Keywords

GHS, Safety Data Sheets, Raw Materials, Labeling, Classification

Track

Metalworking III (Session 3K)

The Case for Product Testing 

Under OSHA’s rules implementing the Globally Harmonized System of authoring Safety Data Sheets and labels, formulators and SDS authors now need to classify products for hazards. If critical test data – eye and skin irritation and acute toxicity – are not available, a detailed assessment of hazards based on the classifications of all included components according to the GHS rules for mixtures must be completed. Classification based on this approach may result in “overclassification,” that is, a product concentrate classified as a skin corrosive when, in fact, it is a skin irritant. While OSHA says testing is not required, formulators may find it advantageous to test key products and use “bridging principles” to extend application of key product testing results to other products. With a target date of June 1, 2015, 
for all new SDSs and labels to be completed, much work needs to be done – and quickly. Using examples and cost estimates, the case for product testing will be reviewed.

Authors and Company/Institution

John K. Howell and Richard C. Kraska, GHS Resources Inc., Edinboro, PA

The Case for Product Testing
(Adobe PDF File)