Labeling the GHS Way

Today, we’ll look key requirements of the new GHS labeling system

New labels required by the revision of the hazard communication standard (29 CFR 1910.1200) to incorporate GHS amendments will look and read somewhat differently from previously approved label formats.

Of course the purpose of the new labels, tags, and markings remains as always to give employees an immediate warning of hazardous chemicals and a reminder that more detailed information is available.

Label Elements

There are three key elements required for all new chemical labels:

1.   Text in English. Each hazardous chemical label, tag, or marking must be prominently displayed, and text must be in English. Other languages may also be included, if appropriate, but can’t be substituted for English.

2.   Product identifier. The label, tag, or marking must include a “product identifier.” The product identifier is the name or number that enables the user to identify the chemical. The identifier must allow cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label, and the safety data sheet (SDS).

3.   Signal word, pictogram, hazard statement, precautionary statement, and contact information. In addition to the product identifier, all of the following information must be provided together on a chemical label, tag, or marking, and in compliance with the requirements of Appendix C of the standard:

  • Signal word to indicate the relative level of severity of the hazard, such as the more severe word "danger" or the less severe "warning"
  • Hazard statement(s) assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including the degree of hazard, where appropriate
  • Pictogram(s) that may include a symbol and other graphic elements intended to convey specific information about the hazards of a chemical on a white background within a red diamond square
  • Precautionary statement(s) that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling
  • Supplier identification with the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party

Click this link to see samples of a variety of labels.

Get ready for compliance with the new OSHA amendments to HazCom. BLR’s GHS Compliance Focus will help you understand how GHS changes hazard communication requirements and what you need to do to comply. Try it.

Procedure to Correct Outdated Labels

A chemical manufacturer, importer, or distributor that becomes aware of any significant new information about the hazards of a chemical must revise the labels for the chemical within 6 months of becoming aware of the new information and make sure the labels on containers of hazardous chemicals shipped after that time contain the new information.

If the chemical is not currently produced or imported, the information must be added to the label before the chemical is shipped again.

DOT Labels

Chemical manufacturers, importers, and distributors must ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged, or marked in a manner that does not conflict with the requirements of the Hazardous Materials Transportation Act (49 CFR 173), administered by the U.S. DOT.

Employer Requirements

  • You must ensure that each container of hazardous chemicals in the workplace is labeled, tagged, or marked. If you purchase your chemicals, you can rely on the labels provided by your suppliers.
  • You can’t remove or deface existing labels on incoming containers of hazardous chemicals, unless the container is immediately marked with the required information. Hazardous chemical containers must include either (1) the label shipped with the chemical container, or (2) a product identifier and combination of words, pictures, or symbols that provide at least general information regarding the hazards of the chemicals and provide employees with the specific information about the physical and health hazards of the chemical.
  • You are not required to label pipes or piping systems or portable containers transferred from a labeled container intended only for the immediate use of the employee who performs the transfer.

BLR’s GHS Compliance Focus provides the compliance dates along with a side-by-side comparison of the HazCom standard before and after the GHS amendments. Get the details.

Alternatives to GHS Labeling

As an alternative to labeling all individual process containers, you can:

  • Substitute various types of standard operating procedures, process sheets, batch tickets, blend tickets, and similar written materials for container labels on stationary process equipment if they contain the same information as the labels, and the written materials are readily accessible to employees in the work area throughout each work shift.
  • Post signs or placards that convey the hazard information if there are a number of stationary containers within a work area that have similar contents and hazards.
  • Use alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS).

But remember, any alternative labeling method must be consistent with the GHS label system. All information supplied on the alternative labels must be consistent with the GHS label system. There must be no conflicting hazard statement and pictogram.


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