Does GHS Require Product Testing for Hazard Classification?

What is Involved in GHS Hazard Classification?  

GHS Hazard classification is the process of evaluating the full range of available scientific evidence to determine if a chemical is hazardous, as well as to identify the level of severity of the hazard. When complete, the evaluation identifies the hazard class(es) and associated GHS hazard category of the chemical.

Do I need to test my products to author a Safety Data Sheet?

Yes. When identifying a hazard classification for GHS the chemical manufacturer, importer, or employer is expected to conduct a thorough evaluation, examining the full range of available data, and producing a scientifically defensible evaluation of the chemical hazards. All potential physical or health hazards associated with a chemical’s use must be considered to author a safety data sheet.  

The GHS hazard classification process consists of four main steps: 

1. Selection of chemicals to evaluate. 
2. Collection of data. 
3. Analysis of the collected data using criteria provided in the Canadian Hazardous Products Act/US Hazard Communication Standard. 
4. Documentation of the hazard classification process and results obtained. 

Classification of material or hazardous substance needs to be evaluated with established scientific principles, with respect to the criteria and requirements of each category or subcategory of the hazard class, using available data of the following types, as applicable in relation to the material or substance itself.  

As for testing, GHS/WHMIS may or may not require testing of products for classification purposes. Chemical manufacturers and importers are required to evaluate the hazards of the chemicals they produce or import and prepare labels and safety data sheets to convey the physical and health hazard information to their downstream customers. The United Nations Economic Commission for Europe has a comprehensive list of classifications and categories that should be used to verify your classifications.  

The GHS Classification and Labelling Summary tables also includes decision flow charts and numerical limits/thresholds that are essential if you are required to author GHS-compliant SDSs and/or labels.  

Proof of Classification for Transportation 

If your product is being offered for transport as a dangerous good or hazardous material according to 49 CFR Part 172, your product can be classified according to the TDGR Schedule 1 or the Table of Hazardous Materials and Special Provisions, respectively.

For products that are variable in nature like Crude Oil, TDG regulations require proof of classification to ship dangerous goods on public roadways. There are also exemptions for consumer products and laboratory samples. 

Proof of Classification can be the following: 

• A test report 
• A lab report or 
• A document that explains how the dangerous goods were classified. 

The Proof of Classification must include the following: 

• The date on which the dangerous goods were classified 
• If applicable, the technical name of the dangerous goods 
• The classification of the dangerous goods 
• If applicable, the classification method used under this part or under chapter 2 of the UN recommendations 

DOT has a similar testing requirement for the challenges posed by materials with variable composition and potentially variable properties—such as crude oil. 

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