Posted March 5, 2013
To provide further insight into the label requirements that are part of the revised Hazard Communication standard (HazCom), OSHA released a brief explaining the new label elements and the responsibilities employers have when it comes to maintaining the labels on containers as well as use of other labeling systems. As an added bonus, OSHA also revealed a change that it intends to make to Appendix C, Allocation Of Label Elements, along with a clarification.
The revision OSHA intends to make consists of a change to the wording of Appendix C.2.3.3. Currently, this section states that that the corresponding HazCom pictogram shall not appear. However, DOT does not view the HazCom pictogram as a conflict and for some international trade both pictograms may need to be present on the label. Therefore, OSHA intends to revise C.2.3.3. In the meantime, the agency will allow both DOT and HazCom pictograms for the same hazard on a label. As for the clarification, OSHA says in the brief that “if the employer chooses to use the pictograms that appear in Appendix C on the workplace (or in-plant) labels, these pictograms may have a black border, rather than a red boarder.
As for an explanation of the new label elements, OSHA began by re-emphasizing that chemical manufacturers and importers are required to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged, or marked with the required label by June 1, 2015. Distributors, however, have until December 1, 2015 to comply. Although there is no required format for how a workplace label must look and no particular format an employer has to use, there are required elements. These consist of the following:
- Name, address and telephone number of the chemical manufacturer, importer or other responsible party.
- Product identifier, which is how the hazardous chemical is identified.
- Signal words, which are used to indicate the relative level of severity of the hazard and alert the reader to a potential hazard on the label.
- Hazard statement(s), which describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
- Precautionary statement(s), which describe recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling.
- Pictogram(s), which are graphic symbols used to communicate specific information about the hazards of a chemical.
- Supplementary information, which is any additional instructions or information that the label producer deems helpful.
To read the OSHA Brief, titled Hazard Communication Standard: Labels and Pictograms, visit OSHA’s publications page.
- GHS Information
- Hazard Communication Plan Template
- NFPA Diamond
- Hazard Communication: MSDS Content and Format ANSI
- Hazard Communication: MSDS Content and Format OSHA