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