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 1994 HCS and the new (GHS) labeling requirements adopted by the HCS 2012 in this module.
We'll take a look at the labeling requirements for each of the types of containers referred to in the hazard communication standard:
As of June 1, 2016, the new GHS labeling system must be used. We decided to continue to discuss the "old" labeling system as well as the new so that if you find any of the old labels in your workplace, you'll be able to recognize them and update them.
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 that the hazard warning must convey 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," "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 HCS 2012, labels on primary containers shipped from manufacturers or distributors, the container must be labeled, tagged or marked with the following six items:
The next section gives you a good look at what these labels should look like.
As you can see, the new GHS primary container label below provides much more information than the old HCS 1994 primary container label shown in the previous section.
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 and must 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 warning to supplement the secondary label information.
See the photo on the right. OSHA inspectors see this all of the time and cite the employer for lack of proper labeling. This also tells the OSHA inspector they need to look at the overall HAZCOM Program because it's obvious the program is not working.
This exercise is optional. To complete the exercise you must speak to trainer John and answer his questions. To do so, you will need to select a response at the bottom of the screen. Do your best to answer his questions. Good luck!
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 images to the right show the NFPA and HMIS labels under the current HCS 1994. In Module 3.12, you can see the GHS pictogram labels required under the HCS 2012.
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. The term "other such written materials" does not include safety data sheets used in lieu of labels.
Stationary process containers are...well...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 of the employee who performs the transfer. The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer.
Drugs which are dispensed by a pharmacy to a health care provider for direct administration to a patient are exempted from labeling.
It's important to know that portable containers must be under the positive control of the employee using it. Let's say an employee is cleaning some parts with solvent he has placed in a plastic container. As long as the employee is using it for immediate use and can prevent another employee from exposure, labeling is not required. But what if he walks away from the workstation to go on a break (or for any reason), and loses control of the chemical?
If the employee loses positive control of the container, the container becomes a secondary container and must be labeled. OSHA inspectors routinely find unlabeled or improperly labeled containers in the workplace. As a safety person, make sure you're always on the hunt for unlabeled secondary containers!
For solid metal (such as a steel beam or a metal casting), solid wood, or plastic items that are not exempted as articles due to their downstream use, or shipments of whole grain, the required label may be transmitted to the customer at the time of the initial shipment, and need not be included with subsequent shipments to the same employer unless the information on the label changes.
The label may be transmitted with the initial shipment itself, or with the safety data sheet that is to be provided prior to or at the time of the first shipment.
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. Railroad ties treated with creosote should have an accompanying safety data sheet (SDS) when shipped.
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).
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 employees who speak other languages may add the information in their language to the material presented, as long as the information is presented in English as well.
Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical must revise the labels for the chemical within six months of becoming aware of the new information, and must ensure that labels on containers of hazardous chemicals shipped after that time contain the new information.
If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer must add the information to the label before the chemical is shipped or introduced into the workplace again.
The HCS 2012 requires 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.
While the GHS uses a total of nine pictograms, OSHA will only enforce the use of eight. The environmental pictogram is not mandatory but may be used to provide additional information. Workers may see the ninth symbol on a label because label preparers may choose to add the environment pictogram as supplementary information.