Container Labeling

Types of Containers

Stationary Container.

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 look at the labeling requirements for each of the types of containers referred to in the hazard communication standard:

• Shipped container labels - on shipped containers
• Workplace container labels - on employer containers
• Portable containers - there are NO label requirements
• Stationary container labels - on large tanks, etc.

Check out this short video podcast by Dan Clark (theSafetyBrief.com) that discusses important questions about labeling requirements.

Shipped Container Labeling

Containers with Shipped Labels.

Under the Hazard Communication Standard (HSC) 2012, labels on containers shipped from manufacturers or distributors, the container must be labeled, tagged or marked with the following six items:

1. Product Identifier
• Product identifier should be used and it should match product identifier used on the SDS. If mixture is covered by UN Model regulations for transport of Dangerous goods, UN proper shipping name should also appear on package.
• Label for substance should include the chemical identity of the substance. For mixtures and alloys - label should include chemical identities of all ingredients or alloying elements that contribute to 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, competent authority may choose to give suppliers discretion to include chemical identities on the SDS, in lieu of including them on labels.
• The competent authority rules for CBI take priority over the rules product identification and ingredients meeting criteria for CBI do not have to be included on the label.

3. 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.
• 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.
4. 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.
5. 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.
6. Supplier identification
• Name, address and telephone number of the manufacturer or supplier of the substance or mixture should be provided on the label.

Sample Shipped Container Label

Sample GHS Label
Click to Enlarge

As you can see, the GHS shipped container label below provides much more information than the older HCS primary container label shown in Section 2.

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.

Workplace Container Labeling

A workplace/secondary container must be labeled if it is left unattended. This container is not properly labeled.

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.

See the image above. If this worker was to leave this container to go to the restroom, the container would have to be properly labeled. OSHA inspectors see workplace containers without labels frequently and cite the employer. This situation also tells the OSHA inspector they need to look more closely at the overall HAZCOM Program because it's obvious the program is not working.

Portable containers are for immediate use and need not be labeled unless the worker loses positive control.

Portable Container Labeling

Portable containers are used by employees use or transfer chemicals from labeled containers, and need not be labeled if immediately used by the employee who transferred the chemical. 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 must be reclassified as a secondary container and 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!

Stationary Process Containers.

Stationary Process Container Labeling

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.

Labeling Solid Materials

Railroad ties with labels.

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).

Alternative labels may be used if they meet HCS requirements.

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 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.

Other Important Labeling Requirements

Revise labels as required.

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, or
• readily available in the work area throughout each work shift.

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.

Updating Labels

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.

Pictogram Requirements

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.

HCS Pictograms and Hazards

Check your Work

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Exercise

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