There is a lot of confusion out there regarding what OSHA is requiring for labeling.
Kim Peterson, @safetec walks us through the basics.
Types of Labels
First, there are “primary labels” and “secondary labels”
Most of the time workplaces use the primary containers they purchase to store and use chemicals. However, sometimes, they may use their own containers such as flam cans, plastic jugs, or spray bottles to store and use smaller quantities of chemicals they purchase. So, that smaller container is the “secondary container.”
OSHA refers to this as a “portable container” but most people in industry think of them as “secondary containers”
Next there are labels that the manufacturers put on primary containers prior to shipping them out AND there are “workplace” labels – labels that employers put on both primary and secondary containers.
Manufacturer, Importer, Distributor Labeling Requirements:
For chemical manufacturers, labeling requirements under HCS 2012 is very clear.
“the chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemical leaving the workplace is labeled, tagged or marked. Hazards not otherwise classified do not have to be addressed on the container. Where the chemical mfg or importer is required to label, tag or mark, the following information shall be provided:
Product identifier
Signal word
Hazard statement
Pictograms
Precautionary statement
Name/address/phone number
Workplace Labeling Requirements
Employers have more flexibility.
For workplace container labels (primary containers) the ruling states,
“the final rule retains the flexibility by indicating that the employer can choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard.”
“it should be noted that while alternatives are permitted for workplace containers, the information supplies must be consistent with the revised HCS.”
“Hazard classifications must be revised as necessary to conform with the final rule, and the other information provided must be revised accordingly to ensure the appropriate information is conveyed”
All of this information was presented in the final ruling pages 436-446.
The HCS 2012 specifically states for workplace container labeling that labels must contain GHS label elements (pictograms, etc) OR
“Product identifier and words, pictures, symbols, or combination thereof, which, in conjunction with the other information immediately available to the employee under the HC program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical”
The problem will be regarding if employers really want to take on an alternative labeling program that is consistent with the GHS/HCS 2012 label requirements. HOWEVER, by June 1, 2016 all alternative labeling will need to be updated to the GHS labeling standards.
Secondary and Stationary Labeling Requirements
For secondary labeling requirements in the workplace, OSHA’s HCS 2012 language says:
• The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers…
• 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…
So that means that NO, secondary/stationary container labels do NOT need to use a pictogram IF it meets the definition of a secondary or stationary container.
Please read more from Kim Peterson, kimP@safetec.net
Director of Environmental, Health and Safety
