As with any good regulation, Nauman said, there are not only benefits, but costs as well.Implementing GHS – which includes labeling products and training employees on hazard communication programs and new labeling practices for safety data sheets – could cost U.S. industries alone U.S. $201 million (157 million) per year. The U.S. Occupational Safety & Health Administration (OSHA) estimates a setback of U.S. $22.5 million to reclassify chemical hazards, U.S. $59 million for management to become familiar with the system, U.S. $95.4 million for training and U.S. $241 million to print new packaging labels.

Despite the extra costs, it all sounds pretty good, Nauman continued. GHS will simplify hazard communication training and facilitate the international trade of chemicals.

OSHA says these factors will counteract many of the added expenditures and result in gains of almost U.S. $500 million from productivity improvements alone.

But as most of us who have been in the field a number of years know, there are always a few unintended consequences, she noted. Its very difficult to think through everything that could possibly happen, and several of us in the packaging industry have recently become very concerned about some unexpected consequences for companies that are purchasing our packaging.

Worst-Case Scenario

GHS has introduced new criteria for classifying corrosives, which would put some chemicals in the Class 8 category based on skin corrosivity and pH value. To fall in this category, a chemical would have to present evidence of irreversible damage to the skin, animal skin corrosion after exposure, harm to skin based on in-vitro data, or have pH extremes of either two or less or 11.5 or above. Therefore, chemicals in the Class 8 category, such as some amines and caustics, would fall under the U.N.s Transport of Dangerous Goods Packaging Group 1.

Packaging, shipping or purchasing chemicals in the Class 8/Packaging Group 1 categories is the worst-case scenario under the new system, Nauman said. This is mainly because such goods are not permitted to be transported in any type of intermediate bulk container (IBC).

The reclassification would affect approximately 6 million tons, or 15 percent, of all products shipped in IBCs today. All applicable mixtures and products would need to be packaged in another type of approved container, such as 55-gallon steel or plastic drums, Nauman pointed out.

It takes five 55-gal drums to replace one IBC, she continued. Therefore, the 6 million IBCs that would potentially be shipping Class 8 goods would need to be substituted by 30 million drums, resulting in a 20 percent increase in transport and warehouse costs. According to the International Confederation of Plastics Packaging Manufacturers, substituting those 6 million IBCs would increase transport costs by around U.S. $8 billion.

One IBC occupies the footprint of four 55-gal drums on a pallet. Therefore, the change to drums would require more warehouse space. In addition, the emptying procedures for IBCs and drums are entirely different. IBCs generally are emptied by gravity through an outlet valve near the bottom, while drums require an emptying lance or pump. Modifying these operations represents a capital investment issue, Nauman noted.

And the list of consequences goes on. There are also setbacks in switching from IBCs to drums when it comes to marking and labeling, bung closing and creating tamper-evident sealings. Another really important consequence is that Packaging Group 1 products are not allowed on any means of air transport, which would have a big impact on shipping these goods, Nauman said.

The Industry Reacts

Nauman related that the packaging industry has recognized that the reclassification plan would present significant downstream consequences for all types of packaging and the whole supply chain. Most suppliers agree that the current level of safety for these substances is already significant; therefore, the industry has begun making its case that reclassification of Class 8 materials will not add additional safety benefits, but will most certainly create extra costs.

Late last year, the Criteria for a Workable Solution at the U.N. Level Intercessional Working Group, led by the Netherlands, called for no change in the level of safety for the transport of what would be considered Class 8 goods. The group collectively agreed that the classification criteria for skin corrosives should be consistent between GHS and transport sectors, but decided that transport conditions should not become more severe. In addition, the group held that there should be no direct change in the classifications of GHS categories or packaging group levels for skin corrosive substances. Furthermore, the group said that the solution should not promote animal testing.

The working group presented its requests to the U.N. in June of last year. Currently, it reports that pure chemicals are easier to classify, but that mixtures tend to be more problematic. Nauman said the group is making progress, and will continue reporting its proposed solutions to the U.N.

The Effect on Lubricants

In the lubricants industry, the harmonization among GHS classes and U.S. Department of Transportation, Canadas Transportation of Dangerous Goods and other shipping regulations arent quite so clear-cut, GHS Resources John Howell explained to Lubesn Greases. Based in Bonita Springs, Florida, U.S., Howell said, An untested mixture classified as GHS Class 8 skin corrosive is not automatically a USDOT Packing Group 1 corrosive and, as such, cannot be transported in an IBC. Only testing of the mixture can determine that.

He added, The only way a product can meet the Class 8 Packing Group 1 criteria is if it is tested and found to meet the corrosivity criteria under tests conducted in accordance with the Organization for Economic Cooperation and Development Guideline for the Testing of Chemicals. For example, Howell said, a product that contained 2 to 50 percent caustic soda in a water solution would be classified without testing as a GHS Class 8 skin corrosive. But if that product were tested under OECD guidelines, it would most likely not be considered a USDOT Class 8 Packing Group 1 corrosive.

Howell concluded that, in the world of lubricants, even corrosive raw materials such as 50 percent caustic soda and 45 percent caustic potash are not Packing Group 1, but rather Packing Group 2. Ethanolamine, one of the more corrosive amines, is Packing Group 3, not Packing Group 1.

Lube Report Asia occasionally includes articles originally published in sister publications of LNG Publishing Co. This article originally appeared in the December 2014 issue of LubesnGreases Europe – Middle East – Africa, under the title GHS Brings Costs, Consequences For Packagers.