Sometimes, regulations don’t give us all the answers we need. For example, many people are confused about the labelling requirements found in the Hazard Communication Standard (HCS) of Part 1910.1200 of the Occupational Safety and Health Act (OSHA). This section tells us that we must label all “shipped containers” that contain hazardous substances destined for workplace use. But what exactly is the “shipped container,” when you have inner containers inside an outer one?
The simplest form of “shipped container” is a single packaging. This is a packaging such as a drum or bag, with no inner containers. Such a packaging must be labeled according to the HCS, if the product is hazardous and is intended for a U.S. workplace. If the product is also regulated as a hazardous material for transport according to the Department of Transportation (DOT), then we must also display DOT labels and marks as required by 49 CFR.
However, it gets murkier when we look at combination packagings. These packagings consist of an outer packaging as well as one or more inner packagings. In a transportation sense, both the inner and outer packagings are “shipped.” But are they “shipped containers”?
The answer to this question isn’t found directly in the HCS. Instead, OSHA has issued interpretations that provide guidance here and here. (Note that one of these interpretations was issued long before the current rules, known as Hazcom Continue Reading…