FREQUENTLY ASKED QUESTIONS
What has changed from Rev 8 of the UN GHS to Rev 9 of 2021
Section 2.1 Revised
Revision 9 of GHS now encompasses 2 categories for explosive substances, mixtures and articles, with category 2 divided into 3 sub-categories.
Updated decision logics and summary tables incorporating above changes.
Hazard Statements
H200: deleted
H201: deleted
H202: deleted
H203: deleted
H205: deleted
H209: added: Explosive
H210: added: Very Sensitive
H211: added: May be sensitive
Precautionary statements:
P210, P222, P234, P240, P250, P280, P370, P372, P373, P375, P380: Revised hazard references regarding Explosives section 2.1 and Flammable gas
P230: Renamed from “Keep wetted…” to “Keep diluted…”
P236: added: “Keep only in the original packaging. Division…in the transport configuration.”
P264: revised: Applicable now to Serious Eye damage, Cat 1.
P265: added: “Do not touch eyes”
P377, P381: revised: Scope clarified
P264+P265: added: “Wash Hands [and…] thoroughly after handling. Do not touch eyes”.
Appendix:
Table A1.17 updated: Includes UN-Model pictograms
Updates to EU SDS Regulation
On 25 Jun 2020, the European Commission published Regulation (EU) 2020/878 amending the annex II of REACH regulation. The annex II of REACH regulation sets the content and format requirements for chemical safety data sheets in the EU.
The new regulation comes into force on 1 Jan 2021. Existing SDSs can be used until 31 December 2022.
Section 1
Europe has implemented a poison control regulation which requires each formula to have a “Unique Formula Identifier” or UFI. The UFI code must be included in Section 1 of the SDS for your product.
If the product pertains to one or more nanoforms, the product description in Section 1 must contain the word “nanoform”.
Section 1.2 must now contain “relevant identified uses of the substance or mixture and uses advised against”.
Section 2
The new regulations require that any endocrine disruptors (in accordance with Article 59(1)) that appear in the product at 0.1% and above are listed in Section 2.3 of the product’s SDS.
Section 3
Endocrine disruptors at 0.1% must also be included in Section 3
In Section 3, make note of any nanoforms, and extra data needs to be disclosed in section 9 and 12 and display the M Factors, cut offs and ATE values that are listed in the regulation’s Part 3 of Annex VI to Regulation (EC) No 1272/2008.
Additionally, several new classifications of generic cut-off values are introduced in the updated SDS requirements. Any chemical with one of these classifications that are below the cut off must appear in section 3.
Refer to the table below for the list of the cut-offs that are unique to the EU or have changed due to the update. NOTE: this does not change the classification cut-offs, just those for inclusion in section 3.
|
GHS Classification |
Old Cut-off % |
New Cut-off % |
|
Acute Toxicity Cat. 1-3 |
0.1 |
0.1 |
|
Respiratory sensitiser |
||
|
category 1 or category 1B |
1 |
0.1 |
|
category 1A |
1 |
0.01 |
|
Skin sensitiser |
||
|
category 1 or category 1B |
1 |
0.1 |
|
category 1A |
1 |
0.01 |
|
Carcinogenicity Category 2 |
1 |
0.1 |
|
Reproductive toxicity, |
||
|
category 1A, 1B, & lactation |
0.3 |
0.1 |
|
category 2 |
3 |
0.1 |
|
Specific Target Organ Toxicant |
||
|
category 1 |
1 |
1 |
|
category 2 |
10 |
1 |
|
category 3 |
20 |
1 |
|
Aspiration toxicity Cat. 1 |
10 |
1 |
|
Hazardous to Aquatic Environment |
0.1 |
0.1 |
|
Acute Category 1 |
0.1 |
0.1 |
|
Chronic Category 1 |
0.1 |
0.1 |
|
Hazardous for the ozone layer |
0.1 (EUH059) |
0.1 (H420) |
Section 9
Appearance has been split into two categories: Physical State and Colour.
Definition for specific properties updated.
Section 9.2.1 now must contain information regarding physical hazards (such as explosive properties or metals that are corroded by the substance or mixture).
Section 9.2.2 also must contain other safety characteristics such as mechanical sensitivity or conductivity properties.
Section 11
Section 11.1 should now be titled “Information on hazard classes as defined in Regulation (EC) No 1272/2008”.
In a new sub section, 11.2.1, endocrine disrupting properties must be included.
Section 12
Section 12.6 is now “Endocrine disrupting properties”, and Section 12.7 is now “Other adverse effects”.
Does SANS10234 classification provide clarity over landfill requirements?
Disposal of waste to Landfill requirements are governed by The National Norms and Standards for the Assessment of Waste to Landfill Disposal No R635: 2013 and No R636: 2013 of NEM:WA. These Norms and Standards describe the identification of chemical substances present in the waste as well as provide sampling and analysis procedures to determine the chemical substances’ total concentrations and leachable concentrations. Based on the tables contained in the se Norms and Standards, regulating the extent of these concentrations, waste streams will be allocated into different types of waste, ranging from Type 0to Type 4. Whilst Type 0 wastes may not be disposed to landfill, the Norms and Standards provide for allocation of the remaining waste types to different landfill classes, based on their containment barrier construction.
