Safety Data Sheets (SDS)
ICC Compliance Center Writes Science Fiction?

In the 1960’s, an American author by the name of Robert A. Heinlein wrote a science fiction story about a man born and raised on Mars, but as an adult comes to Earth. The title of the novel is “Stranger in a Strange Land”. The plot focuses on the main character adapting and understanding humans – their language, laws and culture.

How does this connect with ICC Compliance Center, Safety Data Sheets (SDS), and labels one might ask? Consider this scenario: a US chemical with its SDS and label end up in a Chinese chemical plant or a Romanian factory. Can the workers in either of those places read it? Can it be understood? Are the workers aware of the hazards or dangers of the chemical? Are these workers safe when using this US chemical?

By using ICC Compliance Center, companies now have the capability to translate an entire SDS or label into any of 40 languages. Granted using a third-party is a possibility for translating specific words and phrases, but that can be expensive given how long SDS documents and labels are under the new GHS regulations. ICC Compliance Center is different, because we allow for flexibility when translating. Since we work per SDS document we’re likely a lower cost than other companies.

Learn about ICC’s full range of compliant SDS services »

One also has to remember the regulations and what they Continue Reading…

OSHA Labeling
Workplace Labels – An Essential Part of Workplace Safety

Nola Murphy’s Story

It was in a soft-drink bottle. It looked like lemonade. But 73-year-old Nola Murphy discovered, after pouring herself a glass, that it wasn’t. In fact, it was a toxic mould-remover that a cleaner had left sitting on a restaurant bar. The cleaner had poured the product from a larger container into the soft drink bottle for easier handling.

Mrs. Murphy was lucky – she survived the experience, although she required emergency hospital treatment. But her story, given in an article in the New Zealand Medical Journal, shows how putting hazardous chemicals in unlabeled containers can be a recipe for disaster. (More: The New Zealand Herald)

Many countries, including the United States and Canada, require hazardous chemicals sold to the workplace to be labeled by the supplier. Regulations such as the U.S. Occupational Safety and Health Act (OSHA), and Canada’s WHMIS (Workplace Hazardous Materials Information System), set out the basic requirements for such labels (called “supplier labels” under WHMIS, and “labels for shipped containers” by OSHA). But as Mrs. Murphy’s experience shows, many hazardous chemicals still end up in unlabeled containers. They may be poured (“decanted”) from larger containers for convenience. The original supplier label may have been damaged or removed. Or two or more chemicals in separate containers may be mixed together to make a new product. No matter how it happens, unlabeled chemicals create a Continue Reading…

7 Health Canada & OSHA FAQs

FAQs Arising from My Attendance at the SCHC Conference

Last week I had the pleasure of attending a Q&A session at the fall session of the SCHC conference. The session included speakers from OSHA and Health Canada. There were a number of great questions, and here are some of those questions and answers that stood out to me.


Are any required pictograms being considered by OSHA for combustible dusts?

This topic is in discussion, but there is definitely an aversion to creating whole new pictograms (i.e., non-current GHS pictograms).


Will there be a Word template (like the old OSHA form 174) provided by OSHA?

Yes, but progress on it is very slow since it is not a priority.


Has there been any progress by OSHA on creating more pictogram precedence rules? Right now if you have an acute toxicity classification requiring a skull and crossbones, you would still have to include the exclamation if you had a STOT SE Category 3 material. The exclamation seems redundant.

There is “some” discussion on this but, more pressure from industry is needed for this discussion to progress further.


Is it okay with OSHA to continue using HMIS/NFPA in a US workplace?

Yes, but you need to make sure training and other information available on the GHS hazards of chemicals used in the workplace is readily available. Also, by 2016, HMIS/NFPA ratings are updated to reflect any “new” GHS Continue Reading…

A Welcome Change to HazCom Labeling

OSHA recently published a brief relating to the new hazardous chemical labeling requirements under the Hazard Communication Standard, 29 CFR 1910.1200 (HCS), which brought the standard into alignment with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

The brief outlines the labeling requirements under the new standard. OSHA also discussed an exciting change, that it intends to make to Appendix C, Allocation Of Label Elements, along with a clarification.

Previously, OSHA did not allow a GHS pictogram to be shown on a shipped container label if it conflicted with the DOT hazmat label. Section C.2.3.3 stated:

“Where a pictogram required by the Department of Transportation under Title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in C.4 for the same hazard shall not appear.”

GHS OSHA HazCom drum label

This statement caused a lot concern for those companies shipping 55 gallon drums and/or smaller containers. Those companies would be forced to have various label designs and train workers to recognize the hazards, even without the pictogram showing (on the drum label due to the 4 x 4 hazmat label). OSHA was petitioned to change the requirement almost immediately after the final rule was published in March of 2012.

In the recent brief, OSHA announced its intent to make the change, allowing the use of both the pictogram and the hazmat label.

“However, Continue Reading…