GHS and As-Presented Product Rules: Applying Hazard Inversion to the Classification Process

Donald Ewert, IH Moderator
RJ Lee Group
Monroeville, PA 
United States of America
Donald Ewert, IH Presenter
RJ Lee Group
Monroeville, PA 
United States of America
Wed, 9/11: 1:30 PM  - 3:00 PM 
Deep Dive Session 
Greater Columbus Convention Center 
Room: A 216 


While authors generally understand the ingredient basis for creating effective Safety Data Sheets, few go beyond this initial level to evaluate final as-presented product toxicology and its potential for reclassification. In this session, we will provide attendees with an overview and discussion of successful final mixture approaches to bioavailability and hazard inversion.

We'll intermingle an overview of exemptions to GHS classification with real-world examples of the hazard reclassification process. In addition to engaging attendees in evaluating their own as-presented product scenarios, we will provide participants with a wide-range of recent case studies and real-world examples of hazard inversion success. Attendees will not only gain insight into the flexibility of GHS and Prop 65 rules, they will acquire the tools needed to apply these practices on their own.

Learning Objectives

At the end of this session, attendees will be able to:

1. Summarize UN-GHS and Prop-65 rules for hazard classification and, based on these regulations, learn of the numerous exemptions available for reclassification of their as-presented products

2. Recall the analytical methods available for product characterization and demonstrate how these can be used to assess their own materials and to derive an accurate estimate of bioavailability involving those hazardous components which exist in their materials

3. Determine bioavailability and how this factor alone can be used to overcome hazard classification and labeling under UN-GHS and Prop-65 

Learning/Experience Level



Hazard Communication