The Globally Harmonized System for the Classification and Labelling (The GHS) - Implementation of the GHS in Canada
Transportation of Dangerous Goods
Table 2: Comparison of Hazard Communication: TDG and the GHS [Physical, Health, Environment]
Explosives
| Class |
1.1 |
1.2 |
1.3 |
1.4 |
1.5 |
1.6 |
TDG |
|
|
|
 |
 |
 |
Division |
Unstable/1.1 |
1.2 |
1.3 |
1.4 |
1.5 |
1.6 |
GHS |
Danger
Explosive; mass explosion hazard |
Danger
Explosive;
severe projection hazard |
Danger
Explosive; fire, blast or projection hazard |
1.4*
Warning
Fire or projection hazard |
1.5*
Warning
May explode in fire |
1.6* |
* Apply to substances or mixtures subject to the UN Recommendations for the Transport of Dangerous Goods, Model Regulations
Comments: Unstable explosives are FORBIDDEN for transport.
Flammable Gases
| Class |
2.2 |
|
TDG |
 |
Not required under TDG |
|
Category 1 |
Category 2 |
GHS |
Danger
Extremely flammable gas |
No symbol
Warning
Flammable gas |
Comments: In addition to the testing criteria for flammable range outlined in the GHS, for mixtures TDG allows the use of calculations specified in ISO 10156.
Flammable Aerosols
| Class |
2.1 |
2.1 |
TDG |
|
|
|
Category 1 |
Category 2 |
GHS |
Danger
Extremely flammable aerosol |
Warning
Flammable aerosol |
Comments: Since TDG is silent on the criteria for flammable aerosols, criteria in the UN Recommendations on the Transport of Dangerous Goods, Model Regulations should be used. In the 12th Revised Edition of the Model Regulations, criteria are defined in Special Provision 63:
"(a) Division 2.1 applies if the contents include more than 45% by mass, or more than 250 g of flammable components. Flammable components are gases which are flammable in air at normal pressure or substances or preparations in liquid form which have a flash point less than or equal to 100 oC;"
GHS testing procedures were recently incorporated into the UN Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria so it expected that TDG will be in line with the GHS in the future.
Oxidizing Gases
| Class |
2.2(5.1) |
TDG |
 |
|
Category 1 |
GHS |
Danger
May cause or intensify fire, oxidizer |
Comments: Since TDG is silent on the criteria for oxidizing gases, criteria in the UN Recommendations on the Transport of Dangerous Goods, Model Regulations should be used. In the 12th Revised Edition of the Model Regulations, the criterion for oxidizing gases is the same as the GHS.
Gases Under Pressure
| Class 2.2 |
Compressed Gas |
Liquified Gas |
Refrigerated Liquified Gas |
issolved Gas |
TDG |
 |
|
|
|
|
Compressed Gas |
Liquified Gas |
Refrigerated Liquified Gas |
Dissolved Gas |
GHS |
Warning
Contains gas under pressure; may explode if heated |
Warning
Contains gas under pressure; may explode if heated |
Warning
Contains refrigerated gas; may cause cryogenic burns or injury |
Warning
Contains gas under pressure; may explode if heated |
Comments: Under TDG these symbols are not required for toxic, oxidizing or flammable gases.
Flammable Liquids
| Class 3 |
Packing Group I |
Packing Group II |
Packing Group III |
|
TDG |
|
|
|
Not required under TDG |
|
Category 1 |
Category 2 |
Category 3 |
Category 4 |
GHS |
Danger
Extremely flammable liquid and vapour |
Danger
Highly flammable liquid and vapour |
Warning
Flammable liquid and vapour |
No symbol
Warning
Combustible liquid |
Comments: The GHS has a flash point requirement for Category 1 of < 23 oC, no such requirement exists in either TDG or the UN Recommendations on the Transport of Dangerous Goods, Model Regulations.
Flammable Solids
Class 4.1 |
Packing Group II |
Packing Group III |
TDG |
 |
|
|
Category 1 |
Category 2 |
GHS |
Danger
Flammable solid |
Warning
Flammable solid |
Comments: In addition to the above categories for Flammable solid, TDG regulates solid desensitized explosives and substances that cause fire through friction. Neither of these groups are covered by GHS criteria.
Self-Reactive Substance
| Class 4.1 Packing Group II |
Type A |
Type B |
Types C & D |
Types E & F |
Type G |
TDG |
Forbidden for Transport |
 |
|
|
Not required under TDG |
|
Type A |
Type B |
Types C & D |
Types E & F |
Type G |
GHS |
Danger
Heating may cause an explosion |
Danger
Heating may cause a fire or explosion |
Danger
Heating may cause a fire |
Warning
Heating may cause a fire |
No label elements |
Pyrophoric Liquids
Class 4.2 |
Packing Group I |
TDG |
 |
|
Category 1 |
GHS |
Danger
Catches fire spontaneously if exposed to air |
Pyrophoric Solids
| Class 4.2 |
Packing Group I |
TDG |
|
|
Category 1 |
GHS |
Danger
Catches fire spontaneously if exposed to air |
Self Heating Substances
Class 4.2 |
Packing Group II |
Packing Group III |
|
TDG |
|
|
|
Category 1 |
Category 2 |
GHS |
Danger
Self-heating; may catch fire |
Warning
Self-heating in large quantities; may catch fire |
Substances, which in contact with water, emit flammable gases
Class 4.3 |
Packing Group I |
Packing Group II |
Packing Group III |
TDG |
 |
|
|
|
Category 1 |
Category 2 |
Category 3 |
GHS |
Danger
In contact with water releases flammable gases which may ignite spontaneously. |
Danger
In contact with water releases flammable gases |
Warning
In contact with water releases flammable gases |
Oxidizing Liquids
Class 5.1 |
Packing Group I |
Packing Group II |
Packing Group III |
TDG |
 |
|
|
|
Category 1 |
Category 2 |
Category 3 |
GHS |
Danger
May cause fire or explosion; strong oxidizer |
Danger
May intensify fire; oxidizer |
Warning
May intensify fire; oxidizer |
Oxidizing Solids
Class 5.1 |
Packing Group I |
Packing Group II |
Packing Group III |
TDG |
|
|
|
|
Category 1 |
Category 2 |
Category 3 |
GHS |
Danger
May cause fire or explosion; strong oxidizer |
Danger
May intensify fire; oxidizer |
Warning
May intensify fire; oxidizer |
Organic Peroxides
| Class 5.2 Packing Group II |
Type A |
Type B |
Types C & D |
Types E & F |
Type G |
TDG |
Forbidden for Transport |
|
|
|
Not required under TDG |
|
Type A |
Type B |
Types C & D |
Types E & F |
Type G |
GHS |
Danger
Heating may cause an explosion |
Danger
Heating may cause a fire or explosion |
Danger
Heating may cause a fire |
Warning
Heating may cause a fire |
No label elements |
Corrosive to Metal
Class 8 |
Packing Group III |
TDG |
 |
|
Category 1 |
GHS |
Warning
May be corrosive to metals |
Acute Toxicity: Oral - Liquid
| Class 6.1 |
Packing Group I |
Packing Group II |
Packing Group III |
|
|
TDG |
 |
|
|
Not required under TDG |
Not required under TDG |
| mg/kg |
5 |
50 |
500 |
|
|
|
Category 1 |
Category 2 |
Category 3 |
Category 4 |
Category 5 |
GHS |
Danger
Fatal if swallowed |
Danger
Fatal if swallowed |
Danger
Toxic if swallowed |
Warning
Harmful if swallowed |
No symbol
Warning
May be harmful if swallowed |
| mg/kg |
5 |
50 |
300 |
2000 |
5000 |
Comments: The current TDG breakpoint for Category 4 is 500 mg/kg. A change to a breakpoint of 300 mg/kg for Packing Group III would result in fewer toxic liquids being regulated.
Acute Toxicity: Oral - Solid
| Class 6.1 |
Packing Group I |
Packing Group II |
Packing Group III |
|
|
TDG |
|
|
|
Not required under TDG |
Not required under TDG |
| mg/kg |
5 |
50 |
200 |
|
|
|
Category 1 |
Category 2 |
Category 3 |
Category 4 |
Category 5 |
GHS |
Danger
Fatal if swallowed |
Danger
Fatal if swallowed |
Danger
Toxic if swallowed |
Warning
Harmful if swallowed |
No symbol
Warning
May be harmful if swallowed |
| mg/kg |
5 |
50 |
300 |
2000 |
5000 |
Comments: The current TDG breakpoint for Category 4 in 200 mg/kg. A change to a breakpoint of 300 mg/kg for Packing Group III would result in more toxic solids being regulated.
Acute Toxicity: Skin
Class 6.1 |
Packing Group I |
Packing Group II |
Packing Group III |
|
|
TDG |
|
|
|
Not required under TDG |
Not required under TDG |
| mg/kg |
40 |
200 |
1000 |
|
|
|
Category 1 |
Category 2 |
Category 3 |
Category 4 |
Category 5 |
GHS |
Danger
Fatal in contact with skin |
Danger
Fatal in contact with skin |
Danger
Toxic in contact with skin |
Warning
Harmful in contact with skin |
No symbol
Warning
May be harmful in contact with skin |
| mg/kg |
50 |
200 |
1000 |
2000 |
5000 |
Comments: The current TDG breakpoint for Category 1 is 40 mg/kg. A change to a breakpoint of 50 mg/kg would increase the number of toxic substances included in Packing Group I.
Acute Toxicity: Inhalation (dust, mist)
| Class 6.1 |
Packing Group I |
Packing Group II |
Packing Group III |
|
|
TDG |
|
|
|
Not required under TDG |
Not required under TDG |
| mg/L(1h) |
0.5 |
2.0 |
10 |
|
|
|
Category 1 |
Category 2 |
Category 3 |
Category 4 |
Category 5 |
GHS |
Danger
Fatal if inhaled |
Danger
Fatal if inhaled
|
Danger
Toxic if inhaled |
Warning
Harmful if inhaled |
No symbol
Warning
May be harmful if inhaled |
| mg/L(4h) |
0.05 |
0.5 |
1.0 |
5.0 |
|
Comments: The result of replacing the current TDG breakpoints with the GHS breakpoints would be to decrease the number of toxic substances in Packing Group I while increasing the number in Packing Group II also, the number of substances in Packing Group III would be reduced. It is not expected that this would have much impact since very few substances are classified using these criteria.
Acute Toxicity: Inhalation (vapour)
Class 6.1 |
Packing Group I |
Packing Group II |
Packing Group III |
|
|
TDG |
|
|
|
Not required under TDG |
Not required under TDG |
| mL/m3(1h) |
1000 |
3000 |
5000 |
|
|
| Category 1 |
Category 2 |
Category 3 |
Category 4 |
Category 5 |
GHS |
Danger
Fatal if inhaled |
Danger
Fatal if inhaled |
Toxic if inhaled |
Warning
Harmful if inhaled |
No symbol
Warning
May be harmful if inhaled |
| mg/L(4h) |
0.5 |
2.0 |
10.0 |
20.0 |
|
Comments: The results of aligning the current TDG breakpoints, based on hazard alone, with those of the GHS would be dramatic. Packing Group I would cover extremely toxic substances (LC50 < 250 mL/m3). Packing Group II would include the remainder of substances currently in Packing Group I. Packing Group III would be comprised of those substances currently in Packing Groups II and III. TDG breakpoints also include a risk factor "V"(saturated vapour concentration). Although truly only useful in defining Packing Group I, "V" should be considered before any mass reclassification of substances.
Acute Toxicity: Inhalation (gas)
|
Class 2.3 |
|
|
TDG |
 |
Not required under TDG |
Not required under TDG |
mL/m3(1h) |
5000 |
|
|
|
Category 1 |
Category 2 |
Category 3 |
Category 4 |
Category 5 |
GHS |
Danger
Fatal if inhaled |
Danger
Fatal if inhaled |
Danger
Toxic if inhaled |
Warning
Harmful if inhaled |
No symbol
Warning
May be harmful if inhaled |
| ppm(4h) |
100 |
500 |
2500 |
5000 |
|
Comments: TDG has no breakpoints within Class 2.3 and so, all toxic gases must be treated as if they were in GHS Category 1.
Skin Corrosion/Irritation
|
Category 1A |
Category 1B |
Category 1C |
Category 2 |
Category 3 |
TDG |
|
|
|
Not required under TDG |
Not required under TDG |
GHS |
Danger
Causes severe skin burns and eye damage |
Danger
Causes severe skin burns and eye damage |
Danger
Causes severe skin burns and eye damage |
Warning
Causes skin irritation |
No symbol
Warning
Causes mild skin irritation |
Serious Eye Damage/Irritation
|
Category 1A |
Category 2A |
Category 2B |
TDG |
Not required under TDG |
Not required under TDG |
Not required under TDG |
GHS |
Danger
Causes serious eye damage |
Warning
Causes serious eye irritation |
No symbol
Warning
Causes eye irritation |
Respiratory Sensitization
|
Category 1 |
TDG |
Not required under TDG |
GHS |
Danger
May cause allergy or asthma symptoms or breathing difficulties if inhaled |
Skin Sensitization
|
Category 1 |
TDG |
Not required under TDG |
GHS |
Warning
May cause an allergic skin reaction |
Germ Cell Mutagenicity
|
Category 1A |
Category 1B |
Category 2 |
TDG |
Not required under TDG |
Not required under TDG |
Not required under TDG |
GHS |
Danger
May cause genetic defects (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Danger
May cause genetic defects (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Warning
Suspected of causing genetic defects (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Carcinogenicity
|
Category 1A |
Category 1B |
Category 2 |
TDG |
Not required under TDG |
Not required under TDG |
Not required under TDG |
GHS |
Danger
May cause cancer
(state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Danger
May cause cancer
(state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Warning
Suspected of causing cancer
(state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Toxic to Reproduction
|
Category 1A |
Category 1B |
Category 2 |
TDG |
Not required under TDG |
Not required under TDG |
Not required under TDG |
GHS |
Danger
May damage fertility or the unborn child
(state specific effect if known) (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Danger
May damage fertility or the unborn child
(state specific effect if known) (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Warning
Suspected of May damaging fertility or the unborn child (state specific effect if known) (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Effects on or via Lactation
|
Category 1 |
TDG |
Not required under TDG |
GHS |
May cause harm to breast-fed children |
Target Organ Systemic Toxicity (Single Exposure)
|
Category 1 |
Category 2 |
TDG |
Not required under TDG |
Not required under TDG |
GHS |
Danger
Causes damage to (state all organs affected, or use a general statement where there is no definite evidence that other organs are not affected) if (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Warning
Causes damage to (state all organs affected, or use a general statement where there is no definite evidence that other organs are not affected) if (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Target Organ Systemic Toxicity (Repeated Exposure)
|
Category 1 |
Category 2 |
TDG |
Not required under TDG |
Not required under TDG |
GHS |
Danger
Causes damage to (state all organs affected, or use a general statement where there is no definite evidence that other organs are not affected) if (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Warning
Causes damage to (state all organs affected, or use a general statement where there is no definite evidence that other organs are not affected) if (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Aquatic Toxicity (Acute)
|
Category 1 |
Category 2 |
Category 3 |
TDG |
|
Not required under TDG |
Not required under TDG |
GHS |
Warning
Very toxic to aquatic life |
No symbol
No signal word
Toxic to aquatic life |
No symbol
No signal word
Harmful to aquatic life |
Comments: TDG now follows the requirements outlined in the International Maritime Dangerous Goods Code (IMDG CODE) for marine transport only. As it expected that these requirements will be harmonized with the GHS, TDG will follow suit.
Aquatic Toxicity: Chronic
|
Category 1 |
Category 2 |
Category 3 |
Category 4 |
TDG |
|
|
|
|
GHS |
Warning
Very toxic to aquatic life with long lasting effects |
No signal word
Toxic to aquatic life with long lasting effects |
No symbol
No signal word
Harmful to aquatic life with long lasting effects |
No symbol
No signal word
May cause long lasting harmful effects to aquatic life |
Comments: TDG now follows the requirements outlined in the International Maritime Dangerous Goods Code (IMDG CODE) for marine transport only. As it expected that these requirements will be harmonized with the GHS, TDG will follow suit.
|
