Q&A: HazCom Labeling for Consumer Products

Recently, we received the following question from a subscriber: We are trying to come into full compliance with GHS labeling requirements. Are we required to affix labels to items such as can of WD-40, for example?

Here’s our answer:

The hazard communication standard (HazCom) exempts any consumer product or hazardous substance, as those items are defined in the Consumer Product Safety Act and Federal Hazardous Substances Act, where the employer can show that the product is used in the workplace for the purpose intended by the manufacturer and the use results in a duration and frequency of exposure that is not greater than the range of exposures that could reasonably be experienced by consumers when used for the intended purpose (29 CFR 1910.1200(b)(6)(ix)).

So if your employees use the WD-40 as a normal consumer would, then the employer is not required to use a GHS-compliant label. However, it is the employer’s responsibility to establish that the frequency is equivalent to typical consumer use.

On the other hand, if the product is used as part of an employee’s regular job duties, such as bleach or Windex by cleaning personnel, an SDS, labeling, and HazCom training are required.

More information is available in this OSHA letter of interpretation.