Course 606 - Hazard Communication for the Employee

Safety guides and audits to make your job as a safety professional easier
primary container
Shipping and manufacturing containers need “primary” labels.
stationary container
Stationary container labels are found on large, fixed tanks.

Container Labeling

Types of Containers

Container labeling can be a very effective method to communicate the physical and health hazards of chemicals used in the workplace. The information on a container label will vary depending on what type of container it is and how it is used. We'll discuss labeling requirements under the old HCS 1994 and the new HCS 2012 (often referred to as GHS) labeling requirements in this module.

We'll take a look at the labeling requirements for each type of container referred to in the hazard communication standard. The various types of container labels that will be discussed include:

  • Primary (Shipped) container labels are found on the shipping containers and containers received for use.
  • Secondary (Workplace) container labels are found on employer containers, such as a smaller container used to store a chemical. For example, a spray bottle containing a chemical used during a manufacturing process would be a secondary container.
  • Stationary container labels are typically found on large, fixed tanks. These containers cannot be readily moved and may be secured in place.
  • Portable containers are used to transfer a chemical from one location to another to be used immediately. Portable containers cannot be used to store chemicals. Portable containers are not required to have a label. For example, a beaker used to transfer a chemical from the secondary container to a workbench for immediate use does not require a label.

HCS Container Labeling

OSHA is allowing a phase-in period for the new HCS 2012. As of December 1st, 2013, all employees should be trained on the new label elements and safety data sheet (SDS) format. Beginning June 1st, 2016, employers should update alternative workplace labeling and the hazard communication program as necessary. They should also provide additional employee training for newly identified physical or health hazards.

During the phase-in period, employers may comply with either the existing HCS 1994, the revised HCS 2012, or both. OSHA recognizes that hazard communication programs will go through a period of time when labels and MSDSs/SDSs under both standards will be present in the workplace. This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.

Primary Container Labels

The HCS 1994 Primary Container Label Requirements

Most containers shipped directly from the manufacturer or purchased from a distributor are called shipped or primary containers. Labeling information on these containers is usually adequate in communicating the hazards of the chemical. Under the old HCS 1994, the chemical manufacturer, importer, or distributor must ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following three elements of information:

caution sign
  • identity of the hazardous chemical(s)
  • appropriate hazard warnings (including target organ effects of the hazardous chemical)
  • name and address of the chemical manufacturer, importer, or other responsible party

It's important to understand the hazard warning must convey both the particular physical and health hazards of the chemical, including target organ effects. Employees exposed to health hazards must be apprised of both changes in body functions and the signs and symptoms that may occur to signal those changes.

Statements such as "Hazardous if Inhaled," "Caution," or "Danger," are precautionary statements and are not to be considered appropriate hazard warnings. If, when inhaled, a chemical causes lung damage, then the appropriate warning is "may cause lung damage."

Primary Container Labels (Continued)

The HCS 2012 Shipped - Primary Container Label Requirements

Under the new HSC 2012, labels on primary containers shipped from manufacturers or distributors, the container must be labeled, tagged or marked with the following six items:

Product Identifier

  • A product identifier means the name or number used for a hazardous product on a label or in the SDS. It provides a unique means by which the product user can identify the substance or mixture within the particular use setting (e.g. transport, consumer or workplace).
  • A product identifier should be used and it should match the product identifier used on the SDS. If the material is a mixture of two or more compounds and it is covered by UN Model regulations for transport of dangerous goods, UN proper shipping name should also appear on package.
  • The label for a substance should include the chemical identity of the substance (name as determined by IUPAC, ISO, CAS or technical name). For mixtures and alloys, the label should include chemical identities of all ingredients or alloying elements that contribute to the following:
    • acute toxicity
    • skin corrosion or serious eye damage
    • germ cell mutagenicity, carcinogenicity, reproductive toxicity, skin or respiratory sensitization, or specific target organ toxicity (STOT)
  • Where a substance or mixture is supplied exclusively for workplace use, a competent authority may choose to give the suppliers discretion to include chemical identities on the SDS, in lieu of including them on labels.
  • The competent authority rules for “Confidential Business Information” (CBI) take priority over the rules for product identification. The meeting criterion for CBI does not have to be included on the label.

Signal Words

  • Words used to indicate the relative level of severity of hazard. They alert the reader to a potential hazard on the label. Signal words used in GHS are "Danger" and "Warning." “Danger” is for the more severe hazard categories, while “Warning” is used for less severe hazards. Signal words are assigned to each hazard category.

Hazard Statements

  • A phrase assigned to a hazard class and category that describes the nature of the hazards of a hazardous product, including, when appropriate, the degree of the hazard. For example, “Fatal if swallowed” could be used as a hazard statement.
  • Hazard statement and code: Hazard statement codes are intended to be used for reference purposes: they are not part of the text and should not be used to replace it.

Primary Container Labels (Continued)

The HCS 2012 Shipped - Primary Container Label Requirements (Continued)

pictogram
HCS Pictogram and Label Examples

Pictograms

Pictogram means a graphical composition that may include a symbol plus other elements, such as a border, background pattern or color that conveys specific information. See the pictograms on the right.

Precautionary Statements

  • Phrase (and/or pictogram) that describes the recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous product. GHS label should include appropriate precautionary information, the choice of which belongs to the labeler or competent authority.
  • Precautionary codes are used to uniquely identify precautionary statements and are for reference purposes: they are not part of the precautionary text and should not be used to replace it.

Supplier Identification

The name, address, and telephone number of the manufacturer or supplier of the substance or mixture should be provided on the label.

Sample HCS 2012 Primary Container Label

pictogram
Sample Primary Container Label
(Click to enlarge)

The new GHS (HCS 2012) primary container label on the right provides much more information than the old HCS 1994 primary container label.

This label is intended to be an immediate visual reminder of the hazards of a chemical. However, it isn't necessary to list every hazard of the chemical on the label. The safety data sheet (SDS) is used for this purpose. Manufacturers, importers, and distributors will have to assess the evidence regarding the product's hazards. They must also consider exposures under normal conditions of use or in foreseeable emergencies when evaluating what hazards are listed on the label. This is not to say that only acute hazards are to be listed on the label, or that well-substantiated hazards should be left off the label because they appear on the data sheet.

Workplace or Secondary Container Labeling

pictogram
Employers can use their own containers to store smaller quantities of chemicals.

Most employers use the primary containers they purchase to store and use chemicals. However, they may also use their own containers such as coffee cans, drums, plastic jugs, spray bottles, etc. to store and use smaller quantities of chemicals they purchase. These are called workplace or secondary containers.

The employer must ensure that each workplace or secondary container of hazardous chemicals in the workplace is labeled, tagged or marked with either:

  • The information required on shipped container labels; or,
  • Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.

Bottom line, the employer must ensure that employees still get all of the hazard information from the elements of the hazard communication program implemented in their workplaces that they would have gotten from a shipping label. To do this, the employer should conduct additional training, discuss SDS information, use signs, process sheets, or other types of warnings to supplement the secondary label information.

Alternative Labeling Methods

Both the HCS 1994 and 2012 recognize and allow the use of alternative in-plant labeling systems such as the HMIS (Hazardous Materials Information System), NFPA (National Fire Protection Association), and others which may be used in industry as long as they convey the required information. These alternative systems use color, numbers and other information to convey the hazards of the chemical.

The key to evaluating the effectiveness of any alternative labeling method is to determine whether employees can correlate the visual warning on the in-plant container with the applicable chemical and its appropriate hazard warnings. The alternative labeling system must also be readily accessible to all employees in their work area throughout each work shift.

For purposes of this provision, the term "other such written materials" does not include safety data sheets used in lieu of labels.

Stationary Process Container Labeling

stationary container
Storage tanks are a good examples of stationary containers.

Stationary process containers are, obviously, stationary. Storage tanks are good examples. The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required on secondary containers. The written materials must be readily accessible to the employees in their work area throughout each work shift.

Portable Container Labeling

Portable containers are used to transfer hazardous chemicals from labeled containers, and are intended only for the immediate use by the employee who performs the transfer. The employer is not required to label portable containers. Drugs which are dispensed by a pharmacy to a health care provider for direct administration to a patient are exempted from labeling.

Labeling Solid Materials

The label may be transmitted with the initial shipment itself, or with the material safety data sheet that is to be provided prior to or at the time of the first shipment. This exception to requiring labels on every container of hazardous chemicals is only for the solid material itself, and does not apply to hazardous chemicals used in conjunction with, or known to be present with, the material and to which employees handling the items in transit may be exposed (for example, cutting fluids or pesticides in grains). For example, treated lumber is covered since the lumber is not completely cured at the time of shipment and the hazardous chemical will, to a varying degree, offgas during shipment and be available for exposure to employees.

If the hazardous chemical is regulated by OSHA in a substance-specific health standard, the chemical manufacturer, importer, distributor, or employer must ensure the labels or other forms of warning used are in accordance with the requirements of that standard.

Other Important Labeling Requirements

Labels are useless unless they accurately communicate the hazards of their associated chemicals. It's important to keep labels in good condition at all times. The employer must not remove or deface existing labels on incoming containers of hazardous chemicals, unless the container is immediately marked with the required information.

The employer must ensure that labels or other forms of warning are:

  • Legible in English
  • prominently displayed on the container
  • readily available in the work area throughout each work shift

Employers having non-English speaking employees may add the information in their native language to the material presented, as long as the information is presented in English as well.

HCS 2012 Pictogram Requirements

Pictogram
The HCS 2012 requires GHS pictograms on labels.
(Click to enlarge)
chemicals
Employees must be protected in the event of a spill or leak of a hazardous chemical from a sealed container.

As of June 1, 2015, the HCS 2012 will require GHS pictograms on labels to alert users of the chemical hazards to which they may be exposed. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s). The pictogram on the label is determined by the chemical hazard classification.

Employees Handling Chemicals in Sealed Containers

In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use (such as are found in marine cargo handling, warehousing, or retail sales), employers must:

  • ensure labels on incoming containers of hazardous chemicals are not removed or defaced
  • maintain copies of any safety data sheets that are received with incoming shipments of the sealed containers of hazardous chemicals
  • obtain a safety data sheet as soon as possible if sealed containers do not have safety data sheets
  • ensure the safety data sheets are readily accessible during each work shift
  • provide appropriate information and training about the hazards of the chemicals employees use
  • protect employees in the event of a spill or leak of a hazardous chemical from a sealed container

Comply with the GHS of Classification and Labeling of Chemicals

Instructions

Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the module content, but only focuses on key concepts and ideas.

Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you do not answer all the questions, you will receive an error message.

Good luck!

1. Under the new HCS 2012 guidelines, _____ labels are found on manufacturing or shipping containers.

2. Under the new HCS 2012 guidelines, when do employers need to start updating alternative workplace labeling and hazard communication programs and provide additional employee training?

3. Labels on primary containers will need to be labeled, tagged or marked with _____.

4. A _____ means the name or number used for a hazardous product on a label or in the SDS.

pictogram

5. This type of pictogram is used for ______.


Have a great day!

Important! You will receive an "error" message unless all questions are answered.