Fire Codes and the GHS

Part 1: Is the GHS coming to the 2027 International Fire Code?

A collection of proposed fire code amendments could help ease the 30-year struggle to classify hazardous materials correctly for fire and building codes.

The proposals made in April at the International Code Council’s (ICC) Group A Committee Action Hearings in Orlando would incorporate the GHS (Rev 7) classifications into the hazardous material definitions in the International Fire Code (IFC) and International Building Code (IBC). This would allow one to more easily classify or verify a material’s classification by referring to its Safety Data Sheet (SDS).

Code officials have little time to verify hazard classes of materials, and navigating multiple classification systems can be complex and introduce errors. A more accessible and accurate way to verify random samples of the classifications provided by facility operators and consultants is sorely needed.

This article is the first in a series highlighting the similarities and differences between the physical and health hazard categories in the GHS and model fire and building codes. The goal is to help users navigate between the two systems now, prevent any overwhelm, and make the transition straightforward if the code change proposals are ultimately approved for adoption in the 2027 IFC.

Warning symbol set of GHS Danger icons Physical hazards signs. Explosive Flammable Oxidizing Compressed Gas Corrosive toxic Harmful Health hazard Corrosive Environmental hazard.

What is the GHS?

The GHS is the Globally Harmonized System of Classification and Labelling of Chemicals. It’s developed, published and updated every two years by the United Nations “Committee of Experts on the Transport of Dangerous Goods and on the Globally Harmonized System of Classification and Labelling of Chemicals”. Often referred to as the ‘Purple Book’, the GHS provides a method to uniformly communicate a material’s physical, health, and environmental hazards.

Over 83 countries have either adopted or are adopting the GHS classification system to help identify chemicals and safeguard human health and the environment.

In the GHS, physical hazards are evaluated using test methods found in the UN Manual of Tests and Criteria. Health hazards, including acute toxicity studies, can be assessed or estimated using methods outlined by the Organization of Economic Co-Operation and Development (OECD). These widely accepted test methods would help remove much of the ambiguity and subjectivity surrounding some IFC hazard class definitions.

Over the last ten years, the EPA, DOT, and OSHA have all incorporated the GHS into their regulatory and reporting programs. While they may not be fully aligned yet, the horizon for doing so is not far off. In fact, the OSHA’s Final Rule to update the Hazard Communication Standard to GHS Rev 7 was published on May 20, 2024, and takes effect on July 19, 2024.

Why is hazard classification important?

Fire and building codes prescribe the fire and life safety features and controls in buildings and at facilities to prevent and mitigate emergencies involving hazardous materials. They are unique from other regulations in that the quantities and hazards presented by materials in the building are used to help define a building’s occupancy class. Among other things, the occupancy class affects property line setbacks, allowable heights and areas and building construction types. That makes proper hazard classification a critical step in safeguarding the public and firefighters.

Firemen using water from hose for fire fighting at firefight training of insurance group. Firefighter wearing a fire suit for safety under the danger case.

Doesn’t IFC Appendix E104 solve the problem?

The IFC and GHS Hazard Definition Comparison Table (Table E104.2) introduced in the 2024 IFC allows users to readily compare an IFC hazard class with the most similar GHS hazard class and category. It’s a valuable resource and a good starting point when the hazard classes found in the SDS are the best available information. However, the Table does not intend to imply that the hazard classes are fully aligned. In many cases, additional research and data are needed to determine the correct IFC hazard class.

What’s next?

You can view the proposed GHS-related code changes and all the proposed amendments to the 2024 IFC here. Public comments to these proposals are due to ICC by July 8, 2024, and will be heard at the second ICC Group A Committee Action Hearing scheduled for October 2024. The Public Comment Hearing in April 2026 and ICC’s voting members will ultimately decide if the GHS classification system will help define material hazard classes in the IFC in the future.

Check back here over the next several months; we’ll be highlighting the similarities and differences between the individual IFC and GHS hazardous classes and categories to help you use the 2024 IFC Table E104 effectively. You can also subscribe to the Hazmat Halftime newsletter to stay updated.