Definition
The Hazardous Supplies Identification System, HMIS®, was developed by the Nationwide Paint & Coatings Affiliation (NPCA), now often called the American Coatings Affiliation (ACA), to assist employers adjust to OSHA’s Hazard Communication (HCS), 29 CFR 1910.1200.
The present HMIS® III model makes use of coloured bars, numbers and symbols to convey the hazards of chemical substances used within the office. See beneath for an evidence of the system.
Alas, this non-obligatory system is proprietary and the ACA has apparently awarded unique rights for HMIS® services and products to a handful of distributors. The implementation handbook alone prices $299.00 USD; in distinction OSHA’s obligatory GHS labeling system is open and freely obtainable – anybody can print or promote their very own labels. In our opinion, the thought of charging to be used of a labeling system is completely unacceptable and runs counter to the facile dissemination of well being and security info. Extra importantly, as a result of the HMIS® numeric hazard rating scale is the reverse of the one which OSHA legally requires beneath HCS 2012, the possibility of employee confusion, conceivably with deadly penalties, is kind of excessive. For these and extra causes, we strongly discourage use of the HMIS® system.
Actually, that $299.00 ACA implementation handbook has an whole chapter devoted explaining easy methods to convert the OSHA-required GHS labeling system to proprietary and non-mandatory HMIS® labels. Why on earth would anybody wish to require their staff to study an extra and complicated proprietary system after they have already complied with OSHA labeling necessities utilizing a system that’s accepted worldwide? As security professionals, this makes our heads spin. Let’s ask one other query – why is a company that offers solely with paints and coatings making an attempt to carry itself up as some kind of authority on a system customers might attempt to apply to over 159 million identified chemical substances, most of which the ACA has zero expertise with?
Observe the next:
Extra Information
At first look, the HMIS® and NFPA labeling methods seem fairly related. Each have 4 sections coloured blue, purple, yellow and white. HMIS® makes use of coloured bars, whereas NFPA makes use of coloured diamonds. HMIS® makes an attempt to convey full well being warning info to all staff whereas NFPA is supposed primarily for hearth fighters and different emergency responders. Key level: HMIS® is just not supposed for emergency circumstances.
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Some employers use hybrids of the 2 methods. For instance, they may use an NFPA hazard diamond, however the white part is used to indicate each private protecting gear (PPE) and/or particular hazards. The ACA and NFPA each discourage the blending of the 2 methods on this method. OSHA permits one to make use of any labeling system so long as it meets their labeling efficiency necessities. Thus, in case you use a hybrid system at your location, your staff should be correctly educated in utilizing it and be made conscious of those potential conflicts.
HMIS® labels can seem in quite a lot of codecs. Some will embody extra areas to record goal organ results, a labeling requirement beneath 29 CFR 1910.1200, and different info, however the 4 coloured areas proven right here will at all times be current.
An older type HMIS® label is proven beneath on the left. Within the April 2002 launch of HMIS® III, the yellow Reactivity part was changed with an orange Bodily Hazard part as proven beneath on the fitting. Different points of the system had been additionally modified (see beneath).
ACA recommends upgrading your older HMIS labels.
SDS Relevance
Particular sections of an HMIS® label embody the next:
| Well being | |
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The Well being part conveys the well being hazards of the fabric. Within the newest model of HMIS®, the blue Well being bar has two areas, one for an asterisk and one for a numeric hazard ranking.
If current, the asterisk signifies a power well being hazard, that means that long-term publicity to the fabric may trigger a well being drawback comparable to emphysema or kidney injury. NFPA lacks this essential info as a result of the NFPA system is supposed just for emergency or acute (short-term) exposures.
In keeping with ACA, the numeric hazard evaluation process is completely different than that utilized by NFPA. Listed below are the numeric well being rankings for the HMIS system: |
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| 4 |
Life-threatening, main or everlasting injury might outcome from single or repeated overexposures. |
| 3 |
Main harm doubtless except immediate motion is taken and medical therapy is given. |
| 2 |
Momentary or minor harm might happen. |
| 1 |
Irritation or minor reversible harm doable. |
| 0 |
No important threat to well being.
|
| Flammability | |
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For HMIS® I and II, the factors used to assign numeric values (0 = low hazard to 4 = excessive hazard) are equivalent to these utilized by NFPA. In different phrases, in this class, the methods are equivalent.
For HMIS® III, the flammability standards are outlined in accordance with OSHA requirements:
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| 4 |
Flammable gases, or very risky flammable liquids with flash factors beneath 73 °F, and boiling factors beneath 100 F. Supplies might ignite spontaneously with air. (Class IA). |
| 3 |
Supplies able to ignition beneath nearly all regular temperature situations. Consists of flammable liquids with flash factors beneath 73 °F and boiling factors above 100 °F, in addition to liquids with flash factors between 73 °F and 100 °F. (Lessons IB & IC). |
| 2 |
Supplies which should be reasonably heated or uncovered to excessive ambient temperatures earlier than ignition will happen. Consists of liquids having a flash level at or above 100 °F however beneath 200 °F. (Lessons II & IIIA). |
| 1 |
Supplies that should be preheated earlier than ignition will happen. Consists of liquids, solids and semi solids having a flash level above 200 °F. (Class IIIB). |
| 0 |
Supplies that won’t burn. |
| Reactivity (HMIS® I and II – now out of date) | |
|
The standards used to assign numeric values (0 = low hazard to 4 = excessive hazard) had been equivalent to these utilized by NFPA. In different phrases, in this class, the methods had been equivalent.
This model is now out of date. The yellow part has been changed with an orange part titled Bodily Hazards – see the following part for extra info.
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| Bodily Hazard (HMIS® III) | |
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Reactivity hazards are assessed utilizing the OSHA criterion of bodily hazard. Seven such hazard courses are acknowledged:
This model replaces the now-obsolete yellow part titled Reactivity – see the earlier part for extra info. As with the Well being and Flammability sections, the extent of hazard is indicated utilizing numeric values (0 = low hazard to 4 = excessive hazard)
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| 4 |
Supplies which are readily able to explosive water response, detonation or explosive decomposition, polymerization, or self-reaction at regular temperature and stress. |
| 3 |
Supplies which will type explosive mixtures with water and are able to detonation or explosive response within the presence of a powerful initiating supply. Supplies might polymerize, decompose, self-react, or endure different chemical change at regular temperature and stress with reasonable threat of explosion. |
| 2 |
Supplies which are unstable and should endure violent chemical adjustments at regular temperature and stress with low threat for explosion. Supplies might react violently with water or type peroxides upon publicity to air. |
| 1 |
Supplies which are usually steady however can change into unstable (self-react) at excessive temperatures and pressures. Supplies might react non-violently with water or endure hazardous polymerization within the absence of inhibitors. |
| 0 |
Supplies which are usually steady, even beneath hearth situations, and can not react with water, polymerize, decompose , condense, or self-react. Non-explosives. |
| Private Safety |
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That is by far the biggest space of distinction between the NFPA and HMIS® methods. Within the NFPA system, the white space is used to convey particular hazards whereas HMIS® makes use of the white part to point what private protecting gear (PPE) ought to be used when working with the fabric.
The ACA particularly recommends that “preparers of MSDSs shouldn’t place HMIS® PPE designation codes on the MSDSs or labels that depart the ability, as they have no idea the situations beneath which their prospects use these merchandise.” Nevertheless, these nonetheless flip up on some SDS’s.
HMIS® makes use of a letter coding system for this part. We at ILPI discover this unacceptable as a result of we might moderately see the PPE listed explicitly as an alternative of getting staff attempt to bear in mind a bunch of codes or seek the advice of a chart, one thing that might result in confusion and/or a deadly accident. Likewise, the “customized codes” facet is especially harmful for guests and contractors who might not bear in mind/acknowledge that these may fluctuate from job website to job website.
Observe: A number of the letters/symbols used on this desk are additionally used as TSCA, CHIP, and/or DoD HMIRS/HCC codes, all of which have fully completely different meanings and functions! Say, did we inform you we dislike code methods?
We current the lettering scheme right here, together with a sequence of graphics meant to bolster the that means of every letter:
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NOTE: NFPA and different labeling codes (comparable to HMIS®) are NOT required by OSHA. OSHA has mentioned “…OSHA doesn’t endorse particular providers or merchandise. It could, subsequently, be inappropriate for OSHA to require a selected labeling system’s code on the fabric security information sheet.” (see this official OSHA interpretation). OSHA does have particular labeling necessities that should be fulfilled, and the hazard classifications which are required run fully counter to the now-obsolete HMIS® III sytem.
SDS Relevance
Demystify arcane labeling methods with security posters from Security Emporium.
Some producers embody HMIS info on their SDS’s, however there has by no means been an OSHA requirement for them achieve this.
There are a variety of copycat HMIS® methods on the market to get across the proprietary points. They’ve very related wording on the label and name themselves one thing barely completely different. For instance, you would possibly see HMIG (Hazardous Materials Info Information) or HMCIS (Hazardous Supplies Classification Info System). These might use the older instability vs reactive header within the yellow part, diamonds for the blanks as an alternative of packing containers, and different little nuances that differ from an HMIS® label. Once more, it is the absurdity of a proprietary label system that results in this type of nonsense.
OSHA’s adoption of the Globally Harmonized System (GHS) as a part of the 2012 revision of the Hazard Communication Normal (29 CFR 1910.1200) modified container labeling necessities to incorporate particular parts together with pictograms, hazard statements, precautionary statements and a sign phrase. This harmonized labeling system has made HMIS® all however out of date or redundant. Nevertheless, non-mandatory NFPA 704 info remains to be good to have as state or native hearth codes might require 704 signage on tanks, doorways and different office areas.
In a 2013 interpretation letter, OSHA confirmed that SDS authors might embody HMIS and NFPA scores in Part 2 of the SDS “as long as the scores within the HMIS label don’t contradict or solid doubt on the validity of label info required by HCS 2012 (C.3.1) or impede the person’s capability to establish the knowledge required by HCS 2012 (C.3.2)“.
We’ve got emphasised the final a part of that assertion. On condition that HMIS ranks 1 as low and 4 as excessive hazard whereas the HCS ranks 1 as excessive and 4 as low, it appears exceedingly doubtless that even educated staff shall be confused if each methods are in simultaneous use, notably at multi-employer workplaces. For instance, utilizing the 2 methods on the similar time may end in a label with an HMIS® flammability ranking of 4 however a (required) GHS flammability classification of 1 on the identical label! Due to this fact, we strongly discourage employers from utilizing the HMIS® system given the potential for confusion with the obligatory OSHA hazard classification and categorization system.
Additional Studying
See additionally: flamable, flammable, well being hazard, smoke
Extra definitions Google and OneLook.
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