Use of precautionary statements
As you probably know already, precautionary statements are one of the key elements in the United Nations (UN) GHS standard. When you select a GHS hazard classification for your product, the GHS standard identifies the signal word, pictogram(s), hazard statement(s), and precautionary statement(s) that are associated with the classification.
Each precautionary statement in the GHS standard has an associated code of the form "Pxxx", where "xxx" is a three-digit number. The P100-series numbers are general precautions; the P200-series relate to prevention of product-specific hazards; the P300-series relate to response to fires, releases, etc.; the P400-series relate to storage; and the P500-series relate to disposal. In some cases the codes represent a combination of precautionary statements, such as "P370+P380", which refers to "In case of fire: evacuate area.".
The UN precautionary statements include "P" codes so that each statement will be the same when translated into the various official language(s) of participating countries. Only the precautionary statement(s) need to appear on the Safety Data Sheet (SDS), and on GHS labels. However, you can include the "P" codes as well as the statements.
In the Hazard Communication Standard (HCS, 29 CFR 1910.1200) for the US, OSHA did not associate each precautionary statement with a "P" code. Because the HCS includes precautionary statements which are mostly identical to those in the UN GHS revisions, however, "P" codes can be assigned to most of the HCS statements.
Precautionary statement variations
Precautionary statements vary somewhat in different revisions of the UN GHS standard.
In some cases, the exact phrasing or punctuation of a precautionary statement changes in later revisions. For example, under UN rev. 3, Code P378 referred to "Use … for extinction.", whereas in UN revs. 4, 5, and 6, the same code referred to an updated phrase, "Use … to extinguish."
Regulatory authorities (like OSHA in the US) may have revised precautionary statement wording. For example, under UN revs. 3, 4, 5, and 6, Code P272 is "Contaminated work clothing should not be allowed out of the workplace." The equivalent statement in the OSHA Hazard Communication Standard (HCS) is "Contaminated work clothing must not be allowed out of the workplace."
Another difference between the UN GHS revisions and the OSHA HCS involves Code P280, which for the UN revisions is "Wear protective gloves/protective clothing/eye protection/face protection." The forward slashes indicate that you should modify the statement to reflect the personal protective gear appropriate for your product (refer to "Customizing precautionary statements", next).
Unlike the UN GHS, the HCS separates these items into individual statements, such as "Wear face protection.", "Wear protective gloves.", and "Wear protective gloves/protective clothing.", etc.
If you specify the "US" GHS revision in the drop-down menu (Tab 2, "Hazards"), SDScribe™ includes suffixes on P280 (e.g., "P280f" for face protection or "P280fg" for face protection and gloves, etc.). These suffixes will not appear on the generated SDS. You should select only one P280 code for the hazard table, whether or not it includes suffixes.
Customizing precautionary statements
As you may have noticed, some precautionary statements contain ellipsis ("…") and/or series of slashes. For example,
P230 – "Keep wetted with..."
P280 – "Wear protective gloves/protective clothing/eye protection/face protection."
P378 – "Use … to extinguish."
In these cases, you as the SDS author must tailor the phrase as you deem appropriate for your product. For example, you might require gloves and eye protection, but not protective clothing or face protection (e.g., a face shield). For storage, you would specify the type of material to wet the product with, when appropriate. For firefighting, you would want to specify a type of fire suppressant to use (water, foam, dry chemical, etc.).
It is a mistake to use a customizable precautionary statement on an SDS or GHS label without making the necessary customizations.
Combining precautionary statements together
Where space is at a premium on GHS labels, you can combine statements together and/or include them in series to form a paragraph. However, the combined statements must convey the same information as would using the individual statements.
How SDScribe™ incorporates precautionary statements
When you create an SDS, you use the "2 Hazards" tab of the entry form to add hazard classifications for your product to a table listing. From the "Classification" table tab, you can select classification(s) from either the drop-down menu or from the "Multi" button.
The program will offer to add pictograms, hazard statements, and precautionary statements which are appropriate for the hazard classification, and for the GHS revision selected. (You select the GHS revision from the "GHS" drop-down menu, just above the table.)
The related items will appear on the other table tabs ("Pictograms", "Hazard statements", and "Precautionary statements").
For precautionary statements that require customization, SDScribe™ includes a dialog for creating variations based on the "Pxxx" code (File menu -> "Customize P-statements"). Then, when you add a precautionary statement to the SDS hazard table, if customized variants are available, the program will prompt you to select one of the variants. You can also select the unmodified ("standard") statement.
You can also add precautionary statements individually (without first adding a hazard classification), by selecting them from a drop-down menu on the "Precautionary statements" table tab.
Effect of changing the GHS revision
You can change the GHS revision for an SDS by selecting the new GHS revision from the "GHS" drop-down menu, above the hazard table. If the SDS already contains hazard classifications, pictograms, hazard statements, and/or precautionary statements, the program may ask whether it should attempt to convert the hazard items from the current GHS revision to the selected GHS revision.
If you allow the changes, the program will determine whether each of the precautionary statements, hazard statements, pictograms, and/or classifications are each available in the newly-selected GHS revision. In the case of precautionary statements, it performs this task by comparing the "P" codes. If a statement is not available, then the statement itself will remain unchanged, but will appear in the list with an orange-colored text.