Because GHS conversion focuses heavily on chemical hazard classification, your company is expected to disclose its formulas to its GHS SDS conversion provider. Having the formulas is essential, given that GHS hazard classification depends on this and this alone, and therefore a GHS SDS cannot be completed in full if you cannot provide your conversion service with a list of your product’s constituent chemicals and their relative percentages. But do you really have to report your ENTIRE formula?
The answer depends on the makeup of your product. The chemical reporting cutoffs vary by hazard classification, which means that concentrations at which chemicals must be reported (included in the formula you provide) differ across the board.
Chemicals that must be reported at concentrations ≥0.1% are:
- Respiratory/skin sensitization
- Germ cell mutagenicity (category 1)
- Carcinogenicity, and
- Reproductive toxicity
Chemicals that must be reported at concentrations ≥1% are:
- Acute toxicity
- Skin corrosion/irritation
- Serious eye damage/eye irritation
- Germ cell mutagenicity (category 2)
- Specific target organ toxicity (single exposure)
- Specific target organ toxicity (repeated exposure), and
- Those that are hazardous to the aquatic environment.
Aspiration hazards in Categories 1 and 2 do not need to be reported at concentrations below 10%, though they have additional specifications.
- Aspiration hazard (Category 1): ≥10% of Category 1 ingredient(s) and kinematic viscosity > 20.5mm 2/s at 40˚C
- Aspiration hazard (Category 2): ≥10% of Category 2 ingredient(s) and kinematic viscosity > 14 mm 2/s at 40˚C
Most chemicals fall under the ≥1% reporting cut-off, but there are still several exceptions. To be safe, your best option is to provide your GHS SDS conversion service with your full formula, in order to reduce delays and/or make sure that your SDSs are created with the highest level of accuracy.
