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

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow.

Steven Erlandson

Environmental Coordinator

The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun.

Teresa Arellanes

EHS Manager

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.

John Troy

Environmental Specialist

Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.

George Alva

Manufacturing Manager

Download Our Latest Whitepaper

Your hazmat paperwork is the first thing a DOT inspector will ask for during an inspection. From hazmat training records to special permits, make sure your hazmat documents are in order.

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.