North America specifics

United States of America

Rules - all the North American rules can be run at the same time using a grouping.

• GHS US: there are mainly 3 differences in the US GHS rule compared to the other GHS:
  • OSHA has adopted 3 additional hazards that are mandatory to appear if applicable: Combustible dust, Simple Asphyxiant and Pyrophoric gas;
  • OSHA has not published a list of official supplemental hazards (equivalent to the EUH statements in Europe). However it is encouraged to include on the SDS and label in the section 2.3 any "Other hazards that do not result in classification", or "HNOC" ( Hazards Not Otherwise Classified ). It is possible to customize the rule to populate some of them automatically based on phrases maintained in section 9, 11 or 12.
• GHS_US Environment:
  • as OSHA has not adopted the environmental portion of the GHS, the environment H-statements should not appear as part of the mandatory classification and labeling. However, Solvay  (to modify) as a group decided to voluntarily show these H-statements on the SDS and label in the section 2.3 "Other hazards that do not result in classification". They are based on the UN classification. Only the percentage of unknown acute toxicity is displayed (unknown acute ecotoxicity not shown).

  • Automatic notification statement in the beginning of section 2 from template shown on SDS: "Although OSHA has not adopted the environmental portion of the GHS regulations, this document may include information on environmental effects."

• Hazard Comp US:
  • The rule reports in section 3 : OSHA GHS classified ingredients above their regulatory threshold, ingredients listed as carcinogens by OSHA, IARC, ACGIH, NTP if above 0.1% and ingredients with OEL and BEI according to OSHA, ACGIH, NIOSH , Solvay (to modify) if above 1%.
  • The rule reports in section 8 : ingredients with OEL according to OSHA, ACGIH, NIOSH, Solvay (to modify) if above 1%
• RegInfo NA:
  • The rule reports in section 11 (Carcinogenicity section): ingredients listed as carcinogens, reproductive toxicity, mutagens (class 1), skin or respiratory sensitization (class 1, 1A and 1B) by OSHA, IARC, ACGIH, NTP if above 0.1%
  • The rule reports in section 15: ingredients listed on the California Proposition 65 carcinogen and reproductive toxicity lists, regardless of components concentration in product. The rule does not output any concentration together with the ingredient. However it may be added manually by the SDS writer (exact value or range), in this case the unit (% or ppm) must be maintained.
• Sara comp: the rule writes back components that are listed on SARA 313 chemicals and/or SARA 302 Extremely Hazardous Substances .
• SARA classification: this rule populates the SARA hazard categories based on GHS US classification.
• Spill reporting: the rule writes back components that are listed on:
  • the EPA Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA);
  • SARA 302;
  • Section 304 Reportable Quantities;
  • We do only show in the SDS the RQ at the pure substance level, we do not apply any de minimis.
• Clean Water Act (for information only, result not mapped on the SDS);
• Clean Air Act (for information only, result not mapped on the SDS). This outputs information in 2 classes: Clean Air Act (US) and VOC;
• US State RTK (for information for the Massachusetts and Pennsylvania listings, only the NJ RTK listings may be mapped on the SDS).

Canada

Rules:

• GHS_CA - this is mostly aligned with GHS US , with some exceptions.

• • Also note: a sensitizer classification 1A or 1B may be derived for a mixture directly from the ingredients, while in other countries, it could only be based on product's data (defaulting to cat 1 otherwise).
• GHS US Environment - like in the US, voluntary disclosure of environmental information in section 2.3 and label.

  • Automatic notification statement in the beginning of section 2 from template shown on SDS: "Although WHMIS has not adopted the environmental portion of the GHS regulations, this document may include information on environmental effects."

• Hazard_Comp_US - it was decided to use the output of the US hazard comp rule for Canada as well (the validity area of this output was changed to "Z_NA" to fit this need).

  • The template then filters out the regulatory lists relevant for Canada: only ACGIH, IARC and Solvay  (to modify) for the carcinogen and OEL listings;

• CA PBT (for information only, result not mapped on the SDS).

Other Sections

• Section 1: It is mandatory to indicate in this section:
  • • Name and phone number of the group, department or party responsible for the preparation of the material safety data sheet. This is managed inside the address master.
    • Date of preparation of the material safety data sheet. This is added automatically by the template (same as issue date).

• Section 2:

  • • Since the template is not in the GHS format, the classification is expressed via phrases maintained in the class "Possible Hazards (Summary)", "Signal word" and "Remarks" and then by route of exposure. Warning: a program controls the punctuation of this section. To have phrases displayed as a list (go to the next line and start with a dash for the next phrase), this has to be maintained as 1 value per instance.
• Section 3: Same comments as US.

• Section 5: Some physical properties important to fire-fighters are duplicated here from the section 9 (Flash Point, Auto-ignition temperature and explosive properties).

• Section 8:

  • • Environmental precautions are not displayed.
    • The template also brings, when available, and only if the ingredient is listed as an OEL ingredient in Section 8: the ACGIH BEI (located in Section 8 > International > BEI in the PURE SUB property tree).

• Section 14:

  • • Reportable Quantities, Marine pollutant ingredients, Toxic by Inhalation Hazard, Combustible liquid may be mentioned if applicable. They are managed by the DG Administrator.

• Section 15:

  • • Other regulatory information may be added manually in the classes "Prohibitions and Restrictions" or "Information About Other Regulations".

• Section 16:

  • • HMIS a nd NFPA classifications may be added manually by the SDS writer, same priorities as for US.
      
    • The legend has 2 parts: a dynamic part that collects the acronyms present in section 8 (value types of the OEL values) and a fixed part.