GHS does not require SDS to provide NFPA or HMIS labeling information, but when they do – IT MUST BE CORRECT

HFO SDS screen shot

Over the past four (4) years, I have been involved in an industry that I would have never thought would be some of my Process Safety clients and over these same four years, I have come to feel sorry for an entire industry.  This industry was forced to change to an alternative chemical in order to “protect the environment”; albeit their new chemical is NOT a less “hazardous” chemical!  In fact, the replacement chemical is a Category 1 Flammable Gas (as defined by GHS/OSHA) and the chemical it replaced was NOT flammable gas and in fact was darn near “safe” for workers, but it had too high of a Global Warming # and such was deemed a threat to our environment.  This “replacement chemical” is manufactured by a hand full of companies and the one thing they seem to agree on is that using the Globally Harmonized System (GHS) that this chemical is a “Category 1 Flammable Gas“.  Unfortunately, that is where their similarities end.  What confuses many of the Safety Professionals responsible for managing this material is how Category 1 Flammable Gas can be anything but a “4” in the NFPA 704 or HMIS labeling systems.  What is more curious is how one of these manufacturers’s started out stating the CAT 1 Flammable Gas was a “1” in the NFPA 704 and HMIS labeling system.  That company has gone full circle and now states the NFPA rating is a 3-Health and 4-Flammability; that is quite a change from 0-Health and 1-Flammability.  While one manufacturer has brought their SDS more in line with what one would expect; the other manufacturer has gone in the opposite direction; they started out with these NFPA ratings, 2-Health and 4-Flammability and have now revised their NFPA 704 ratings to 2-Health and 2-Flammability in their 2018 revision of their SDS.  So the question I have… how does a CAT 1 Flammable Gas (Extremely Flammable) end up with a “2” for the NFPA 704 rating?  Let’s see…

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