 Skin corrosion: Cat. 1B Skin sensitisation: Cat. 1 LD50 oral – rat – 90 mg/kg LC50 inhalation (4h) – rat – 3.1 mg/L Probably carcinogenic to humans bp = 115°C / fp 32°C Acute toxicity – Oral: Cat. 3 Acute toxicity – Inhalation: Cat. 3 Carcinogenicity: If unsure about denoting as Cat. 1A or Cat. 1B, then use the “umbrella” Cat. 1; The labelling elements are the same. Translation table would classify R23 as Acute Toxicity – Inhalation Cat. 2; this material is a liquid, so you should use the vapour physical state for classification. Inhalation data is available on the SDS. Can use this to assign to Acute tox. Cat. 3 for inhalation, rather than Cat. 2.

30 Classification Example 3: Plastics starting material: Answer
GHS Classification Carcinogenicity: Cat. 1B Acute toxicity – Inhalation: Cat. 3 Acute toxicity – Dermal: Cat. 3 Acute toxicity – Oral: Cat. 3 Flammable liquids: Cat. 3 Skin corrosion: Cat. 1B Skin sensitisation: Cat. 1 Signal Word: DANGER H350 May cause cancer H301+H311+H331 Toxic if inhaled, if swallowed and in contact with skin H226 Flammable liquid and vapour H314 Causes severe skin burns and eye damage H317 May cause an allergic skin reaction Pictograms: Remember, hazard statements can be combined when appropriate to do so. There are precedence rules for pictograms. Where the skull and crossbones applies, the exclamation mark should not appear. These rules are dealt with in more detail in the labelling Code of Practice. Precedence rules for pictograms See Codes of Practice

31 Classification Example 4: Bulk supply of solvent
A solvent supplier provides delivery of solvents in drums of 200 L in volume. These drums are transported directly to workplaces on pallets in a truck. How should this solvent be classified and labelled? Data from SDS / Labelling GHS Classification DG Classification – Div. 3 PG II Flammable liquids: Cat. 2 R45 – may cause cancer R46 – may cause heritable genetic damage R48/23/24/25 – toxic: danger of serious damage to health through prolonged exposure through inhalation, in contact with skin and if swallowed R65 – harmful: may cause lung damage if swallowed R11 – highly flammable R36/38 – irritating to eyes and skin Carcinogenicity: Cat. 1A Germ cell mutagenicity: Cat. 1B STOT Repeated Exposure: Cat. 1 Aspiration hazard: Cat. 1 Flammable liquid: Cat. 2 Eye irritation: Cat. 2A / Skin irritation: Cat. 2 LD50 oral – rat – 2990 mg/kg LC50 inhalation – rat – 447 mg/l LD50 dermal – rabbit – 8263 mg/kg bp = 80°C / fp = -11°C In vivo test shows mutagenic effect Known to cause cancer in humans Acute toxicity – Oral: Not classified Acute toxicity – Inhalation: Not classified The clue here is direct transporting of drums on pallets. This means labelling elements (pictograms) must comply with ADG Code. Use dangerous goods class labels where appropriate. Acute toxicity – Dermal: Not classified

32 Classification Example 4: Bulk supply of solvent: Answer
GHS Classification Flammable liquids: Cat. 2 Carcinogenicity: Cat. 1A Germ cell mutagenicity: Cat. 1B STOT – Repeated Exposure: Cat. 1 Aspiration hazard: Cat. 1 Eye irritation: Cat. 2A Skin irritation: Cat. 2 Signal Word: DANGER H225 Highly flammable liquid and vapour H350 May cause cancer H340 May cause genetic defects H372 Causes damage to organs through prolonged or repeated exposure <…> H304 May be fatal if swallowed and enters airways H315 Causes serious eye irritation H319 Causes skin irritation Pictograms: Because it is intended to transport this solvent in 200 L drums, appropriate transport labels must be on the outside of the container. For STOT – RE if the route of exposure is known and/or the organ/s affected is/are known, these can be stated in the H-statement e.g. Causes damage to the kidneys through repeated exposure by inhalation. DG label required for transport

33 Classification Example 5: Compressed gas Data from SDS / Labelling
A gas manufacturer is re-classifying its products to accord with the GHS. The following data for the gas is known. The product is supplied in cylinders. How would you classify this gas according to the GHS? Data from SDS / Labelling GHS Classification DG Classification – Div. 2.3 (8) Acute toxicity (gas) (Sub. risk – corrosive) R10 – flammable R23 – toxic by inhalation R34 – causes burns R50 – very toxic to aquatic organisms Flammable gases: Cat. 2 (Not classified) Acute toxicity – Inhalation: Cat. 3 Skin corrosion: Cat. 1B Acute aquatic toxicity: Cat. 1 LC50 inhalation – rat – 2000 ppmV LEL – 15 % v/v / UEL – 25 % v/v Acute toxicity – Inhalation: Cat. 3 Flammable gases: Cat. 2 (Not classified) For gases, the data on flammability/lower and upper explosion limits is necessary to obtain a proper classification. In this case the gas is classified as Flammable gas Cat. 2 – under the WHS Regulations, this is not classifiable. This more closely represents the transport sector. Gases under pressure: Compressed gas

34 Classification Example 5: Refrigeration gas: Answer GHS Classification
Gases under pressure: Compressed gas Acute toxicity – Inhalation: Cat. 3 Skin corrosion: Cat. 1B Acute aquatic toxicity: Cat. 1 Signal Word: DANGER H280 Contains gas under pressure; may explode if heated H331 Toxic if inhaled H314 Causes severe skin burns and eye damage H400 Very toxic to aquatic life Pictograms:

35 Classification Example 6: Herbicide Data from SDS / Labelling
How would this herbicide be classified and labelled according to the GHS given the information below on its classification under the ADG and AC? Data from SDS / Labelling GHS Classification DG Classification – Div. 6.1 PG II Acute toxicity: Cat. 2 R61 – may cause harm to the unborn child R24 – toxic in contact with skin R28 – very toxic if swallowed R44 – risk of explosion if heated under confinement R50/53 – very toxic to the aquatic environment, may cause long-term adverse effects in the aquatic environment Reproductive toxicity: Cat. 1B Acute toxicity – Dermal: Cat. 3 Acute toxicity – Oral: Cat. 2 No GHS equivalent – AUH044 Acute/chronic aquatic toxicity: Cat. 1 Presumed human reproductive toxicant LD50 oral – rat – 26 mg/kg LD50 dermal – rat – 150 mg/kg Acute toxicity – Oral: Cat. 2 Acute toxicity – Dermal: Cat. 2 For reproductive toxicity, if it is not certain whether to place into Cat. 1A or Cat. 1B then it is acceptable to use Cat. 1 only; the labelling elements are identical.

36 Classification Example 6: Herbicide: Answer GHS Classification
Acute toxicity – Dermal: Cat. 2 Acute toxicity – Oral: Cat. 2 Reproductive toxicity: Cat. 1B Acute aquatic toxicity: Cat. 1 Chronic aquatic toxicity: Cat. 1 Signal Word: DANGER H300+H310 Fatal if swallowed or in contact with skin H360 May damage the unborn child H410 Very toxic to aquatic life with long-lasting effects Pictograms: AUH044 Risk of explosion if heated under confinement

37 Classification of mixtures
Example 7: Alcohol:water solution The following mixture is a commercially-available rinsing solution used for cleaning scientific instruments. It is a 50:50 mixture of an alcohol and water. How would this be classified and labelled under the GHS? Data from SDS / Labelling GHS Classification DG Classification – Class 3 PG II Flammable liquids: Cat. 2 R10 – flammable R36 – irritating to eyes R67 – vapours may cause drowsiness Flammable liquids: Cat. 2 Eye irritation: Cat. 2A STOT – Single Exposure: Cat. 3 No toxicity data on SDS fp 22°C No boiling point data on mixture itself Bp of alcohol is 82-83°C There are two ways in which this translation can be done. There are sufficient data available and cut-off concentrations are same from approved criteria so classification can be done simply by translation (we know boiling point/flash point data, too). The cut-off limit for Eye irritation Cat. 2 and STOT – SE Cat. 3 are both 20%. The R-phrase to H-code translation can be done with confidence in this case. Alternatively, can find the individual classifications of each component and use cut-off limits to derive the classification.

38 Classification of mixtures
Examples of classification using translation tables Example 7: Alcohol : water solution GHS Classification Flammable liquid: Cat. 2 Eye irritation: Cat. 2A STOT – Single exposure: Cat. 3 Signal Word: DANGER H225 Highly flammable liquid and vapour H319 Causes serious eye irritation H336 May cause drowsiness or dizziness Pictograms: Concentration of the alcohol is well above the suggested cut-off limit for STOT-SE 3. In this case, we can just translate the classification from ADG/AC to GHS with confidence. Cut-off limits only apply to health hazards in the context of the WHS Regulations.

39 Classification of mixtures
Example 8: Insecticide preparation A ready-for-bottling herbicide preparation is being supplied from the manufacturing plant to the bottling plant. It will be stored in bulk containers in the plant’s warehouse for a few weeks until it is processed. In order to meet the WHS requirements for storage, the preparation requires labelling in accordance with the regulations prior to it being bottled for consumer use. The active insecticide is present at 0.4 %w/w. What will the GHS classification be? What would happen if the classification was directly translated from its classification under the previous schemes? Data from SDS / Labelling GHS Classification DG Classification – Not classified Not classified Not classified as a hazardous substance Not classified If we were to directly translate, this preparation would have no classification. Would this be correct? Care must be taken to take into account the cut-off limits of the GHS. Some cut-off limits are lower under GHS. The SDS provides information on individual ingredients and their proportions. This allows a classification to be derived by retrieving data on hazardous components.

40 Classification of mixtures
GHS Classification To classify this mixture, the GHS classifications and toxicology information can be obtained from the active ingredient’s SDS. Pyroglusinate: (0.4 %w/w) R60/61: May impair fertility; May harm the unborn child R20/21/22: Harmful by inhalation, in contact with skin or if swallowed R48/20/22: Danger of serious damage to health by prolonged exposure through inhalation and if swallowed. LD50 – oral = 1620 mg/kg; LC50 – inhalation = 1260 mg/m3; LD50 – dermal = 2000 mg/kg Other components: (99.6 %w/w) Not classified as hazardous Acute Toxicity – component below 1 %w/w, so no need to consider. Apply other cut-off limits in GHS / Regulations to ascertain the classification. Breaches cut-off for Reproductive toxicity: Cat. 1 No data is available to place into Reproductive Toxicity Cat. 1A or 1B, so using Cat. 1 is acceptable and results in the same labelling elements.

41 Classification of mixtures
GHS Classification Reproductive toxicity: Cat. 1 Signal Word: DANGER H360 May damage fertility or the unborn child Pictogram(s): Always pay attention to cut-off limits. If GHS cut-off is lower than AC  possible non-classification If GHS cut-off is higher than AC  possible under-classification In this instance, this mixture would have been given no classification had the information been directly translated. It is the manufacturer’s responsibility to correctly classify. If more information is needed to correctly classify a mixture, then ask the manufacturer(s) of each component to provide you with that information so you can derive the classification can be derived.

42 Classification of mixtures
Example 9: Rust-removing preparation The following data relates to a rust-removing preparation. According to the SDS, the material is classified as a hazardous substance under the AC but there is no dangerous goods classification. What issues could you face classifying this mixture? What would you do to classify this material to the GHS and what would its classification be? Data from SDS / Labelling GHS Classification DG Classification – Not classified Not classified R36 – Irritating to eyes R52 – harmful to aquatic organisms R53 – may cause long term adverse effects in the aquatic environment Serious eye irritation: Cat. 2A Acute/Chronic aquatic toxicity: Cat. 3 Is this classification correct? Care must be taken when reclassifying mixtures with corrosive components. Cut-off concentrations are significantly different versus the AC When re-classifying mixtures which have corrosive components, care needs to be taken. The cut-off concentration limits for skin and eye damage/corrosion are significantly different. Although a classification can be derived from directly translating the previous classifications, it is not correct. This is because cut-off limits must be taken into account. The data on the SDS shows that the active ingredients are present at about 9.95% - this is just below limits for classification under the AC for corrosion. BUT, they are above the limits for classification in the GHS. There is no hazardous substance classification on the SDS. Environmental effects are classified. The SDS provides information on individual ingredients and their proportions. This allows a classification to be derived by retrieving data on hazardous components.

43 Classification of mixtures
GHS Classification To classify this mixture to the GHS, individual GHS classifications and toxicology information can be obtained from individual components’ SDSs. Acid component 1: (9.95 %w/w) Eye irritation: Cat. 2A / Skin irritation: Cat. 2 Acute/chronic aquatic toxicity: Cat. 3 Acid component 2: (9.95 %w/w) Acute toxicity – Oral: Cat.4 (LD50 = 1950 mg/kg) Skin corrosion: Cat. 1B / Serious eye damage: Cat. 1 STOT – SE: Cat. 3 Surfactants: (20 %w/w) Not classified as a hazardous chemical/env. hazard (can ignore for classification) Need to check the cut-off limits against each category to check if it will contribute to the overall classification of the mixture. Where skin and eye categories exist, it is recommended to classify the skin class first as Skin corrosion: Cat. 1 also covers serious eye damage (it is assumed that all skin corrosion: cat 1 also cause serious eye damage, but not necessarily the other way round). Always classify the higher intrinsic hazard first if there is more than one contributing category for the hazard class. Always follow the decision logic in each chapter of the GHS for classifying mixtures, taking into account any specific Australian cut-off as specified in the WHS Regulations or in Appendix G of the classification guide. If your mixture is close to the cut-off limits under either system, then take care to ensure that a classification is not missed. Need to calculate ATE using formula in GHS text – see Cut-off for Skin Corr. 1B is ≥5% and ≥3% for Eye Dam. 1

44 Classification of mixtures
GHS Classification Skin corrosion: Cat. 1B Acute/Chronic aquatic toxicity: Cat. 3 Signal Word: DANGER H314 Causes severe skin burns and eye damage H402 + H412 Harmful to aquatic life with long lasting effects Pictogram(s): If direct translation of R-phrases was used: Serious eye irritation: Cat. 2A Acute/Chronic aquatic toxicity: Cat. 3 Signal Word: WARNING H314 Causes serious eye irritation H402 + H412 Harmful to aquatic life with long lasting effects Pictogram(s): If the translation was done purely on the available classification, this would have given Eye irritation 2A and Acute/chronic aquatic toxicity Cat. 3. The “Environment” pictogram is not required for the level of hazard this chemical poses.

45 Classifying mixtures Gather as much information as you can – where test data is available, use it. Most mixtures should be able to be re-classified using direct translations of R-phrases to H-statement. However, where components are close to cut-off concentrations, re-classifying sometimes may involve a few extra steps. If this is not possible, obtain the individual classifications (GHS or AC/ADG) of each component and derive the overall classification from there. Contact the supplier/manufacturer/importer for extra information if necessary. The decision logic in each chapter of the GHS text can help greatly. The translation of physical and environmental hazards should be more straightforward.

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