The Ultimate GHS Hazard Classification Guide - ERA Software Solutions

About This Guide
The goal of this guide is to give you the guidelines and best practices your
organization needs to properly classify the chemical hazards associated with your
products so that you can author accurate Safety Data Sheets (SDS) in accordance with
the Globally Harmonized System (GHS).
By reading this guide you’ll learn:
✓ The step-by-step process for classifying a chemical hazard

✓ The logic behind GHS categories and classes
✓ How hazard and precautionary statements are used for SDSs and Labels
✓ The most effective way to become GHS compliant
✓ How to ensure your SDSs are accurate and reliable
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www.era-environmental.com | info@era-ehs.com
Contents
Executive Summary ........................................................................................................ 3
The Step-by-Step Process for Classifying Hazards ........................................................ 5
Understanding GHS Hazard Classifications: Classes & Categories ............................... 8
Hazard Classes and Their Applicable Categories ........................................................ 10
Essential Step: UNECE Classification Summary table ................................................. 13
Classification of Mixtures .............................................................................................. 14
How to Communicate Hazards: Hazard Statements ................................................... 16
How to Verify Chemical Data ........................................................................................ 20
Resolving Conflicting Data Case Study ........................................................................ 22
The Most Effective Way to Classify Hazards ................................................................. 28
About ERA Environmental Management Solutions ..................................................... 31

Executive Summary
The Globally Harmonized System (GHS) for Safety Data Sheets (SDSs) and Labels has
rolled out profound changes to how your business needs to classify and communicate
chemical hazards to your clients and work force. The radical overhaul introduced by
the GHS standards means your business has new obligations and will need new
approaches to compliance.
OSHA committed to adopting the United Nation’s GHS Standards for chemical hazard
communication for 2015. Today, North American chemical manufacturers, importers,
and distributors are required to be authoring compliant GHS SDSs. The GHS is
outlined in a free regulatory document known as “The Purple Book” which you should
use in tandem with this guide.
Resource Guide
This guide gives you a simplified walk through of GHS hazard classification and
references other regulatory documents. In addition to this guide you should
familiarize yourself with these resources (click to read):
• The UN “Purple Book”

• The OSHA implementation of GHS, known as Hazard Communication 2012
• If you do business in, or ship chemical goods to Canada, read the Canadian
Hazardous Products Regulation (HPR) guidelines

•
Step-by-Step Process for

Classifying Hazards
The goal of SDS Authoring is to provide your staff, clients, and any other product users
with important information about the hazards associated with your products.
That’s why it’s paramount that you have a clear and repeatable methodology for
classifying your chemical hazards. The GHS and OSHA outline this methodology, but it
is not always so simple to implement.
This chapter explains:
• Steps to properly classify a hazard

• How to understand hazard classes and categories
• How to classify chemical mixtures

The Step-by-Step Process
for Classifying Hazards
Under the GHS, hazards are subdivided into class and
category. There are 3 major classes: health hazards,
physical hazards, and environmental hazards. Each of
these 3 major classes are subdivided into hazard classes and categories, each one with
specific hazard statements. A material can have several hazard categories and classes.
For example, it’s possible for a single material to be flammable, an eye irritant, and
acutely toxic.
It’s your job to figure out what classes and categories are applicable to your
products.
Currently, the OSHA and WHMIS implementation of the GHS only has jurisdiction over
the classification of physical hazards and health hazards. For environmental
hazards, we recommend that you use the default GHS classifications.
The goal of classifying your product hazards is to determine which Hazard Statements
need to be displayed in Section 2 of your SDS. We’ll go into more explanation about
Hazard Statements in the next chapter of this guide… but first you need to follow
the GHS step-by-step classification process on the next page.

Steps to classify a hazard:

We recommend printing the infographic on the previous page or saving the image
where you can easily reference it.
Ultimately, classifying your material comes down to:
1. Knowing the exact chemical makeup of your material

2. Applying the Purple Book’s guidelines to each chemical to first determine
class
3. Then use the Purple Book to determine category
Compliance Alert
You are not required to test chemicals for the purpose of hazard classification.
A key benefit of adopting the GHS is to reduce the burden of testing and evaluating
chemical information. Instead, consult scientific literature to assess whether your
material meets the OSHA and WHMIS definition of a hazardous chemical. For
example, the EPA’s chemical databases or the ECHA’s C&L library can be used in
place of in-house lab testing.

Understanding GHS Hazard
Classifications: Classes & Categories
GHS uses three hazard classes: Health hazards, Physical hazards and Environmental
hazards:
Health Hazards Physical Hazards Environmental Hazards
• 10 hazards • 16 hazards • Not covered by OSHA

• Dangers to human • Dangers to the body or WHMIS jurisdiction.
health • Apply OSHA/WHMIS • Apply United Nations
• Apply OSHA/WHMIS guidelines generic guidelines.
guidelines • Example: skin • Example: aquatic
• Example: respiratory corrosion toxicity
damage
Health hazards present dangers to human health (i.e. breathing or vision) while
physical hazards cause damage to the body (like skin corrosion). There are 16
physical hazards and 10 health hazards: each hazard is then further divided according
to different severity levels. Environmental hazards refer to acute and chronic aquatic
toxicity; however, environmental hazards do not fall under OSHA/WHMIS jurisdiction
under the current implementation. Accordingly, all environmental hazard
classifications should be done following the UN’s GHS guidelines.

How to know which classes to use
Hazard classes are determined by the regulatory body overseeing workplace safety for
your country. In the United States this body is OSHA. OSHA has aligned its SDS
regulations with the GHS through a standard known as Hazard Communication 2012 –
known as HazCom 2012 for short. In Canada, the GHS has been implemented
nationally through a regulation known as WHMIS – Workplace Hazardous Materials
Information System.
American chemical manufacturers, importers, and distributors are required to classify

their chemicals using the updated HazCom 2012 standards. HazCom 2012 provides
you with specific criteria to identify and classify physical hazards, health hazards
of chemical mixtures.
Compliance Alert
HazCom 2012 categories use a 1-4 rating system for hazard severity
similar to HMIS/NFPA rating but with a critical difference. GHS ranks 4 as the
least severe whereas NFPA ranks 4 as the most severe. To avoid confusion,
NFPA and OSHA have worked to produce an online “quick card” reference
document [external link]. We recommend you print or save this document for
your future reference.

Hazard Classes and Their Applicable
Categories
The first step in the classification process is to know which class your materials falls
under. From there you can start identifying categories.
We’ve prepared simple reference tables for you to quickly narrow down which
categories need your attention for your materials based on classes you identified in
step 1. A single class can contain several categories. Once you know your class and
category per material, you can move on to assigning hazard statements,
precautionary statements, pictograms, and signal words (more on those in the next
chapter).
On the next two pages you will find the GHS class/category tables.

Physical Hazards
Hazard Class Associated Hazard Category
Divisions 1.1-1.6 (with 1.1 being the most
Explosives
hazardous, 1.6 the least hazardous)
Flammable gases Categories 1 and 2
Flammable aerosols Categories 1 and 2
Oxidizing gases Category 1
4 Groups include: Compressed gas, Liquefied

Gases under pressure
gas, Dissolved gas, and Refrigerated liquefied gas
Flammable liquids Categories 1 – 4
Flammable solids Categories 1 and 2
Self-reactive substances Types A-G
Pyrophoric solids Category 1
Pyrophoric liquids Category 1
Self-heating substances Categories 1 and 2
Substances which in contact

with water emit flammable Categories 1 – 3
gases
Oxidizing liquids Categories 1 – 3
Oxidizing solids Categories 1 – 3
Organic peroxides Types A-G
Substances corrosive to metal Category 1

Health Hazards
Acute toxicity Categories 1-4 (with 1 being the most
dangerous)
Skin corrosion Categories 1A, 1B, 1C, and 2
Skin irritation Categories 1A, 1B, 1C, and 2
Eye Effects Categories 1, 2A, and 2B
Sensitization (Skin or Eye) Category 1A and 1B
Germ cell mutagenicity Categories 1A, 1B, and 2
Carcinogenicity Categories 1A, 1B, and 2
Reproductive toxicity Categories 1A, 1B, 2, and additional

category for effects on or via lactation
Target organ systemic toxicity: single Single: Categories 1-3

and repeated exposure Repeated: Categories 1 and 2
Aspiration toxicity Category 1 and 2
Environmental Hazards
Acute Aquatic Toxicity Categories 1 -3
Chronic Aquatic Toxicity Categories 1 – 4

Essential Step: UNECE Classification
Summary table
The above tables provide a simplified summary of the classification/category
relationships and is your starting point for classification. However, the United Nations
Economic Commission for Europe (UNECE) has compiled a comprehensive list of
classification and categories which you should use to verify your classifications after
the first pass. Access the most recent Annex 2 of GHS for free online here [external
link].
This document also includes decision flow charts and numerical limits/thresholds that
will be essential if you are required to author GHS-compliant SDSs and/or labels. It is
too in-depth to summarize nicely in this guide but is still important reading.
Don’t skip this step – make sure you reference the UNECE table in addition to this
guide.

Classification of Mixtures
During the process of classifying the hazards associated with your chemical products
you’ve likely come across chemical mixtures and might not know how to classify
them.
The GHS classifies mixtures using a tiered approach. To classify your mixtures,
you should use available testing data (or available literature testing data) for the
mixture itself alongside the GHS classification guidelines.
An exception to this is if your mixture is a carcinogen, a mutagen, or a reproductive

toxin where classification may be based on the strength of evidence and modified on
a case-by-case basis.
For untested mixtures the GHS suggests applying bridging principles with similar
tested mixtures or using the cut-off approach with the values described in the
specific end point. Bridging principles exist for Dilutions, Batching, Concentration of
Highly Toxic Mixtures, Interpolation within One Toxic Category, Substantially Similar
Mixtures and Aerosols.
More information about the GHS bridging principles and Mixture classification can be
found online here [External link].

How to Communicate
Hazards
The purpose of a Safety Data Sheet is to clearly communicate the hazards of your
products. Now that you’ve classified your hazards, it is time to share that data with
your users via a properly authored SDS.
This chapter explains how to communicate your chemical hazards using the correct
methods outlined by OSHA and the GHS:
• How to use Hazard Phrases

• Where to include Hazard Phrases
• What to communicate if your hazards are a special case (for example, not
classified under GHS standards but still important for users to know)

How to Communicate Hazards:
Hazard Statements
Once you have classified and categorized your substances and mixtures you will finally
be able to apply the correct Hazard Statements to your Safety Data Sheets and
Labels. GHS Hazard Statements were designed to replace OSHA R-Phrases and WHMIS
classifications. Using the appropriate regulatory guidelines for your country, match up
the class and category with the correct Hazard Statement.
Each Hazard Statement has a specific hazard code, although your SDSs and Labels
must include the entire statement and not simply the code number. This ensures
that anyone reading the document knows exactly what to expect without decoding.
Section A3.1.2.1 of the UNECE document explains hazard statements codification:
1. Each code begins with the Letter “H” for Hazard Statement
2. The first number designates the type of hazard:
2 = physical hazard
3 = health hazard
4 = environmental hazard
3. The second and third numbers refer to the intrinsic properties of the substance
4. Some hazard codes and statements can be combined/ conjoined using a “+”
which means “or” or "and"
For example, the hazard code H200 refers to an unstable explosive. It’s clear from the
first letter of the code, 2, that the explosive property of the material is a physical
hazard.

What if a Hazard is Not Classified under GHS?
Some hazards are not classified under GHS, but that doesn’t mean they can be
ignored. These types of hazards are divided into groups:
• Specific additional hazards

• Biohazards
• and “Hazard not otherwise classified” (HNOC)
Let’s go more in depth into these hazard types below.
Specific Additional Hazards

These hazards have their own unique requirements and generally are not associated
with specific GHS pictograms (with the exception of pyrophoric gases). Nevertheless,
they all must be included under Section 2 in the SDS and on the label as follows:
Pyrophoric Gases
• Signal word: Danger
• Pictogram: GHS Flame Pictogram
• Hazard statement: Catches fire spontaneously if exposed to air
Simple Asphyxiants
• Signal word - Warning
• Hazard statement - May displace oxygen and cause rapid suffocation
Combustible Dusts
• Signal word - Warning
• Hazard statement - May form combustible dust concentrations in the air

The “Hazards not otherwise classified” Category (HNOC)
Some materials may have hazards not classified by the Globally Harmonized System
that do not fit the “Specific Additional Hazards” category. If a chemical product
contains a Hazard Not Classified by the GHS (HNOC), it must be addressed in section 2
of the SDS and may or may not be included on the label under Supplemental
information.

How to Ensure SDS
Accuracy and Quality
As a chemical manufacturer or distributor, it is your responsibility to ensure the SDSs

you provide employees and clients are accurate and provide the right data to keep
them safe. That means you are liable for any errors in classification.
This chapter focuses on methodologies to ensure your SDS authoring is efficient and
reliable:
• How to effectively classify hazards using published and testing data

• How to resolve conflicts in classification data
• How to make your SDS authoring more reliable and repeatable

How to Verify Chemical Data
Reliability is crucial when you’re assessing information about
your chemicals and classifications so that you can author
GHS-compliance labels and SDSs. Using the wrong
information for the situation could result in an inaccurate and dangerous SDS.
The best method to ensure accuracy and reliability in any GHS-compliant material you
produce is to take a two-tiered approach: first have the most accurate raw chemical
data about your materials and, second, reference and compare multiple
regulatory resources before making any final determinations.
The GHS doesn’t require chemical manufacturers or distributors to test each and
every chemical and material that they ship or sell. Instead, you are allowed to use
industry publications that review lab testing data performed by others. But if you use
published testing data it is especially important to ensure the publication is credible.
The best sources are those sanctioned by or curated by an official government or
regulatory body. For example, the Environmental Protection Agency (EPA) collects
reliable data on chemical toxicity and environmental impacts.
Most importantly, always refer to the United Nations’ Purple Book, which is the official
guideline to GHS implementation. You can order a physical copy for your business
online, or read it for free online here:
http://www.unece.org/trans/danger/publi/ghs/ghs_rev03/03files_e.html

How many data sources is enough?
The key is balance: taking information from one regulatory list to make your
classifications leaves you vulnerable to incorrect assumptions… but consulting every
available list for each chemical will take days to author a single SDS.
ERA recommends that specialists authoring SDSs by hand consult around three to
five trustworthy sources and using those same sources each time (or as often as
possible).
When ERA authors SDSs using our GHS software, we reference at least 13 different
databases of chemical determinations, chemical testing data, and regulatory body
finds per chemical. We’re able to reference this many through our built-in Master
Chemical List. ERA also breaks each material down into its exact chemical
components so that SDSs have all the information they need.
Stopping at just one source of chemical information for any material when authoring
your SDSs and labels is bad practice, even if it’s from a source you generally trust, like
the Environmental Protection Agency.

Resolving Conflicting Data
Case Study
There is so much information available about the GHS
classification system that there’s debate about certain
chemicals even between regulators and experts. ERA Environmental Management
Solutions experienced this scenario firsthand when our team of experts went to work
researching how to properly classify materials containing sulfur.
Here’s a short case study to illustrate why using multiple chemical references is
important in any situation.
When using GHS standards to classify sulfur according to OSHA’s implementation you
can get different results than under other international regulatory bodies. Which
should you use? Which governing body is correct? Which offers the best protection
against harmful effects?
The Chemical: Sulfur

Sulfur is an abundant, multivalent non-metal. It occurs naturally as a pure element.
Today, most of elemental sulfur is produced as a by-product of removing
contaminants from natural gas and petroleum. The element is commercially used in
fertilizers and in the production of sulfuric acid.

The Problem
According to the Classification Labelling and Packaging (CLP) regulation, sulfur is
classified as Skin corrosion/irritation – Category 2. Upon further research, our expert
scientists found that sulfur could also be classified under Acute Toxicity Inhalation
Category 4, Acute Toxicity Dermal Category 5, and Acute Toxicity Oral 5 in addition to
its CLP classification.
Additional but less affirmative evidence also suggests that sulfur can be classified as
an Eye Irritant Category 2 and a Flammable Solid Category 2.
The Sigma- Aldrich SDS for Sulfur indicates that under OSHA and WHMIS, sulfur is
classified as a flammable solid Category 2. However, under the CLP, this
categorization is not specified. GHS classification criteria can be used to reclassify
chemicals on lists, if desired. Existing lists could be used in conjunction with the GHS
to promote harmonization, according to OSHA and WHMIS.
Even though the GHS Classification specifies that Category 2 skin irritants are not
necessarily eye irritants, this is subject to debate. Table 3.2.5 from the GHS Purple
Book shows that only category 1A, 1B and 1C are linked to eye damage because they
are corrosive. Though not specified in the GHS guidelines, it is certainly possible that a
chemical that causes a simple skin irritation can also cause an eye irritation.

There is some uncertainty with regards to the eye irritant potential and flammability
of sulfur. However, this case study draws attention to the fact that Hazard
classification is not always black and white. And sometimes, companies need to make
the most conservative judgment call based on the research available.
The Solution:
By researching multiple chemical and toxicological databases, including Sigma
Aldrich and RTECS, our scientists were able to gather and compare SDSs to see how
sulfur was classified. Additional GHS Classification information is presented below:

SIGMA ALDRICH:
RTECS database:
Acute toxicity, Inhalation (Category 4)

Decision tree from GHS Purple Book (Pg. 127)

Key Take-away:
Without proper cross-referencing, sulfur would have remained classified as a Category
2 Skin Irritant. While this is acceptable according to GHS, it does pose a risk to your
employees.
According to OSHA you must classify sulfur as a Category 2 Skin Irritant, but you
should also classify it as an eye irritant, a flammable solid, and with Acute Toxicity
Inhalation Category 4.
Researching multiple sources and authoring the most comprehensive SDSs and Labels
is important, but also requires a great deal of time and effort without a system in place
to be more efficient. ERA’s SDS authoring software system lets you author GHS
compliant SDSs and labels on the fly for any of your materials in just minutes - and it
instantly references multiple databases to ensure you get the most reliable and
comprehensive data possible. As this case study shows, we take getting you the best
information possible seriously.

The Most Effective Way to Classify
Hazards
The Globally Harmonized System offers manufacturers, importers, and distributors a
better way of understanding and communicating information about their materials.
However, this shift presents a challenge because the systems most businesses have in
place will need to be updated. Classifying a single material can require a great deal of
testing, research, and uses an unfamiliar set of thresholds and requirements.
When it comes to the Globally Harmonized System having information is power.

Information is what powers your ability to classify materials properly, author accurate
Safety Data Sheets (SDSs) and labels, train your staff how to understand chemical
hazards, and implement the GHS standards as efficiently as possible.
Raw chemical component information is the foundation of your SDSs and labels. If
you know which chemicals make up your materials, you have the essential building
blocks to classify your chemical hazards and assign proper precautionary statements.
If you get your materials from a vendor and need to author labels for containers you
use on site, take the extra step to ensure you are given reliable chemical component
data from your vendors. Ideally, you should collect all your data from vendors
electronically using a secure upload system to encourage higher quality data being
shared with you.

Many companies are looking for ways to automate this GHS classification process
using an electronic system that already has the GHS rules built in. GHS SDS/Label
authoring software can ease the transition by automatically classifying your materials
while you properly implement and master the GHS.
Finding tools for accurate & reliable authoring

Right now, businesses have a lot of options when it comes to SDS authoring.
Classifications can be done in-house, you can hire consultants to do your authoring for
you, or you can use a GHS software platform to author and manage your SDSs and
labels online.
Regardless of which option you choose, it is essential that you assess their
methodology for classifying material under the GHS standards:
• How many sources do they reference when making a determination?

• How do they measure the reliability of those sources?
• Is there a dedicated research team knowledgeable about the many sources of
information about the GHS?
Look for a solution that pulls data from multiple sources, as this is the best way to
guarantee accuracy in your SDSs and labels. Extensive library and testing research
should be done on each chemical component to ensure hazard classifications are
correct. Doing this in-house gives you complete control of how much research gets
done, but also requires a far greater time investment. Using a GHS software platform
like ERA’s allows your authoring to rapidly cross-reference multiple reliable sources,
producing an SDS or label in just minutes.

Conclusion
Congratulations, you’ve reached the end of the Ultimate GHS Hazard Guide from ERA
Environmental. By this point you should have a greater understanding of:
✓ The scientific step-by-step methodology for classifying hazards

✓ How to translate those hazards to your SDSs and labels
✓ How to best use chemical data sources effectively
✓ How to handle chemical classification conflicts
Thank you for downloading this GHS guide. If you have any questions about SDS
authoring, please contact ERA at info@era-ehs.com and one of our SDS specialists will
reach out to you.

About ERA Environmental
Management Solutions
ERA Environmental Management Solutions specializes in web-based SDS and EHS
management software for manufacturers, including chemical, automotive, and oil &
gas. ERA’s software combines more than 20 years of environmental compliance
expertise with cutting-edge technology to provide managers with the most accurate
environmental and chemical data. ERA’s authoring software specialists take pride in
their chemical research; with over 120,000 chemicals in its Master Chemical List, ERA
boasts thoroughly-researched and classified chemicals, as this is the best way to
guarantee accuracy in your SDSs and labels.
If you would like to find out more about ERA’s SDS Management Software solutions
and how they can help you manage your facilities more efficiently and with less
frustration, call us 1-438-799-6208 or visit www.era-environmental.com.
Disclaimer: All information contained in this fact sheet is accurate as of January 2019. ERA
accepts no liability for the content of this guidebook, or for the consequences of any
actions taken on the basis of the information provided. To ensure the accuracy of the
information provided, please contact your state or provincial regulator. For the most
recent version of this document, please contact ERA at 1-438-799-6208.


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About This Guide

By reading this guide you’ll learn:

✓ The step-by-step process for classifying a chemical hazard

Get more SDS Insights 1

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• The UN “Purple Book”

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Step-by-Step Process for

This chapter explains:

• Steps to properly classify a hazard

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Ultimately, classifying your material comes down to:

1. Knowing the exact chemical makeup of your material

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Health Hazards Physical Hazards Environmental Hazards

• 10 hazards • 16 hazards • Not covered by OSHA

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American chemical manufacturers, importers, and distributors are required to classify

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Flammable gases Categories 1 and 2

Flammable aerosols Categories 1 and 2

Oxidizing gases Category 1

4 Groups include: Compressed gas, Liquefied

Flammable liquids Categories 1 – 4

Flammable solids Categories 1 and 2

Self-reactive substances Types A-G

Pyrophoric solids Category 1

Pyrophoric liquids Category 1

Self-heating substances Categories 1 and 2

Substances which in contact

Oxidizing liquids Categories 1 – 3

Oxidizing solids Categories 1 – 3

Organic peroxides Types A-G

Substances corrosive to metal Category 1

Get more SDS Insights 11

Skin corrosion Categories 1A, 1B, 1C, and 2

Skin irritation Categories 1A, 1B, 1C, and 2

Eye Effects Categories 1, 2A, and 2B

Sensitization (Skin or Eye) Category 1A and 1B

Germ cell mutagenicity Categories 1A, 1B, and 2

Carcinogenicity Categories 1A, 1B, and 2

Reproductive toxicity Categories 1A, 1B, 2, and additional

Target organ systemic toxicity: single Single: Categories 1-3

Aspiration toxicity Category 1 and 2

Chronic Aquatic Toxicity Categories 1 – 4

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An exception to this is if your mixture is a carcinogen, a mutagen, or a reproductive

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• How to use Hazard Phrases

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Section A3.1.2.1 of the UNECE document explains hazard statements codification:

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• Specific additional hazards

Let’s go more in depth into these hazard types below.

Specific Additional Hazards

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As a chemical manufacturer or distributor, it is your responsibility to ensure the SDSs

• How to effectively classify hazards using published and testing data