Everyone working around hazardous chemicals has a right to know of possible dangers and how to protect themselves. This has always been at the heart of the Hazard Communication Standard (HazCom).
In 2012, OSHA incorporated the Globally Harmonized System of Classification and Labelling of Chemicals—GHS for short—into the HazCom rule.
In this 3-minute compliance video (transcript below), BLR Legal Editor Ana Ellington will help you prepare for the upcoming June 1 GHS deadline.
Bonus – get a free SDS toolbox talk at the end of the video, or you can download it here!)
Who else should know this? E-mail to a colleague!
Can’t watch the video? Here’s the transcript:
Under the new GHS standard, instead of having a variety of different safety data sheets(SDSs) and labels, the hazard warnings will be the same regardless of who produces the chemical or where it is produced. And, even more importantly, the message is the same regardless of who sees it.
The new labels tell you not only what you need to know, but also what you need to do in a way that everyone can clearly and easily understand.
What Should a Label Look Like?
A label on a shipped container must now look like this:
There is no required format for labels, so they may not look like the sample label above—but they have to have all of that information.
- Product identifier(s)
- Supplier identification
- Precautionary statements
- Hazard pictogram(s)
- Signal word
- Hazard statement(s)
- Supplemental information—which isn’t a requirement
June 1, 2016 is the final deadline in the 4-year phase in of the revised HazCom rule. By this date, employers must have trained employees on any new physical or health hazards identified in the safety data sheets received since December 1, 2015—and the HazCom program needs to be updated to reflect these newly identified hazards. Employers must also update their workplace or secondary containers to provide the information required under HazCom GHS. These include spray bottles, jugs, jars, and cans.
What does OSHA say?
“When a secondary container is used for longer than one shift by one person, a label needs to be applied to the secondary container. This label must contain two key pieces of information: the identity of the hazardous chemical(s) in the container (e.g., chemical name) and the hazards present.”
So to be clear, all workplace containers must be labeled with at least:
- Identity of the chemical, and
- All potential hazards associated with the chemical
And you should also include the:
- Manufacturer’s name, address and telephone number
NFPA and HMIS labels
We are all familiar with these NFPA and HMIS labels that have been on containers forever.
OSHA does allow us to keep these well-known labels on our secondary containers. However, these labels are for emergency responders and do not provide the information that HazCom GHS requires. So, if you continue to use these labels, you will need to add the required information just mentioned.
Although we are familiar with the NFPA/HMIS hazard rating systems, they are actually the reverse of the GHS hazard rating system. This is not an issue on the label itself because the GHS labels do not have the rating numbers. But it can cause confusion for employees reading the SDS.
OSHA requires that you train your workers on the GHS label elements, but you also need to include training on the NFPA and HMIS labels, and on how they differ, if you continue to use them.
Best Practice Tip
A best practice is to label your secondary containers with the same GHS label information that came on the shipped container label, like these workplace containers.