What is the Overlap Between Chemical Regulations – TDG/DOT, NFPA 704, GHS, WHMIS, and HazCom?
February 28, 2022
If you manage or write Safety Data Sheets for products you manufacture, you may have wondered about the overlap between certain regulations. The link is in the classification. Let’s examine some commonalities between various regulations, including:
- Transportation of Dangerous Goods (TDG), Canada
- Globally Harmonized System of Classification and Labelling of Chemicals (GHS),
- The Workplace Hazardous Materials Information System (WHMIS) Canada
- The US Hazard Communication Standard (HazCom) US
- Department of Transport (DOT), US
- National Fire Protection Association (NFPA), US
UN Model Regulations for Transportation of Dangerous Goods
The United Nations has a long-standing classification system for Dangerous Goods in transport, called the UN Model Regulations. The UN Model Regulations cover all aspects of transportation necessary to provide international uniformity. They include a comprehensive criteria-based classification system for substances that pose a significant hazard in transportation.
Globally Harmonized System of Classification and Labelling of Chemicals (GHS)An internationally agreed-upon standard also managed by the United Nations that was set up to replace the assortment of hazardous material classification and labelling schemes previously used around the world.
Workplace Hazardous Materials Information System (WHMIS), the Hazardous Products Act (HPA), and the Transportation of Dangerous Goods (TDG)The Canadian Regulations that have adopted GHS and the UN Model Regulations, respectively.
Hazard Communication Standard (HazCom) and Department of Transportation (DOT)In the USA, HazCom and DOT regulations are equivalent to WHMIS and TDG
National Fire Protection Association (NFPA) Standard 704The NFPA was adopted in the 1960s to provide basic information for emergency personnel responding to a fire or spill and those planning for emergency response. In the workplace, the NFPA fire diamond has been replaced by GHS and the UN Model Regulations. You will still see it, however; at worksites that choose to train their employees on both NFPA and GHS, WHMIS, or HazCom standards.
Do each of these regulations require inclusion when authoring a Safety Data Sheet?
By design, GHS hazard classifications should align with TDG/DOT/IMDG/IATA classifications on a Safety Data Sheet. The purpose of the GHS is to ensure all chemicals produced or imported are classified and the information on physical and health hazards is communicated to employers and workers. This information is transmitted to workplaces by means of a comprehensive hazard communication program, which includes SDSs, container labeling, and training.
How do you accurately classify your chemical commodities to satisfy the regulations while being economically practical for your operations?
With GHS, there is a correlation to TDG/DOT packing group and the WHMIS/HazCom physical hazard class category. If the chemical has undergone classification for TDG/DOT regulations, the data from this classification can be used to meet the requirements for WHMIS/HazCom. In contrast, the hazard category numbers found in Section 2 of the GHS-compliant SDSs are NOT to be used to fill in the NFPA 704 diamond.
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