Comment on “GoodWeave Certification Standard First Stage draft v.2.5.1”

William S. Carter, Ph. D. CIH

 

1.) Section B3a “All practices should conform at a minimum to all ILO Standards and national laws and regulations

2.) There should be a definition of hazardous chemical. It is recommended : The definition of hazardous chemicals be consistent with The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) established by the United Nations- ILO

The GHS covers all hazardous chemicals. There are no complete exemptions from the scope of the GHS for a particular type of chemical or product. The term “chemical” is used broadly to include substances, products, mixtures, preparations, or any other terms that may be used by existing systems. The goal of the GHS is to identify the intrinsic hazards of chemical substances and mixtures and to convey hazard information about these hazards. The GHS is not intended to harmonize risk assessment procedures or risk management decisions, as described above.

What are the GHS Physical Hazards?
The GHS physical hazards criteria, developed by the ILO and UNCETDG, were largely based on the existing criteria used by the UN Model Regulation on the Transport of Dangerous Goods. Therefore, many of the criteria are already being used on a worldwide basis. However, some additions and changes were necessary since the scope of the GHS includes all target audiences. The physical hazards classification process provides specific references to approved test methods and criteria for classification. The GHS physical hazard criteria apply to mixtures. It is assumed that mixtures will be tested for physical hazards.
In general, the GHS criteria for physical hazards are quantitative or semi-quantitative with multiple hazard levels within an endpoint. This is different from several of the existing systems that currently have qualitative criteria for various physical hazards (e.g., organic peroxide criteria under WHMIS and OSHA HCS). This could make classification under the GHS more consistent.
In developing GHS criteria for physical hazards it was necessary to define physical states. In the GHS,
 a gas is a substance or mixture which at 50°C has a vapor pressure greater than 300 kPa; or is completely gaseous at 20°C and a standard pressure of 101.3 kPa.
 a liquid is a substance or mixture that is not a gas and which has a melting point or initial melting point of 20°C or less at standard pressure of 101.3 kPa.
 a solid is a substance or mixture that does not meet the definitions of a liquid or a gas.
The GHS physical hazards are briefly described below. For many of the physical hazards the GHS Document contains Guidance Sections with practical information to assist in applying the criteria.
Figure 3.2
Physical Hazard
 Explosives
 Flammable Gases
 Flammable Aerosols
 Oxidizing Gases
 Gases Under Pressure
 Flammable Liquids
 Flammable Solids
 Self-Reactive Substances
 Pyrophoric Liquids
 Pyrophoric Solids
 Self-Heating Substances
 Substances which, in contact
with water emit flammable gases
 Oxidizing Liquids
 Oxidizing Solids
 Organic Peroxides
 Corrosive to Metals
What are the GHS Health and Environmental Hazards?
The GHS health and environmental hazard criteria represent a harmonized approach for existing classification systems (see Figure 3.3). The work at the OECD to develop the GHS criteria included:
 A thorough analysis of existing classification systems, including the scientific basis for a system and its criteria, its rationale and an explanation of the mode of use;
 A proposal for harmonized criteria for each category. For some categories the harmonized approach was easy to develop because the existing systems had similar approaches. In cases where the approach was different, a compromise consensus proposal was developed.
 Health and environmental criteria were established for substances and mixtures.
Figure 3.3
Health Hazard
 Acute Toxicity
 Skin Corrosion/Irritation
 Serious Eye Damage/Eye Irritation
 Respiratory or Skin Sensitization
 Germ Cell Mutagenicity
 Carcinogenicity
 Reproductive Toxicology
 Target Organ Systemic Toxicity – Single Exposure
 Target Organ Systemic Toxicity – Repeated Exposure
 Aspiration Toxicity
Environmental Hazard
 Hazardous to the Aquatic Environment
o Acute aquatic toxicity
o Chronic aquatic toxicity
o Bioaccumulation potential
o Rapid degradability

3.) Reference should be made to “Safety Data Sheets” consistent with The Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This tem should replace any reference in the guidelines to Material Safety Data Sheet since that is not an obsolete term.