The Globally Harmonized System for the Classification and Labelling
(The GHS) - Implementation of the GHS in Canada
Consumer Chemicals
Table 2: Comparison of Hazard Communication: Consumer Chemicals [Health
and Environment; Mixtures]
Acute Toxicity: Oral
Acute Toxicity: Oral
Analysis:
Criteria for both systems is based on the LD50 of the substance
or mixture. Under the CCCR, Very Toxic products align with the LD50
cut-off values for Category 1 and 2 of the GHS. Under the CCCR, product
in these two categories are prohibited from advertisement, sale or importation.
There are no exceptions. This prohibition is based on the policy that
these products are too hazardous to be routinely made available to consumers
who lack specialized knowledge and training to use such products. Such
downstream consequences of product classification such as prohibition
are outside the scope of the GHS. Once the GHS is implemented, it is expected
that the prohibition of Category 1 and 2 products will continue under
the CCCR.
Under the CCCR, Toxic Products do not align with the LD50
cut-off values of the GHS Category 3. Under the CCCR, the cut-off for
Toxic Products is 500 mg/kg, whereas the GHS cut-off is at 300 mg/kg.
As a result, products with LD50s between 300 and 500 mg/kg
will be captured under the GHS Category 4 . It is difficult to measure
the impact of such a change in terms of the number of products affected,
however, it is estimated that less than 10% of consumer products will
be affected. (This estimate is based on an assessment done by PMRA whose
criteria are the same as the CCCR for this endpoint).
There will be a change to the symbol for Toxic products under the GHS.
The skull and crossbones glyph is modified in colour and design and the
GHS border shape (red diamond) will replace the octagon. The signal words
are the same for both systems. The primary hazard statements of "Toxic
if swallowed" will replace "Poison".
Other downstream consequences of classification such as child-resistant
container requirements are outside the scope of the GHS and will continue
under the CCCR. However, due to the change in classification of Toxic
Products, the cut-off value of 500 mg/kg used as the criteria for child-resistant
containers will not coincide with the label requirements under the GHS.
Under the CCCR, Harmful products will be captured under Category 4 of
the GHS. As indicated above, Category 4 will now capture some products
formerly classified as Toxic under the CCCR. The cut-off at the higher
end is the same for both systems. There will be a change to the symbol
for Harmful (and Toxic) products under the GHS Category 4. The skull and
crossbones in an octagon will be replaced by an exclamation mark in a
red diamond border. The signal word will change from "Caution" to "Warning"
and the primary hazard statement of "May be toxic if swallowed" will replace
"Poison".
Consumer education of new symbols will be required.
For Category 5 there are no equivalent lethality criteria under the CCCR.
The Annex or Notes to Category 5, however, are important for consumer
products. The CCCR may capture products based on the criteria in the notes
to Category 5 as substances of special concern, which is a list based
classification of substances causing special concern. In some cases, human
data are available that show lethal dose values less than those of animals.
This warrants assignment to a more hazardous category. For classification
of all consumer products the CCCR has an overlying policy that if human
experience data exist, this must first be used to classify the product.
Mixtures:
Hazard Classes
|
GHS
|
Consumer Chemicals
|
|
Criteria
|
Criteria
|
|
Acute Toxicity - Oral
|
|
|
|
1. Test data on mixture
|
Use test data.
|
Use test data
|
|
2. Test data available on similar mixtures
|
Use Bridging Principles
|
Acceptable data source
|
|
3. Test data available for all ingredients in the mixture
|
Use formula
|
Use formula
|
Formula is similar.
|
4. Test data available for some ingredients, 10%
ingredients with unknown toxicity
|
Use formula in 3.
|
Estimate toxicity of unknown ingredients or substitute the LD50
of most toxic ingredient for unknown LD50 into formula.
|
|
5. Test data available for some ingredients, >10% ingredients
with unknown toxicity
|
Use modified formula in 3.
|
Estimate toxicity of unknown ingredients or substitute the LD50
of most toxic ingredient for unknown LD50 into formula.
|
|
Analysis:
Under both the CCCR and the GHS, mixtures are classified according to
the same criteria as substances when data are available for the complete
mixture. Both systems utilize a formula that is similar for estimating
the toxicity of untested mixtures, where the toxicity of the ingredients
are known. The CCCR is similar to the GHS in that it allows for some bridging
principles to be applied including classification using a product or mixture
that has properties similar to those of the product or mixture under examination.
Under the GHS, the approach for dealing with untested mixtures having
ingredients of unknown toxicity differs from the approach used by the
CCCR. The GHS accounts for the concentration of the unknown only when
it is present in a concentration greater than 10%, otherwise it is not
included in the formula. The CCCR uses the toxicity data of the most toxic
ingredient as the unknown and uses it in the formula.
Acute Toxicity: Skin
Analysis:
Criteria for both systems is based on the LD50 of the substance
or mixture. Under the CCCR, Very Toxic products align with the LD50
cut-off values for Category 1 and 2 of the GHS. Similar to acute oral
toxicity, Very Toxic products are prohibited, therefore consumer products
classified as Category 1 and 2 under the GHS will continue to be prohibited
as consumer products.
Toxic products of the CCCR, align with GHS Category 3. There will be
a change to the symbol such that the skull and crossbones glyph will be
modified in colour and design and the GHS border shape (red diamond) will
replace the octagon. The signal word "Danger" are the same for both systems.
The primary hazard statements of "Toxic in contact with skin" will replace
"Poison".
Harmful products of the CCCR align with GHS Category 4. There will be
a change to the symbol as the skull and crossbones in an octagon will
be replaced by an exclamation mark in a red diamond border. The signal
word will change from "Caution" to "Warning" and the primary hazard statement
of "Harmful in Contact with skin" will replace "Poison".
As described above, products that fall in Category 5 are not specifically
classified under the CCCR. Products with LD50s in this range
or even greater can be classified into a higher hazard category if warranted
e.g., human evidence. The Annex to Class 5 is important to consumer products.
Mixture:
Acute Toxicity - Skin
|
GHS
|
CCCR
|
1. Test data on mixture
|
Use test data.
|
Use test data
|
2. Test data available on similar mixtures
|
Use Bridging Principles
|
Acceptable data source
|
3. Test data available for all ingredients in the mixture
|
Use formula
|
Use formula
|
4. Test data available for some ingredients,
10% ingredients with unknown toxicity
|
Use formula in 3.
|
Estimate toxicity of unknown ingredients or substitute the LD50
of most toxic ingredient for unknown LD50
|
5. Test data available for some ingredients, >10% ingredients
with unknown toxicity
|
Use modified formula in 3.
|
Estimate toxicity of unknown ingredients or substitute the LD50
of most toxic ingredient for unknown LD50
|
Analysis:
same as for acute oral toxicity
Acute Toxicity: Inhalation - Gases
Analysis:
Criteria for both systems is based on the LC50 of the substance
or mixture. Under the CCCR, Very Toxic products align with the LC50
cut-off values for Category 1, 2 and 3 of the GHS. Very Toxic products
are prohibited, therefore consumer products classified as Category 1,
2 or 3 under the GHS will continue to be prohibited as consumer products.
The criteria for Harmful products of the CCCR align with Category 4 of
the GHS. There will be a change to the symbol as the skull and crossbones
in an octagon will be replaced by an exclamation mark in a red diamond
border. The signal word will change from "Caution" to "Warning" and the
primary hazard statement of "Harmful if inhaled" will replace "Poison".
Products that fall in Category 5 are not specifically classified under
the CCCR. Products with LC50s in this range or even greater
can be classified into a higher hazard category (Category 1-4) if warranted
e.g., human evidence. The Annex to Class 5 is important to consumer products.
Acute Toxicity: Inhalation - Vapours
Analysis:
Criteria for both systems is based on the LC50 of the substance
or mixture. Under the CCCR, criteria for Very Toxic products aligns with
the criteria for GHS Category 1 and 2 but also extend partly into GHS
Category 3 up to an LC50 of 5.0 mg/L (1500 ppm). Under the
CCCR, Very Toxic products are prohibited, therefore consumer products
classified as GHS Category 1, 2 or those that fall into Category 3 with
a LC50 equal to or less than 5.0 mg/L (1500 ppm) will continue
to be prohibited as consumer products.
(Prohibition is outside the scope of the GHS).
Under the CCCR, criteria for Toxic products align with the criteria for
Category 3 of the GHS. There will be a change to the symbol such that
the skull and crossbones glyph will be modified in colour and design and
the GHS border shape (red diamond) will replace the octagon. The signal
word "Danger" are the same for both systems. The primary hazard statement
of "Toxic if inhaled" will replace "Poison".
Under the CCCR, criteria for Harmful products aligns with the criteria
for Category 4 but also extends in Category 5 of the GHS for products
with LC50s greater than 20 mg/L (5000 ppm). There will be a
change to the symbol as the skull and crossbones in an octagon will be
replaced by an exclamation mark in a red diamond border for Category 4
and there will be no symbol for products classified as GHS Category 5.
The signal word will change from "Caution" to "Warning" for GHS Category
4 and 5. The primary hazard statement of "Harmful if inhaled" for Category
4 and "May be harmful if inhaled" for Category 5 will replace "Poison".
The criteria for GHS Category 5 includes LC50 values up to
12, 500 ppm, whereas the CCCR cut-off is at 10, 000 ppm. The GHS will
therefore capture more products in this category.
Acute Toxicity: Inhalation - Dusts & Mists
Analysis:
Criteria for both systems is based on the LC50 of the substance
or mixture. Under the CCCR, criteria for Very Toxic products aligns with
the criteria for GHS Category 1 and 2. Under the CCCR, Very Toxic products
are prohibited, therefore consumer products classified as GHS Category
1 or 2 will continue to be prohibited as consumer products. (Prohibition
is outside the scope of the GHS).
Under the CCCR, criteria for Toxic products align with the criteria for
Category 3 of the GHS but also extend into Category 4. There will be a
change to the symbol such that the skull and crossbones glyph will be
modified in colour and design and the GHS border shape (red diamond) will
replace the octagon for products aligned with Category 3. The signal word
"Danger" are the same for both systems. The primary hazard statement of
"Toxic if inhaled" will replace "Poison".
For Toxic products aligned with GHS Category 4, there will be a change
to the symbol as the skull and crossbones in an octagon will be replaced
by an exclamation mark in a red diamond border. The signal word "Danger"
will be replaced with "Warning" and the primary hazard statement of "Harmful
if inhaled" will replace "Poison".
Under the CCCR, criteria for Harmful products aligns with the criteria
for Category 4 of the GHS. There will be a change to the symbol as the
skull and crossbones in an octagon will be replaced by an exclamation
mark in a red diamond border. The signal word will change from "Caution"
to "Warning". The primary hazard statement of "Harmful if inhaled" will
replace "Poison".
Products that fall in Category 5 are not specifically classified under
the CCCR. Products with LC50s in this range or even greater
can be classified into a higher hazard category (Category 1-4) if warranted
e.g., human evidence. The Annex to Class 5 is important to consumer products.
Mixtures:
Acute Toxicity - Inhalation
|
|
|
1. Test data on mixture
|
Use test data.
|
Use test data
|
2. Test data available on similar mixtures
|
Use Bridging Principles
|
Acceptable data source
|
3. Test data available for all ingredients in the mixture
|
Use formula
|
Use formula
|
4. Test data available for some ingredients, 10%
ingredients with unknown toxicity
|
Use formula in 3.
|
Estimate toxicity of unknown ingredients or substitute the LC50
of most toxic ingredient for unknown LC50
|
5. Test data available for some ingredients, >10%
ingredients with unknown toxicity
|
Use modified formula in 3.
|
Estimate toxicity of unknown ingredients or substitute the LC50
of most toxic ingredient for unknown LC50
|
Skin Corrosion/Irritation
CCCR
(criteria for both skin and eye are together)
|
Very Corrosive
Substance of Special Concern
(a) ethylbromoacetate - any concentration;
(b) fluoride - greater than 0.5% of available fluoride ions.
Prohibition for the above
Corrosive
One or more Acids or Bases that are Liquid:
(a) a pH of not more than 1.0 or a pH of 13.0 or more;
(b) a pH of more than 1.0 but not more than 3.0 and an acid reserve
of 5.0 of more or a pH of less than 13.0 but not less than 11.0
and an alkali reserve of 5.0 or more.
One or more acids or bases that are Solid, paste or gel:
(a) a pH of not more than 1.0 or a pH of more than 13.0;
(b) a pH of more than 1.0 but not more than 3.0 and an acid reserve
of 10.0 of more or a pH of less than 13.0 but not less than 11.0
and an alkali reserve of 10.0 or more.
Substance, other than an acid or base, that is cable of
inducing necrosis or ulceration of epithelial tissue at the site
of application:
(c)The total concentration of substances that cause necrosis or
ulceration of 5% or more.
|
Irritant
One or more Acids or Bases that are Liquid:
(a) a pH of more than 1.0 but not more than 3.0 and an acid reserve
of 3.0 or more but less than 5.0;
(b) a pH of less than 13.0 but not less than 12.0 and an acid reserve
of less than 5.0;
c) a pH of less than 12.0 but not less than 11.0 and an acid reserve
of less than 5.0 but not less than 3.0.
One or more acids or bases that are Solid, paste or gel:
(a) a pH of more than 1.0 but not more than 3.0 and an
acid reserve of 5.0 or more but less than 10.0 a pH of more than
1.0 but not more than 3.0 and an acid reserve of 3.0 or more but
less than 5.0;
(b) a pH of less than 13.0 but not less than 12.0 and an acid reserve
of less than 10.0;
c) a pH of less than 12.0 but not less than 11.0 and an acid reserve
of less than 10.0 but not less than 5.0.
Substance, other than an acid or base, that is cable of
inducing necrosis or ulceration of epithelial tissue at the site
of application:
a) The total concentration of substances that cause necrosis
of ulceration of 1% or more but less than 5%.
Substances in a total concentration of 5% or more, other
than an acid or base, that is capable of causing any of the following:
- an erythema or edema of the skin graded at 2 or more,
- corneal damage graded at 2 or more,
- iris damage graded at 1 or more, or
- (iv) conjunctival swelling or redness graded at 2.5 or more.
|
GHS Criteria: Include if possible.
Skin Corrosion/Irritation:
CCCR
|
Very Corrosive
(generally prohibited)
Extreme Danger
Very Corrosive
Causes Severe Burns
|
Corrosive
Danger
Corrosive
Causes Burns
|
Irritant
No Symbol
Caution
Irritant
May Irritate Skin
|
GHS
|
Category 1A
Corrosive
Danger
Causes severe skin burns and eye damage
|
Category 1B
Corrosive
Danger
Causes severe skin burns and eye damage
|
Category 1C
Corrosive
Danger
Causes severe skin burns and eye damage
|
Category 2
Irritant
Warning
Causes skin irritation
|
Category 3
Mild Irritant
No symbol
Warning
Causes mild skin irritation
|
Mixture:
Skin Corrosion
|
|
|
1. Test data on mixture
|
Use test data.
|
Use test data
|
2. Test data available on similar mixtures
|
Use Bridging Principles
|
Classify if mixture contains a substance, other than an acid or
base capable of inducing necrosis or ulceration of epithelial tissue,
or cause erythema, edema >2.
|
3. Test data available for all or some ingredients in the mixture
|
Use additivity formula or classify based on irritating ingredients
present in concentration of >1%
|
Classify if mixture contains a substance, other than an acid or
base capable of inducing necrosis or ulceration of epithelial tissue,
or cause erythema, edema >2.
|
Skin Irritation
|
|
|
1. Test data on mixture
|
Use test data.
|
Use test data
|
2. Test data available on similar mixtures
|
Use Bridging Principles
|
Acceptable data source
|
3. Test data available for all or some ingredients in the mixture
|
Use additivity formula or classify based on irritating ingredients
present in concentration of >1%
|
Total concentration of substances 5%
that cause necrosis or ulceration of 1.0% or more but less than
5.0%
|
Analysis:
- tiered approach
- acid/alkali reserve considered
- physical parameter (pH and a/ar for acids and bases only)
- scoring is at any time rather than the mean score (see WHMIS paper)
- mixture
Serious Eye Damage/Irritation
CCCR
|
Very Corrosive
(generally prohibited)
Extreme Danger
Very Corrosive
Causes Severe Burns
|
Corrosive
Danger
Corrosive
Causes Burns
|
Irritant
No Symbol
Caution
Irritant
May Irritate Eyes
|
GHS
|
Category 1
Irreversible eye effects
Danger
Causes serious eye damage
|
Category 2A
Reversible eye effects in 21 days
Warning
Causes serious eye irritation
|
Category 2B
Reversible eye effects in 7 days
No symbol
Warning
Causes eye irritation
|
Mixtures:
Serious Damage to Eyes
|
|
|
1. Test data on mixture
|
Use test data.
|
|
2. Test data available on similar mixtures
|
Use Bridging Principles
|
Classify if mixture contains a substance, other than an acid or
base capable of inducing necrosis or ulceration of epithelial tissue,
or cause erythema, edema >2, corneal damage >1m or conjunctival
swelling or redness graded 2.5
|
3. Test data available for all or some ingredients in the mixture
|
Use additivity formula or classify based on irritating ingredients
present in concentration of >1%
|
Classify if mixture contains a substance
5%, other than an acid or base capable of inducing necrosis or ulceration
of epithelial tissue, or cause erythema, edema > 2, corneal damage
> 1m or conjunctival swelling or redness graded
2.5
|
Eye Irritation
|
|
|
1. Test data on mixture
|
Use test data.
|
Use test data
|
2. Test data available on similar mixtures
|
Use Bridging Principles
|
Classify if mixture contains a substance 5%,
other than an acid or base capable of inducing necrosis or ulceration
of epithelial tissue, or corneal damage >1m or conjunctival swelling
or redness graded 2.5
Total concentration of Substances that causes necrosis or ulceration
of 1.0% or more but less than 5.0%
|
3. Test data available for all or some ingredients in the mixture
|
Use additivity formula or classify based on irritating ingredients
present in concentration of >1%
|
Classify if mixture contains a substance 5%,
other than an acid or base capable of inducing necrosis or ulceration
of epithelial tissue, or corneal damage >1m or conjunctival swelling
or redness graded 2.5
Total concentration of Substances that causes necrosis or ulceration
of 1.0% or more but less than 5.0%
|
Respiratory Sensitization
CCCR
|
No criteria
|
GHS
|
Category 1
Evidence of Respiratory Sensitization
Danger
May cause allergy or asthma symptoms or breathing difficulties if
inhaled
|
Analysis:
The CCCR currently do not have criteria or labelling requirements for
respiratory sensitizers. If this endpoint is applicable to consumer products,
it is anticipated that such criteria will be adopted by the CCCR when
the GHS is implemented.
Future Work:
Research regarding whether consumer products contain respiratory sensitizers
will need to be determined. Preliminary research on some products has
shown that one class of potential skin and respiratory sensitizers (isocyanates)
may be present in some spray-in foam products as an unreacted monomer
(polyurethane prepolymer) that reacts (within the spray can) to form the
polymer (spray in foam insulation) product.
Skin Sensitization
CCCR
|
No criteria
|
GHS
|
Category
Evidence of skin sensitization
Warning
May cause an allergic skin reaction
|
Analysis:
The CCCR currently do not have criteria or labelling requirements for
respiratory sensitizers. If this endpoint is applicable to consumer products,
it is anticipated that such criteria will be adopted by the CCCR when
the GHS is implemented.
Future Work:
Research regarding whether consumer products contain skin sensitizers
will need to be determined. Preliminary research on some products has
shown that one class of potential skin and respiratory sensitizers (isocyanates)
may be present in some spray in foam products as an unreacted monomer
(polyurethane prepolymer) that reacts (within the spray can) to form the
polymer (spray in foam insulation) product. Other products such as latex
and formaldehyde are known skin sensitizers.
Germ Cell Mutagenicity
CCCR
|
No criteria
|
GHS
|
Category 1A
Known to induce heritable mutations
in germ cells of humans
Danger
May cause genetic defects (state route of exposure if it is
conclusively proven that no other routes of exposure cause the hazard)
|
Category 1B
Should be regarded as if they induce heritable mutations in germ
cells of humans
Danger
May cause genetic defects (state route of exposure if it is
conclusively proven that no other routes of exposure cause the hazard)
|
Category 2
May induce heritable mutations in germ cells of humans
Warning
Suspected of causing genetic defects (state route of exposure
if it is conclusively proven that no other routes of exposure cause
the hazard)
|
Analysis:
The CCCR currently do not have criteria or labelling requirements for
germ cell mutagenicity. If this endpoint is applicable to consumer products,
it is anticipated that such criteria will be adopted by the CCCR when
the GHS is implemented.
Future Work:
Research regarding whether consumer products contain germ cell mutagens
will need to be determined.
Carcinogenicity
CCCR |
No criteria |
GHS |
Category 1A:
Known Human Carcinogen
Danger
May cause cancer
(state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Category 1B:
Presumed Human Carcinogen
Danger
May cause cancer
(state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Category 2:
Suspected Human Carcinogen
Warning
Suspected of causing cancer
(state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) |
Analysis:
The CCCR currently do not have criteria or labelling requirements for
carcinogenicity. This endpoint may be applicable to consumer products,
it is anticipated that such criteria will be adopted by the CCCR when
the GHS is implemented.
Future Work:
Research regarding whether consumer products contain carcinogens will
need to be determined. A Working Group will need to be developed to determine
how the GHS can be applied to consumer products for this endpoint.
Toxic to Reproduction
CCCR |
No criteria |
GHS
|
Category 1A:
Known human reproductive or developmental toxicant
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)
|
Category 1B:
Presumed human reproductive or developmental toxicant
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)
|
Category 2:
Suspected human reproductive or developmental toxicant
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)
|
Analysis:
The CCCR currently do not have criteria or labelling requirements for
this endpoint. If applicable to consumer products, it is anticipated that
such criteria will be adopted by the CCCR when the GHS is implemented.
Future Work:
Research regarding whether consumer products contain ingredients toxic
to reproduction will need to be determined. A Working Group will need
to be developed to determine how the GHS can be applied to consumer products
for this endpoint.
Effects on or via Lactation
CCCR |
No criteria |
GHS
|
Category 1
May cause harm to breast-fed children
|
Analysis:
The CCCR currently do not have criteria or labelling requirements for
this endpoint. If applicable to consumer products, it is anticipated that
such criteria will be adopted by the CCCR when the GHS is implemented.
Future Work:
Research regarding whether consumer products contain ingredients that
have effects on or via lactation will need to be determined. A Working
Group will need to be developed to determine how the GHS can be applied
to consumer products for this endpoint.
Target Organ Systemic Toxicity (Single Exposure)
CCCR
|
No specific criteria, however, the CCCR lists some products as
substances of special concern that may fall within these categories.
The CCCR define "toxic product" which may include products within
this category and includes a chemical product that:
a) is capable of causing a lethal effect on a human;
b) is capable of causing a serious and irreversible but non-lethal
effect on a human, such as depressed level of consciousness, muscular
weakness or paralysis, acute renal or hepatic failure, arrhythmia,
hypotension, dyspnea, respiratory depression, pulmonary edema or
optic neuritis.
Labelling is similar to the Acute Toxicity category and is labelled
based on classification as Toxic or Harmful depending on how a substances
is classified in the list.
|
GHS
|
Category 1
Produces significant toxicity in humans
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)
|
Category 2
May be harmful to human health
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)
|
Analysis:
Under the CCCR, 2001, the list of substances of special concern was developed
as an extension of the human experience criterion. The substances listed
are of special concern because standard animal tests may not reflect the
actual hazard posed by these substances to humans. The GHS criteria for
this endpoint are intended to capture such products. As the GHS is criteria
based, the development and maintenance of lists of chemicals have not
been promoted by the system.
Future Work: There is the need to determine how each substance
of special concern will be classified under the GHS. It may be determined
that some products may be captured under Category 5 of the Acute Toxicity
criteria and be subsequently reclassified based on the criteria of Annex
1 to Category 5 or products could be classified based on human experience
in general and may be classified into a lower Category. Therefore, the
substances of special concern that are currently classified as Very Toxic
and therefore prohibited may be captured in Category 1 and 2 of Acute
Toxicity and will continue to be prohibited as consumer products.
(Although prohibition is outside the scope of the GHS, the classification
of products will determine whether products are prohibited as consumer
products.)
Target Organ Systemic Toxicity (Repeated Exposure)
CCCR
|
No criteria |
|
GHS
|
Category 1
Produces significant toxicity in humans
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)
|
Category 2
May be harmful to human health
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)
|
Analysis:
The CCCR currently do not have criteria or labelling requirements for
this endpoint. If found to be applicable to consumer products, it is anticipated
that such criteria would be adopted by the CCCR when the GHS is implemented.
Future Work:
Research regarding whether consumer products contain substances that
pose target organ systemic toxicity with repeated exposure, will need
to be determined. A Working Group will need to be developed to determine
how the GHS can be applied to consumer products for this endpoint.
Aquatic Toxicity (Acute)
CCCR |
No criteria |
GHS
|
Category 1
Warning
Very toxic to aquatic life
|
Category 2
No symbol
No signal word
Toxic to aquatic life
|
Category 3
No symbol
No signal word
Harmful to aquatic life
|
Analysis:
It is anticipated that this endpoint is not applicable to consumer products.
Aquatic Toxicity: Chronic
CCCR
|
No criteria |
GHS
|
Category 1
Warning
Very toxic to aquatic life with long lasting effects
|
Category 2
Toxic to aquatic life with long lasting effects
|
Category 3
No symbol
No signal word
Harmful to aquatic life with long lasting effects
|
Category 4
No symbol
No signal word
May cause long lasting harmful effects to aquatic life
|
Analysis:
It is anticipated that this endpoint is not applicable to consumer products.
|