GHS Classification Guidance for the Japanese Government

For example, paraformaldehyde (UN-3242*Class 4.1, Packing Group II) shall be flammable
solids・Category 2 in GHS classification. Since it is not classified in the higher precedence class
4.2、4.3, it shall be labeled "Not classified" with regard to pyrophoric substances and substances
and mixtures which emit flammable gases upon contact with water. For oxidizing solids(Division
5.1), since Packing GroupⅠ takes precedence, it is not relevant. Since, however, Packing Group
II and III have lower precedence, test results in TDG classification can not be estimated.
Accordingly, based on TDG classification alone, it shall fall under “Classification not possible”
with regard to oxidizing solids.(In light of its chemical structure, oxygen binds to carbon and
hydrogen only, and so it shall be “not applicable”.)
In case of zirconium nitrate(UN-2728・Division 5.1, Packing Group III), all of Class 4 takes
precedence, its GHS classification shall be “Not classified” for Flammable Solids, Self-heating
Substances and Mixtures, and Substances and mixtures which,in contact with water,emit
flammable gases.
○ Utilization of subsidiary hazards
If a TDG classification includes a subsidiary class, classification may be performed by utilizing
the table of the Dangerous Goods Regulations, Annex 1, Recital 3. Care must be taken, however,
because the Packing Group does not indicate the level of subsidiary hazard.
For example, ethyl chloroacetate(UN-1181・Class 6.1, Subsidiary Class 3, Packing Group
II )is estimated to be GHS Category 3 for Flammable Liquids.(If its Category were 1 or 2, it
would be classified as Packing Group I or II and would take precedence over Toxic Substances. It
would hence be classified as Class 3 and Subsidiary Class 6.1. If it were GHS Category 4, it
would be classified as “not a Dangerous Good in transport”.)
On the other hand, in case of morpholine(UN-2054・Class 8、Subsidiary Class 3, Packing
Group I ), since, if its GHS Category is 2 or 3, it takes precedence over Flammable Liquids, it can
not be classified based on TDG classification alone.
(Depending on its flashing point of 37℃, it shall be Category 3.)
(4) Judgment of “Classification not possible”
As described above, a substance which is classified as neither “Not applicable” nor “Not
classified” based on its state, chemical composition, chemical properties, etc., and can not be
classified based on literature data and TDG classification shall be designated as “Classification
not possible” since there is no data that should serve as the grounds for classification. Table 2-5
shows example entries for the grounds for classifying a substance as “Classification not possible”.
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