Frequently Asked SDS Symbols Questions
How many times have you thought you understood a requirement, only to second guess yourself about whether you got that right or not? It could be something relatively straight forward, or something a bit more complicated. Everyone has these moments occasionally, especially with the implementation of GHS around the world. At ICC, two of the questions that seem to pop up from time to time, revolve around symbols on SDSs.
Do GHS pictograms have to appear on an SDS?
The answer: No. The ‘pictogram,’ specifically, doesn’t have to appear. This answer, in part, boils down to terminology.
In both Canada, under WHMIS 2015 Hazardous Products Regulations (HPR) requirements, and in the United States, under Hazcom 2012 requirements, Section 2 of an SDS is required to list the label ‘information elements’ that are applicable to the product. Hazard ‘symbols’ being one of the required ‘information elements’.
In both the United States and in Canada, ‘pictogram’ is defined as a “symbol” along with other “elements, such as a border or background color”. So a complete GHS ‘pictogram’ is actually two part; a graphic symbol on the inside, and a frame surrounding it. Both countries include an allowance only to show a ‘symbol’ (ie. not a ‘pictogram’), or, just the name of the symbol, on the SDS [Hazcom 2012, Appendix D, Table D.1, Item 2(b); WHMIS 2015 Hazardous Products Regulations, Schedule 1, Item 2(b)].
So … no complete ‘pictogram’ is required on the SDS in the US or in Canada.
If I choose to show a complete ‘pictogram’, and not just the ‘name’ of the symbol on the SDS in Section 2, do I have to use a red frame?
The answer: No. the ‘pictogram’ would not have to show a red frame on the SDS.
As mentioned above, in both countries, what is required on the SDS is the ‘symbol’ and not the complete ‘pictogram’ [Hazcom 2012, Appendix D, Table D.1, Item 2(b); HPR, Schedule 1, Item 2(b)]. What that means, is that if you choose to include a complete ‘pictogram’ on your Hazcom 2012 or WHMIS 2015 SDS (ie. the ‘symbol‘ plus the frame), you can include the frame in the color you prefer since the requirement on the SDS is for the ‘symbol’ only and not the ‘pictogram’. There is no specific requirement in Hazcom 2012 or the HPR to have a red framed pictogram on the SDS. The red frame requirement is only on the label (Hazcom 2012, Appendix C, Section C.2.3.1; HPR, Part 3, Section 3.1).
As an example, Section 2 of an SDS for a product classified as a Flammable Liquid – Category 3 and an Eye Irritant – Category 2A, may appear as any of the following 3 options:
|Option 1||Option 2||Option 3|
|Label elements||Label elements||Label elements|
|Hazard pictogram(s)||Hazard pictogram(s)||Hazard pictogram(s)|
|Insert GHS Red flame & Exclamation Mark||Insert GHS Black flame & Exclamation Mark||Exclamation Mark|
The above SDS information is applicable in Canada and the United States. Section 2 SDS requirements may vary, depending on what region of the world you are dealing with.
Should you have any questions regarding SDS’s, please contact ICC Compliance Center at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).