OSHA HAZARD COMMUNICATION LABELING REQUIREMENTS
By Gary W. Hanson, American Safety and Health Management Consultants, Inc.
With OSHA updating the Hazard Communication standard to include the new Globally Harmonized System (GHS), there have been questions about what will be required on the
labels on containers of hazardous chemicals. Manufacturers and importers will be required to use the new GHS label. This will be a much more detailed label and will provide much better information about the hazards of a chemical, unlike the current requirements. There are 4 new distinct areas on the labels:
- Pictograms- There are nine of these each depicting a different type of hazard
- Single Word- either Danger (meaning the product can be deadly) or Warning (meaning the product is dangerous but not deadly).
- Hazard Statement- a brief statement about the hazard of the chemical.
- Precautionary Statement- This covers the basic steps that can be taken to protect an employee. The statement has to cover 4 areas: Prevention Response, Handing, Storage and Disposal.
In addition, there will be the name of the chemical, the manufacturer’s name, address and telephone number, and supplemental information. The last item is not mandatory.
Companies who don’t manufacture chemicals are also required to ensure all containers of hazardous chemicals are labeled. This includes internal or final use containers. OSHA doesn’t have a recommended approved label. However, OSHA provides leeway in the types of label a company can use for internal or final use containers. Companies can use the new GHS labels if they choose or may choose their own label as long as it provides at least minimal information about the hazards of the chemical and there is more detailed information about the hazards of the chemical immediately available. The SDSs will provide that information but they will need to be readily available to all employees. This will require that Section II of the new SDS be reviewed. This section will list the label requirements.
Two of the current commercial labels the National Fire Prevention Association (NFPA) and the Hazardous Material Identification System (HMIS) labels will still be allowed for internal or final use containers. However, the numeric hazard rating system for the GHS has been revised. Currently, NFPA and HMIS use a 0-4 hazard rating system- 0 means no hazard; 4 means extreme hazard. The GHS rating indicates that 4 is a slight hazard while 1 is an extreme hazard. Needless to say, this has caused a lot of confusion. OSHA has advised that the GHS numeric hazard rating will not be required on GHS labels. Companies that decide to use either the NFPA or HMIS labels will have to review the new SDS to determine the hazards of that particular chemical. They are not to use the numeric hazard for GHS which is found in section II, but continue to use the current rating system. The hazard information needed for the labels can be found in the new SDSs- Section 4- Firefighting Measures; Section 8- Personal Protective Equipment for the HMIS label; Section 10- Physical and Chemical Properties; Section 10- Stability and Reactivity; and Section 11- Toxicology Information.
Companies using either type of label will still need to train their employees in the hazards of the chemicals they use and ensure they understand the difference in the two numeric hazard rating systems. All containers of hazardous chemicals must have a label and SDSs need to be available at the work site for employees. It will be up to each company to determine if their internal labeling policy will meet the required standard.
For more information on this topic, either go to OSHA.gov which has information on the new requirements or call my office at (330) 854-4577.