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Hazard Communication

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US Consumer Products:

Research has demonstrated that a consumer’s attention can be diverted from important use and safety information by too much information on a label. Placement of information regarding all potential hazards posed by a consumer product could contribute to this effect. Furthermore, it was shown that warnings focused on specific hazards that are likely to cause injury to man or the environment enhance consumer and environmental protection. 

US Workplace:

The American Cleaning Institute supports the adoption of the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals for workplace situations, consistent with the statutory authority of the Occupational Safety and Health Administration (OSHA).

Under its statutory authority, the Occupational Safety and Health Administration (OSHA) has adopted changes in its hazard communication rule to incorporate the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals for workplace situations.

Documents:

ACI comments on the Occupational Health and Safety Administration’s (OSHA) Advanced Notice of Proposed Rulemaking (ANPR) seeking further information about the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals, the benefits of adopting it, and its potential impact on the Hazard Communications Standard (HCS) (Federal Register, September 12, 2006), Docket No. H-022K, November 13, 2006

ACI and the Consumer Specialty Products Association (CSPA) comments on the Occupational Health and Safety Administration’s (OSHA) Notice of Proposed Rule Making (NPRM) to modify its existing Hazard Communication Standard (HCS) to align with the United Nation’s Globally Harmonized System (GHS) of Classification and Labeling of Chemicals, Federal Register (Vol. 74, No. 188, September 30, 2009), Docket No. OSHA-H022K-2006-0062, December 23, 2009

Links:

Existing Rule

New Rule

Environmental Protection Agency:

ACI comments on proposals and options that represent the Environmental Protection Agency’s (EPA) thoughts for implementation of the Globally Harmonized System (GHS) for Chemical Hazard Classification and Labeling, as cited in the Federal Register (69 FR 52262) notice "Pesticides; Implementation of Globally Harmonized System; Notice of Availability," Submitted to Office of Pesticide Programs (OPP), Environmental Protection Agency, Docket ID Number OPP-2004-0205, December 6, 2004

United Nations:

The United Nations (UN) is undertaking a program to harmonize the classification and labeling of chemicals worldwide for health and environmental effects under a program adopted at the UN Conference on Environment and Development held in 1992. While appropriate for workplace and transport situations, the proposed classification criteria, which are focused on hazard classification, have the potential to affect the U.S. safety laws and regulations for consumer products, as well as the global competitiveness of U.S. companies if decisions to warn consumers are based on hazard rather than risk.

ACI efforts on this international initiative have focused on having classification and labeling systems that encompass consumer product applications incorporate consideration of risk in making labeling decisions.

Link:

Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Fourth revised edition, United Nations, 2011
http://www.unece.org/?id=25985

Japan:

Guidance on a consumer product risk assessment for GHS labeling
http://www.safe.nite.go.jp/english/ghs/consumer_product.html

Consumer Products

Research has demonstrated that a consumer’s attention can be diverted from important use and safety information by too much information on a label. 1-6 Placement of information regarding all potential hazards posed by a consumer product could contribute to this effect. Furthermore, it was shown that warnings focused on specific hazards that are likely to cause injury to man or the environment enhance consumer and environmental protection.

For example, studies on the comprehensibility and effectiveness of labelling performed in the EU and US over the years have recommended a number of improvements in the labeling requirements in existing systems. These improvements are related to making information more relevant and actionable for the chemical user. These studies confirm the need for considering in particular risk in the labelling of consumer products as indicated in the following abstracts:

  • EU DPD 3
    • "Simplification of [label] content as well as simplification of layout" was been recommended.
  • Dutch Consumer Safety Institute 1
    • "More benefits can be expected if the labelling system is changed to be more consumer and risk oriented".
  • US 5
    • Labels for different product categories "should not be treated in the same way since consumers perceive the products differently and have different label reading habits for each category."
    • "Consumer want clear, concise, easy-to-read information that connects consequences with actions."

In order to place a hazard warning on a label of a substance or product for consumer use, it should satisfy a two-part test. First, it should present a hazards based on specific criteria. Second, it should have the potential to cause substantial illness or injury during or as a result of "reasonably foreseeable handling or use or ingestion by children." Consumer exposure resulting from the use of products, including foreseeable use and accidents, can be estimated since products are designed for specific use(s). In other words, whether a given substance presents a hazard depends not only on whether it is toxic, but also on exposure and risk. The steps in this process are consistent with the U.S. Consumer Product Safety Commission’s Guidelines 7.

The scope of the work of harmonizing chemical hazard communication under the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) (CG/HCCS), states 8:

"The application of the components of the system may vary by type of product or stage of the life cycle. Once a chemical is classified, the likelihood of adverse effects may be considered in deciding what informational or other steps should be taken for a given product or use setting."

This statement acknowledges that for certain products or use settings, once the hazard(s) of a chemical/product are identified and classified using GHS criteria, information on the likelihood of illness or injury may be used to determine if these hazard(s) need to be communicated.

ACI has supported the adoption of the risk-based approach to the GHS for consumer products, consistent with the mandate of the authority given to CPSC. The Commission has announced that it would adhere to the mandates for risk-based decision-making embedded in a number of federal safety statutes and, specifically, follow the risk based labeling option specified under Annex 5 of the GHS when it implements the system.9

References:

1. A. Venema, M. Trommelen, and S. Akerboom. 1997. "Effectiveness of labelling of household chemicals," Consumer Safety Institute, Amsterdam.

2. Leen Petre. 1994. "Safety information on dangerou

s products: consumer assessment," COFACE, Brussels, Belgium.

3. European Commission. 1999. DGIII Study on Comprehensibility of labels based on Directive 88/379/EEC on Dangerous Preparations.

4. Magat, W.A., W.K. Viscusi, and J. Huber, 1988. "Consumer processing of hazard warning information," Journal of Risk and Uncertainty, 1, 201-232.

5. Abt Associates, Inc. 1999. "Consumer Labelling Initiative: Phase II Report," Cambridge, Massachusetts, Prepared for US EPA.

6. Viscusi, W.K. 1991. "Toward a proper role for hazard warnings in products liability cases," Journal of Products Liability, 13, 139-163.

7. US Consumer Product Safety Commission. 2001. Code of Federal Regulations, Subchapter C – Federal Hazardous Substances Act Regulations, 16, Part 1500.

8. IOMC Description and Further Clarification of the Anticipated Application of the Globally Harmonized System (GHS), IFCS/ISG3/98.32B.

9. US Consumer Product Safety Commission. 2006. Policy of the U.S. Consumer Product Safety Commission on the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).


Documents:

Implementation of the Globally Harmonized System (GHS) for Chemical Hazard Classification and Labeling, SDA/CSPA letter to Honorable Hal Stratton, Chairman, Consumer Product Safety Commission, July 15, 2005

Amendment of Federal Hazardous Substance Act Regulations to Implement the Globally Harmonized System (GHS) for Chemical Hazard Classification and Labeling for Consumer Products, SDA/CSPA letter to Honorable Nancy A. Nord, Acting Chairman, Consumer Product Safety Commission, September 28, 2006

Amendment of Federal Hazardous Substance Act Regulations to Implement the Globally Harmonized System (GHS) for Chemical Hazard Classification and Labeling for Consumer Products, SDA/CSPA letter to Honorable Nancy A. Nord, Acting Chairman, Consumer Product Safety Commission, September 28, 2006 Attachment