Chemical Hazard Classes with GHS
Elements of GHS
The Globally Harmonized System (GHS) does not require any changes in the scope of hazards covered by EPA’s existing label requirements. EPA’s initial approach, as outlined in its 2004 White Paper (PDF) (17pp, 88K, about PDF), generally focused on adoption of those hazard classes and categories defined in the GHS for which EPA now requires hazard classification and labeling under the current pesticide program regulations. Specifically, these hazards include:
- Physical hazards, such as flammability
- Health hazards: Acute toxicity/lethality (based on LD50 or LC50 values for dermal, oral, and inhalation routes of exposure), skin sensitization, skin corrosion/irritation, serious (permanent) eye damage/irritation
- Acute aquatic toxicity
To be consistent with GHS, EPA would need to adopt the GHS criteria and label elements for each hazard class and category that EPA requires to be on the label. It would not be necessary to expand the scope of current labeling to include additional hazard classes that are also included in the GHS, such as chronic health effects. EPA requires data and regulates to mitigate the risks of chronic health effects but does not generally require hazard labeling for these effects on pesticide labels.