Q: We are auditing our HazCom program and came across a question about labeling containers. We found this passage from OSHA about exceptions: "Where chemical is stationary, or intended only for the immediate use of the employee."
The question we have is about spray bottles. Would we need to label spray bottles containing various chemicals such as denatured alcohol and rust inhibitor?
A: An exception might apply to your case with the spray bottle if it meets the conditions described in Exception 1 below.
The Hazard Communication (HazCom) regulation allows two exceptions to labeling containers.
Exception 1. The Occupational Safety and Health Administration (OSHA) rule states, "[T]he 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."
The spray bottles must be labeled unless the bottles are intended only for the immediate use ("immediate use" generally means during the work shift) of the employee who performs the transfer of the hazardous chemical into the spray bottle.
Exception 2: Stationary process container, such as a storage tank. A spray bottle is not considered stationary, so the exception would be hard to prove. Explanation: "The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other similar written materials instead of putting labels on individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required [in the HazCom rule] to be on a label.
Great news! BLR’s renowned Safety.BLR.com® website now has even more timesaving features. Take our no-cost site tour! Or better yet, try it at no cost or obligation for a full 2 weeks.
Q: What are the in-house chemical container labeling requirements under the new GHS standard? I have read that the GHS doesn’t require in-house chemical containers (those that will never be shipped or leave the workplace) to be labeled with the new GHS container labels as long as they meet either NFPA or HMIS labeling requirements and again will not be shipped or taken out of the workplace. Is this true?
A: As an alternative to labeling all individual process containers, employers can use alternative labeling systems such as the NFPA and the HMIS as long as those systems are consistent with the GHS labeling system.
All information supplied on the alternative labels must be consistent with the GHS label system; for example, there must be no conflicting hazard statement and pictogram.
Q: When do the GHS requirements become effective (compliance dates)?
A: Here’s a chart of the GHS compliance dates.
4-Year GHS Compliance Transition Period
| May 25, 2012 to November 30, 2013 All employers that use, handle, store chemicals |
Train employees how to read and interpret chemical labels and (material) safety data sheets (SDSs) in compliance with either:
|
| December 1, 2013 All employers that use, handle, store chemicals |
Train employees about the new GHS-compliant chemical labels and SDSs. |
| June 1, 2015 Chemical manufacturers, importers, distributors |
Comply with all the requirements of the GHS rule, including classify chemical hazards and prepare new labels and SDSs. Distributors have until December 1, 2015, to comply with the shipping requirements for GHS-compliant labels. |
| December 1, 2015 All employers that use, handle, store chemicals |
All shipments of chemical containers must include the new GHS-compliant label (signal word, pictogram, hazard statement, and precautionary statement). |
| June 1, 2016 All employers that use, handle, store chemicals |
Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. |
Your one-stop safety management resource, available 24/7. Go here to take a no-cost site tour or here to try it in your own office!
Transition Period for Signage and Labeling of Specific Toxic Substances
| December 1, 2013 All employers that use or handle specific toxic substances |
Affix GHS-compliant labels to containers of protective clothing, equipment, and waste debris contaminated with specific toxic substances, such as asbestos, chromium (VI), lead, cadmium, benzene, and listed carcinogens. |
| June 1, 2016 All employers that use or handle specific toxic substances |
All employers that use or handle specific toxic substances |
See tomorrow’s Advisor for FAQs on MSDSs/SDSs.
Training is an integral part of any hazard communication program. Under the OSHA Hazard Communication Standard (29 CFR 1910.1200), all employers are required to inform and train their employees at the time of their initial assignment to a work area where hazardous chemicals are present, and wherever a new hazard is introduced into the work area.
Globally Harmonized System (GHS) awareness training class will evaluate the old standard and then highlight the alterations to the new standard. After you leave the training you will know precisely what to modify at your place of business.