As of now we should all know or have at least heard that OSHA adopted the hazardous chemical labeling requirements in the latest revision of the Hazard Communication Standard. By aligning with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals or GHS, OSHA helps ensure uniformity in the labeling of chemicals. These updates will provide workers with better information on safe handling and usage of hazardous chemicals. Therefore, providing a systematic approach for avoidance and exposures to hazardous chemicals, reducing injuries and illness through worker awareness.
The upcoming June 1, 2015 effective date, manufacturers, importers and distributors can maintain compliance with the requirements of HazCom 1994 or the revised standard. However, manufacturers, importers, and distributors may start using the new labeling system in the revised Hazard Communication Standard (HCS) before the June 1, 2015 effective date. Hazardous chemicals shipped after June 1, 2015, are required to be labeled with the identified elements including pictograms, signal words, hazard statements and precautionary statements. Distributors have until December 1, 2015 to ship containers labeled by manufacturers or importers in compliance with the HazCom 1994, after which it is required to comply with the HazCom 2012.
According to the revised standard the required information regarding chemical hazards must be communicated on labels using visual cues for awareness to the users. Labels, defined in the HCS, are an appropriate group of written, printed or graphic informational elements concerning a hazardous chemical that are affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging. They must also communicate instructions on safe handling of the chemical so that users are aware of precautions to take in protecting themselves from incident.
Chemical manufacturers, importers, or distributors are to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following information: product identifier; signal word; hazard statement(s); precautionary statement(s); and pictogram(s); and name, address and telephone number of the chemical manufacturer, importer, or other responsible party.
The HCS now requires the following label elements on hazardous chemical labels:
- Name, Address and Telephone Number – of the chemical manufacturer, importer or other responsible party
- Product Identifier – hazardous chemical identification in the form of the chemical name, code number or batch number. The same product identifier must be both on the label and in section 1 of the SDS
- Signal Words – indicates the level of severity of a hazard. There are only two words used as signal words, “Danger” and “Warning
- Pictograms – graphic symbols used to communicate specific information about the hazards of a chemical. The required pictograms consist of a red square frame set at a point with a black hazard symbol on a white background
- Hazard Statements – is a statement that describes the main hazard of a GHS-classified substance or mixture. (i.e. “Causes damage to liver through prolonged or repeated exposure when absorbed through the skin.”)
- Precautionary Statements – describes measures that should be taken to prevent effects from exposure to a hazardous chemical or improper storage or handling. There are four types of precautionary statements: prevention; response; storage; and disposal. (ie. “Do not breathe gas/mist/vapors/spray. Get medical advice/attention if you feel unwell. Dispose of contents/container in accordance with local/regional/national and international regulations.”)
- Supplementary Information – if an employer decides to include additional information on the label regarding the chemical that is considered useful, it can be done. This would be to provide additional instructions or information would go under “supplementary information.”
In regards to HCS labels, there is not a required format for how workplace labels must look. Of course, labels cannot contradict or diminish the required information. It is the responsibility of the employers to maintain the labels on the containers. Meaning that labels must be on chemical containers in a way that is legible and to include pertinent information, it cannot be defaced or removed in any way. Employers can create their own workplace labels; by using all of the required information from the chemical manufacturer label.
Trust the experts! Do you have any questions regarding the transition periods for GHS, GHS label text, software, or other products? Labeling questions? Contact ICC Compliance Center here at 888-442-9628 (U.S.) or 888-977-4834 (Canada), and ask for one of our regulatory specialists.