OSHA will be implementing new hazardous chemical labeling requirements that update the current Hazard Communications Standards (HCS) to match the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The existing OSHA standards enforce a performance-based requirement on chemical labels. This means that employers can choose how to convey the hazard information on a chemical label, allowing liberties to the manufacturer, importer, and distributor on how it is displayed. With the move towards GHS compliance requiring specific elements on the labels, many may feel uncertain of the required changes being made to the label format.
Let’s take a look at how GHS compliance will impact chemical labels for everyone.
Changes And Updates To GHS Compliant Labels
After June 1, 2015, labels will have more structured requirements. GHS compliant labels require that chemical hazard information be conveyed on labels using quick visual notations to alert the users, providing immediate recognition of the hazards. Additionally, the GHS-compliant labels must also provide handling instructions for the chemicals.
Therefore, after June 1, 2015, all hazardous chemicals shipped by chemical manufacturers must be labeled with specified elements including pictograms and signal words, while also including hazard and precautionary statements. Distributors may continue to ship containers labeled by manufacturers (but not by the distributor themselves) without GHS-compliant labels until December 1, 2015.
The Globally Harmonized System (GHS) also requires a red border be used within the pictogram; however, an employer may choose to use a black border for workplace (or in-plant) labels only. Other changes include location requirements, NFPA and HMIS rating systems. There are still no required, standardized formats, just the same required elements we reported on back in January, including the following:
The GHS of hazard communication requires the following elements on labels of hazardous chemicals:
- Supplier identification:
GHS supplier identification must include the name, address and telephone number of the manufacturer or supplier of the substance.
- Product identifier:
The product identifier is the name or number used for a hazardous product on a label or in the Safety Data Sheet (SDS). Both the Product Identifier and the SDS names must be the same.
- Signal words:
There are only two signal words, "Danger" and "Warning." These are the only words used to emphasize hazards. They also indicate the severity of the hazard. There can be only one signal word on a label and defaults to the most severe of the materials within the product.
- Hazard statement:
Hazard statements are a set of statements that succinctly describe the nature of the product's hazard. Each product will contain one or more statements, one for each of the hazards of product.
- Precautionary statement:
Precautionary statements are a set of standardized phrases giving advice about the correct handling of chemical substances and mixtures, such as: Protect from moisture; Use only non-sparking tools, etc.
A pictogram is a symbol inside a diamond with a red border, denoting a particular hazard class, such as corrosion, skin irritation, toxic, e.g. a skull and crossbones inside a red diamond for acute toxicity.
OSHA only enforces the use of eight of the nine pictograms available. The environmental pictogram is not mandatory in the US but can be used to provide additional information if the shipper, manufacturer or distributor chooses to include it. The signal word, pictogram, and hazard statement are required to be located next to each other on the label.
It is important to note that the GHS pictograms do not replace the diamond updated labels that the US Department of Transportation (DOT) requires for the transport of chemicals. The DOT labels must also be on the external part of a shipped container and must meet the DOT requirements.
Under GHS, hazard ratings will be inversely numbered with a number 1 rating being the most severe hazard and a 5 being the least severe hazard. The current ratings are just the opposite, with HMIS hazard ratings listed from 0 (minimal or least serious hazard) to a 4 (most severe hazard). The NFPA and HMIS rating systems are not required on GHS labels.
There are a lot of significant changes to be made, for both large and small companies. For further details, see the OSHA Brief on this topic at https://www.osha.gov/Publications/OSHA3636.pdf.