Search

GHS: Hazards Not Otherwise Classified

Posted on 10/2/2012 by James Griffin

Q. Is there any specific definition for “Hazards Not Otherwise Classified” under the new GHS rule? Also, what rules apply to them?
 
A. With the incorporation of the Globally Harmonized System (GHS) into the Occupational Safety and Health Administration’s (OSHA’s) regulations, companies are faced with revisiting established classifications of their hazardous chemicals.
 
According to OSHA’s Hazard Communication (HazCom) Standard, employers must identify all hazardous chemicals in the workplace and communicate the hazards of these chemicals to employees. While the GHS revisions added criteria for a few new hazards (asphyxiants, pyrophoric gases, combustible dusts, etc.), they did not remove any of the old physical and health hazards (explosives, flammable liquids, oxidizers, poisons, corrosives, carcinogens) from the standard.
 
One of the more confusing new categories is referred to as “Hazards Not Otherwise Classified” (HNOC). This category exists to catch workplace hazards that have not yet been defined in the regulations. Under OSHA’s reasoning, employers still have an obligation to protect employees from hazardous chemicals, even when the chemical doesn’t fit in an officially defined hazard classification.
 
OSHA’s definition of Hazards Not Otherwise Classified (HNOCs):
“Hazard not otherwise classified (HNOC) means an adverse physical or health effect identified through evaluation of scientific evidence during the classification process that does not meet the specified criteria for the physical and health hazard classes addressed in this section.” [1910.1200(c)]
If scientific evidence has proven that something has a physical or health hazard, you need to identify the chemical and cover it in your HazCom program. This does make some sense, because OSHA cannot possibly identify every dangerous hazard in the workplace. The rule acts as a way to still pull in chemicals that OSHA did not think of. It’s a specific case of the General Duty Clause [29 U.S.C. § 654, 5(a)] as applied to the HazCom Standard.
 
One other important aspect of HNOCs is also pointed out in the latter part of its definition:
“This does not extend coverage to adverse physical and health effects for which there is a hazard class addressed in this section, but the effect either falls below the cut-off value/concentration limit of the hazard class or is under a GHS hazard category that has not been adopted by OSHA (e.g., acute toxicity Category 5).”
In essence, OSHA is forbidding businesses from overregulating hazards that they have already identified as hazardous. For instance, flammable liquids are defined as any liquids with a flash point less than 200°F. If a business had a chemical with a flash point of, say, 230°F, employers would not be able to call it “flammable” just to be safe.
 
OSHA has not yet identified any specific HNOCs. However, if a company finds that one of its products meets the definition of an HNOC, then they must communicate that hazard to their employees. This will be done through additional training for employees, and the hazards must be addressed on Safety Data Sheets (SDSs). However, HNOCs do not have to be labeled, as none of the extant labels would apply. [29 CFR 1910.1200(f)(1)]
 
 
How are you preparing your facility and personnel for OSHA’s GHS rule? Share your comments.

Tags: GHS, HazCom, osha

Find a Post

Compliance Archives

Lion - Quotes

I will never go anywhere, but to Lion Technology.

Dawn Swofford

EHS Technician

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

This is the best RCRA training I've experienced! I will be visiting Lion training again.

Cynthia L. Logsdon

Principal Environmental Engineer

The instructor was very patient and engaging - willing to answer and help explain subject matter.

Misty Filipp

Material Control Superintendent

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right.

Gregory Thompson

Environmental, Health & Safety Regional Manager

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.

Timothy Mertes

Hazmat Shipping Professional

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!

Lori Hardy

Process & Resource Administrator

Download Our Latest Whitepaper

Decrease spill, release, and injury risk and increase savings with these "source reduction" strategies to prevent unused chemicals from becoming regulated as hazardous waste.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.