In yesterday’s article, we looked at the labeling requirements for solid materials, specifically, when a solid material is an “article” that does not require labeling and when it is a potentially hazardous chemical that must be labeled. Today, we’ll look at other unusual labeling situations that may arise and how to handle them.
Labeling Stationary Process Containers
Presumably, the hazardous chemicals in your facility are intended for some use, and that use may be in manufacturing or production (as opposed to quality control testing, housekeeping, or some other use for which the chemical is not present in significant quantities outside its original container). When you add chemicals to a stationary process container, it doesn’t make sense to label the container as you would a shipping or storage container –the contents of the process container may change from batch to batch and product to product. In those cases, OSHA permits you to use other documentation to identify the chemicals and hazards that are present, including:
- Process sheets
- Batch tickets
- Operating procedures
Whatever alternative method you use, it must
- Identify the containers to which it is applicable,
- Convey the same information that would be found on a label, and
- Be readily accessible to the employees in their work area throughout each work shift.
GHS vs. NFPA & HMIS Labeling Requirements webcast: How to Comply with OSHA’s New Hazard Communication Small Entity Compliance Guide for & Ensure a Safe Working Environment- Join us on October 16th to learn more!
Labeling Portable Containers
Sometimes a worker will transfer a chemical from its original shipping or storage container to another, portable container for immediate use. For example, the worker may mix floor cleaner into a rolling bucket for use in mopping, or degreaser into a spray bottle for use in cleaning. When the chemical is intended only for the immediate use of the employee who performs the transfer, complete GHS-compliant labeling is not required—although you may wish to require workers to include the chemical’s identity on the container in some form.
Labeling Drug Products
Drug products are another unusual situation: When drugs are dispensed by a pharmacy to a healthcare provider for direct administration to a patient, they fall under the “portable containers” exception and are exempted from hazard communication labeling requirements.
As most companies transition Hazard Communication programs to meet the new compliance requirements, one of the biggest challenges comes from knowing how best to align various labeling schemes to assure compliance. Join us on October 16th for our webcast to learn more on these labeling requirements and how to comply with OSHA’s new hazard communication guide!
By June 1, 2016, employers must update alternative/secondary workplace labeling and their hazard communication program, as necessary, and provide additional employee training for newly identified physical or health hazards.
If your secondary or workplace containers have a National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) labels on them, you will not need to peel off the old labels; they are useful for first responders and those planning for emergency response. But they are no longer in compliance with GHS labeling—informing workers about the hazards of chemicals with which they work. When HazCom is fully implemented, it will still be OK to have NFPA and HMIS labels as long as they are consistent with the GHS labeling system or you could also have GHS labels on the same containers.
Like the NFPA, the GHS standard assigns numerical ranking to hazard levels. However, the two systems are the opposite: NFPA ranks 1 as the lowest hazard level, and GHS ranks 1 as the highest. This conflicting approach does not affect labeling, as the hazard ranking by number does not appear on a GHS-compliant label. However, they could cause confusion when reading the SDS or attempting to create labels without proper training.
If you decide to use alternative workplace labels and the GHS-compliant label, you will need to train your employees on both. In other words, employees must not lose any protections they have under HazCom.
A best practice is to label your secondary container chemicals with the same GHS label information that came on the shipped container label—or the primary label.