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HMIS® III - Questions About HMIS® Ratings

 

Frequently Asked Questions

 

Questions About HMIS® Ratings

 


Q:What determines a chemical's HMIS® rating?

A: A chemical rating for health is based on objective criteria inherent to the material, such as its toxicity (oral/dermal LD50, LC50), and its ability to cause skin and eye irritation. The chronic health effects associated with the material are used to determine whether the rating should carry an asterisk (*). In some cases, the final rating may also reflect additional hazards determined through evaluation of chemical exposure, use, and handling information.

Flammability ratings are assigned according to the flash point and boiling point of the material, while Physical Hazard ratings are based on the material's physical characteristics and potential to release violent energy under conditions of fire, water contact, high temperature or pressure, or proximity to activating agents.
 

Q: Are HMIS® labels compliant as product or shipping labels?

A: HMIS® labels are not labels in the usual sense of the term but are tools for Hazcom compliance. OSHA requires manufacturers to label products both in-plant and on products shipped outside the plant. The Department of Transportation (DOT) also imposes certain labeling requirements on shipped products. HMIS® labels are designed for use in-plant by employees who are trained on the system and are not intended for use as shipping or product labels (although under certain conditions they might be included on a shipping or product label if all requirements are otherwise met).
 

Q: Who gives HMIS® ratings to products?

A: The Hazard Communication standard requires employers to evaluate materials and inform employees of the hazards. The HMIS® ratings are an effective means of providing employees with this information. While ultimate responsibility for ratings lies with the employer, many employers ask suppliers to help them rate materials or provide adequate information for the employer to rate the product. The product MSDS is considered a primary source of this information.
 

Q: How do I assign HMIS® numerical ratings (health, flammability, physical hazard) to a product?

A: HMIS® ratings are developed by comparing information on the health hazard, flammability, and physical hazard of the product to a set of criteria for each hazard category. The criteria indicate which numerical rating (0-4) in each category is appropriate for the material. Basing ratings on the inherent properties of the material helps keep ratings more consistent from company to company. However, there are times when it is appropriate to use professional judgement in creating a final rating value.

If the product is a mixture of chemicals, the mixture is evaluated in the same manner as it is during MSDS development. In developing a product’s rating, an employer must consider all ingredients present in concentrations of 1 percent or greater (0.1% if the ingredient is a carcinogen). The hazard rating for the product as a whole will reflect the ingredient with the highest rating, unless there is evidence that the rating should be different. Testing of the mixture as a whole could provide such evidence.
 

Q: How do I assign Personal Protective Equipment (PPE) ratings to a product?

A: The employer who is familiar with the conditions under which the material will be used at the worksite should develop and provide the appropriate PPE ratings. For example, a material used in confined spaces will often call for a more protective level of PPE than one used in a well-ventilated area. Use information from the product MSDS along with knowledge of how the material will be used at the work location. Choose appropriate PPE that will protect the employees from the hazards the material will present under the actual normal conditions of use. For example, if the material is listed as an eye hazard on the label or MSDS, designate eye protection for employees handling the product. HMIS® is not intended for emergency circumstances.
 

Q:Should I assign HMIS® ratings based on the normal or "worst case" hazards or use?

A: HMIS® hazard ratings are based as much as possible on the inherent properties of the material (LD50/LC50, irritant potential, clear evidence of chronic hazards, flashpoint, and potential to undergo uncontrolled reaction). This practice helps standardize the ratings and minimize confusion. However, where professional judgment is necessary to assign a meaningful rating, consider the expected normal conditions of use. HMIS® is not intended for use in emergency situations (see comparison of HMIS® and NFPA®).
 

Q:How can I list the HMIS® hazard rating on the MSDS or container of a product I manufacture or supply?

A: You may list the hazard ratings on the MSDS. Many manufacturers/suppliers choose to do so. If you do, be sure to indicate that it is an HMIS® rating (to avoid confusion) and give some indication of the category for each code (H, F, PH). ACA recommends that PPE codes be determined by the employer, who is most familiar with the actual conditions under which chemicals are used at the work location.

Some MSDSs also contain a brief description of HMIS® for customers who are not familiar with it and wonder about the code. This practice is recommended. The following language would be appropriate:

Caution: HMIS® ratings are based on a 0-4 rating scale, with 0 representing minimal hazards or risks, and 4 representing significant hazards or risks. Although HMIS® ratings are not required on MSDSs under 29 CFR 1910.1200, the preparer may choose to provide them. HMIS® ratings are to be used only in conjunction with a fully implemented HMIS® program by workers who have received appropriate HMIS® training. HMIS® is a registered trade and service mark of the ACA. HMIS® materials may be purchased exclusively from J. J. Keller (800) 327-6868.

The following are some examples of acceptable formats for putting HMIS® ratings on MSDSs:

 

  • HMIS® = H-*3, F-2, PH-0
  • HMIS® Rating H*3/F2/PH0
  • HMIS® H=3*
    F=2
    PH=0
OR HMIS®

HEALTH       *3
FLAMMABILITY 2
Physical Hazard 0
PPE

You may also list the hazard rating on the label as a convenience to your customers. The sample formats described above would be appropriate for that purpose. However, ACA, which developed HMIS®, has protected its intellectual property rights in HMIS® through trade and service mark registration. J.J. Keller & Associates, Inc., is ACA's exclusive licensee for HMIS® products. You may not print colored HMIS® labels. As an alternative, you may have J.J. Keller & Associates, Inc., print your product labels with the colored HMIS® labels or print your own product labels on one of J.J. Keller & Associates, Inc.'s HMIS® stocks.

 

Note 1: If the product will be leaving your facility (transferred, sold), you should recognize that HMIS® ratings are not an acceptable substitute for the required hazard warnings on the product label or MSDS.
 

Q:What should I do if two different suppliers of the same product rate that product differently?

A: 1) Contact both suppliers and confirm that each is using HMIS® rating criteria and not basing their ratings on another system.

2) Ask for an explanation of the basis for giving the product that rating (one supplier may have new information that the other does not yet have).

3) Use the explanation to form your own opinion of which rating is more appropriate for your facility and handling of the product.
 

Q: What does the asterisk (*) mean in HMIS® ratings?

A: The "*" indicates that the rated product is associated with a chronic health effect (i.e., a health effect that may occur after weeks, months, or years of repeated overexposure). The * symbol signals employees to use additional care in handling the material. It also lets them know that more information about the specific chronic hazard is available on the MSDS or manufacturer's product label.
 

Q: Must my HMIS® rating/label indicate the chronic health effects associated with the product or its ingredients?

A: Yes, the HCS requires employers to inform employees of chronic as well as any acute hazards. Use the (*) on the HMIS® label if evidence of a chronic effect is sufficient that you would be required to note that hazard on the product label.
 

Q:What types of health effects are considered "chronic" and when do they trigger use of the (*) in an HMIS® label?

A: A (*) is needed on the HMIS® label when there is clear evidence that exposure to the chemical is associated with an adverse, non-acute health effect, such as cancer, reproductive effects, or injury to a specific organ of the body. To determine whether a (*) is needed, apply the same rules that would be used to determine whether the material would be required, under the HCS, to list an effect of chronic exposure on the manufacturer's product label. See Sections 7.5(A)-(B) and Tables 7.1a, 7.2, and 7.3 in this manual.

For example, a carcinogen (cancer-causing agent) must carry an asterisk (*) on the HMIS® label if the chemical:

  • Has been evaluated by the International Agency for Research on Cancer (IARC) and found to be a carcinogen or potential carcinogen. Note: The OSHA Compliance Directive (CPL 2-2.38C A-25-26 of 1990) indicates that Groups 1 ("agent is carcinogenic in humans") and 2A ("agent is probably carcinogenic in humans") must be noted on both the MSDS and the label, while Group 2B need only be included on the MSDS; or
  • Is listed as a carcinogen or potential carcinogen in the Annual Report on Carcinogens published by the National Toxicology Program (NTP) (latest edition); or
  • Is regulated by OSHA as a carcinogen.
     

Q: How should a known pulmonary sensitizer be rated? The sensitization develops with repeated exposure, but once sensitization has occurred, the effects can appear within hours of exposure.

A: Clearly defined pulmonary sensitizers, such as toluene diisocyanate, should be rated as chronic hazards and should receive the (*) designation because the underlying health effect, the allergy, develops over time. It is important to note that this effect may appear after variable periods of repeated exposure to relatively low concentrations of material. An "overexposure" relative to the Permissible Explosive Limits (PEL) or Threshold Line Values (TLV®) is not always necessary.
 

Q:How should a combustible dust be rated?

A: HMIS® has adopted the OSHA criteria for determining flammability and physical hazards. Information on determining material ratings is located in Chapter 7 of this manual.

Care should be used in the application of flammability and physical hazard ratings to combustible dusts. The explosion hazard potential of a combustible dust is similar to the explosion hazard of flammable liquid vapors or combustible gases. The major difference is that a combustible dust must be put into suspension by some outside mechanism before an explosion can occur, whereas the flammable liquid vapors and combustible gases have their own capability of diffusing with air to provide possible explosive mixtures.

Keep in mind that the HMIS® is intended to provide ratings for normal workplace use, rather than worst-case conditions. Therefore, the HMIS® user should not misapply unnecessarily high flammability ratings to combustible dusts so as to reflect the worst-case scenario. Doing so will confuse the end user and mask the significantly greater hazards of the true fire and explosion potential of materials such as metal powders. HMIS® is intended to reflect the relative hazard of materials.
 

Q:Should the irritant properties of dusts be reflected in the HMIS® health rating?

A: In "Hazard Communication Standard Interpretive Quips,"

OSHA gives the following interpretation regarding "nuisance dusts." "The particles not otherwise regulated are exempt [from the HCS] unless evidence exists that they present a health or physical hazard other than physical irritant effects."

Although this factor may be included at the employer’s discretion, there is no requirement under the HCS to consider irritation due to mechanical abrasion from the physical presence of an otherwise inert particle (i.e. "grit"). However, if the dust causes any health effect other than a "physical irritant effect," the effect must be considered when assigning the HMIS® health rating.

 

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