|Hazard Communication Definitions|
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Caveat: I've made the following information as useful and accurate as I can... but I won't be held responsible for your actions or inactions. YOU need to know the regulations which apply to you and the resources that you have available; use what I give you as a starting point. I've used my free time to create this page, and I'm offering it freely - remember that what you get may be worth what you paid for.
Hazard Communication DefinitionsThis page does not contain in-depth definitions. For such detailed information, consult the regulating agency. Instead, this page explores how several different definitions inter-relate between agencies and countries.
- Canadian and United States Agencies and Terms
- Anomalies and Oddities
- Flammable / Ignitable Definitions
- US OSHA Physical and Chemical Hazard Definitions
- US EPA RCRA Waste Codes (also appears on main HazCom page)
- Shipping Papers (also appears on main HazCom page)
Agencies and TermsThe following table describes several relationships.
|Worker Safety (Canada)||Health Canada||
|Worker Safety (US)||US Department of Labor's Occupational Safety & Health Administration (OSHA)||
|Public Health & the Environment (Canada)||Environment Canada||
|Public Health & the Environment (US)||US Environmental Protection Agency (US EPA)||
|Transportation Safety (Canada)||Transport Canada||
|Transportation Safety (US)||Department of Transportation's Research & Special Projects Administration (US DOT RSPA)||
Anomalies and Oddities
To Waste or Not To Waste?I am always intrigued by the anomalies that different agencies introduce with their regulations. For example, certain types of Polychlorinated biphenyl (PCB) waste are shipped as " Waste Polychlorinated Biphenyls, Class 9.1, UN 2315, PG II" under Canada's Transport of Dangerous Goods (TDG) regulations, but as " Polychlorinated Biphenyls, Class 9, UN 2315, PG III" under the US HazMat regulations. In other words, PCB wastes are "Waste PCBs" in Canada but not in the US. This is because in the US "Waste" only applies to wastes regulated by the US Resource Conservation and Recovery Act (RCRA), and both PCB and asbestos wastes are regulated by the US Toxic Substance Control Act (TSCA).
Is It a Label, or Isn't It?Within the United States the US EPA and US DOT have agreed that the hazmat class markings used for non-bulk containers are "labels," and that other information is "markings". On a drum of waste acetone, for example, the Flammable liquid, Class 3" red diamond is a label, while the US EPA hazardous waste sticker is a marking. US OSHA, on the other hand, has made no such agreement. As a result US OSHA gladly refers to many types of safety markings as "labels" (29 CFR 1910.145 ).
Should I Pack pH Paper?There are also several anomalies with corrosive liquids. When strongly caustic sodium hydroxide waste is shipped as a solid in the US, it is not "Waste Sodium Hydroxide." This is because RCRA wastes with the "corrosivity characteristic" must be aqueous (i.e., a liquid). Finally, unlike Canadian TDG regulations, the US EPA RCRA regulations, or the US OSHA hazard communication regulations, the US DOT HazMat regulations do not use pH as one of the definitions for determining if a material is a corrosive liquid (the other agencies classify acids with a pH below 2 and caustics with a pH above 12.5 as corrosive liquids).
Also, different agencies regulate different areas. "Flash point" - the minimum temperature at which a flammable liquid gives off enough vapor to be ignited by a spark or flame - is a common standard used in evaluating how flammable a liquid is. The Occupational Safety & Health Administration (OSHA) administers workplace safety in the US. The OSHA definition for flammable liquid matches the definition used by the National Fire Protection Association (NFPA); an OSHA flammable liquid has a flashpoint of less than 100 degrees Fahrenheit, or 37.8 C. The US Department of Transportation (US DOT), on the other hand, regulates internal and international trade.The US DOT uses a flammable liquid definition that matches international treaties. A US DOT flammable liquid has a flashpoint of 141 degrees Fahrenheit or less. And the US EPA definition is different as well.
Border CrossingsInternational differences make their way into the picture as well. As noted above, the US DOT and US EPA regulate flammable/ignitable wastes slighlty differently (140 vs. 141 F). This doesn't happen in Canada; the Canadian equivalent of US RCRA hazardous waste / TSCA toxic waste is dangerous waste, and the definitions are based on Transport Canada's dangerous goods definition, which is the equivalent of the US DOT's hazardous materials. As a result there aren't the same differences in definitions between Canadian dangerous wastes and dangerous goods as there are between US hazardous wastes and hazardous materials.
Hazardous, Dangerous, and Special WastesOn the other hand US states cannot supplement the US DOT HazMat regulations, but Canadian provinces can supplement the TDGR. For example, British Columbia adds "special wastes" which are regulated by the BC Special Waste Regulations but may not be regulated by TDGR. Alberta just adds in its own list of regulated TDG substances. And Ontario's Regulation 347 licenses who is allowed to ship dangerous wastes to Ontario by generator. (while states and provinces require large waste generators to register for permit numbers, Ontario uses a more complex table of which wastes can be shipped where.)
Breathing Easy - OxygenA similar thing happens in workplace safety; the US OSHA defines oxygen concentrations of less than 19.5% to be oxygen deficient. Most provinces where I've lived or at which I looked used less than 18% oxygen as oxygen deficient (Alberta is a special case; they use concentration as an absolute pressure).
|US EPA||Ignitable hazardous wastes have a flashpoint of not more than 140 degrees Fahrenheit (60 C; see US 40 CFR 261.21).|
|Transport Canada, US DOT*||Flammable liquids have a flashpoint of not more than 141 degrees Fahrenheit (60.5-61 C; see Canadian TDG Part 3.12(1) and US 49 CFR 173.120).|
|US OSHA*; also NFPA||Flammable liquids have a flashpoint below 100 degrees Fahrenheit (37.8 C; see US 29 CFR 1910.1200).|
|*US DOT, US OSHA, and NFPA definitions include "combustible liquids," which have flashpoints above those of flammable liquids, but below 200 degrees Fahrenheit (93.3 C).|
US OSHA Hazardous Chemical DefinitionThe United States Occupational Safety and Health Administration has a detailed list of definitions in the Hazard Communication standard. One area wher I have noticed some confusion concerns physical hazard and chemical hazard. I have worked with more than one industrial hygienist who thought that a "physical hazard" meant a mechanical or sonic hazard.
According to 29 CFR 1910.1200, "Hazardous chemical" means any chemical which is a physical hazard or a health hazard.
These definitions are also from the US Hazard Communication standard:
" Physical hazard" means a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive.
" Health hazard" means a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term "health hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.
RCRA Waste Codes Waste Code Description D001 Ignitable Waste. Waste has a flash point below 140 F (60C), or is an oxidizer that will ignite flammable materials. D002 Corrosive Waste. Waste either corrode metal or has a pH below 2 (acid wastes) or above 12.5 (caustic, alkaline, or basic wastes). Unlike WHMIS, OSHA, Canadian TDG and US DOT HMR definitions for corrosives, wastes must be liquids to have the corrosivity characteristic. D003 Reactive Waste. Waste may undergo violent changes, react with water or other wastes, generate toxic gases, vapors, or fumes. Cyanide or sulfide wastes that may generate toxic gases at pHs between 2 and 12.5 fall into this category. D004 - D043 Specific wastes listed for their toxicity (e.g., D008, lead). F-listed wastes Wastes from generic sources, such as spent chlorinated or halogenated solvents. K-listed wastes Wastes from specific sources (e.g., K051, API separator sludge from the petroleum refining industry). P-listed wastes Commercial chemical products, containers, or spill residue with unspent waste with acute (short term) toxicity (e.g., P098, Potassium cyanide. U-listed wastes Commercial chemical products, containers, or spill residue with unspent waste with chronic (long term) toxicity (e.g., U151, Mercury.
|MODE||SHIPPING PAPERS||Responsible Party|
|Highway||Bill of Lading (non-wastes/non-reg wastes) / Dangerous Goods Waste Manifest / US Uniform Hazardous Waste Manifest (dangerous / hazardous wastes)||Vehicle driver|
|Rail||Rail Bill of Lading / Waybill||Crew|
|Water||Dangerous Cargo Manifest||Captain|
|Air||Air Bill with Shipper's Certification for Restricted Articles||Pilot|
If you need more information, I recommend that you try the following sources:
|Hazard Communication||Joint N. America Effort||Canadian Agencies||USA Agencies||Mexican Agencies||Private Sector Organizations||HazMat Page|