Effective June 1, 2015, OSHA’s updated Hazard Communication Standard, 29 CFR 1910.1200 (HCS), requires that all hazardous chemicals be shipped with labels which comply with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The purpose of the GHS is to ensure improved quality and consistency in the classification and labeling of all chemicals, and to also enhance worker comprehension. As a result, workers will have better information available on the safe handling and use of hazardous chemicals, thereby allowing them to avoid injuries and illnesses related to exposures to hazardous chemicals.
The standard requires that information about chemical hazards be conveyed on labels using quick visual notations to alert the user, providing immediate recognition of the hazards. Labels must also provide instructions on how to handle the chemical so that chemical users are informed about how to protect themselves. Under the GHS, labels for hazardous chemicals must contain:
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Name, Address and Telephone Number of the chemical manufacturer, importer or other responsible party.
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Product Identifier is how the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in section 1 of the SDS.
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Signal Words are used to indicate the relative level of severity of the hazard and alert the reader to a potential hazard on the label. There are only two words used as signal words, “Danger” and “Warning.” Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. There will only be one signal word on the label no matter how many hazards a chemical may have. If one of the hazards warrants a “Danger” signal word and another warrants the signal word “Warning,” then only “Danger” should appear on the label.
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Hazard Statements describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.” All of the applicable hazard statements must appear on the label. Hazard statements may be combined where appropriate to reduce redundancies and improve readability. The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards no matter what the chemical is or who produces it.
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Precautionary Statements describe recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling. There are four types of precautionary statements: prevention (to minimize exposure); response (in case of accidental spillage or exposure emergency response, and first-aid); storage; and disposal. For example, a chemical presenting a specific target organ toxicity (repeated exposure) hazard would include the following on the label: “Do not breathe dust/fume/gas/mist/vapors/spray. Get medical advice/attention if you feel unwell. Dispose of contents/container in accordance with local/regional/ national and international regulations.”
A forward slash (/) designates that the classifier can choose one of the precautionary statements. In the example above, the label could state, “Do not breathe vapors or spray. Get medical attention if you feel unwell. Dispose of contents in accordance with local/regional/national/international regulations.”
In most cases, the precautionary statements are independent. However, OSHA does allow flexibility for applying precautionary statements to the label, such as combining statements, using an order of precedence or eliminating an inappropriate statement.
Precautionary statements may be combined on the label to save on space and improve readability. For example, “Keep away from heat, spark and open flames,” “Store in a well-ventilated place,” and “Keep cool” may be combined to read: “Keep away from heat, sparks and open flames and store in a cool, well-ventilated place.” Where a chemical is classified for a number of hazards and the precautionary statements are similar, the most stringent statements must be included on the label. In this case, the chemical manufacturer, importer, or distributor may impose an order of precedence where phrases concerning response require rapid action to ensure the health and safety of the exposed person. In the self-reactive hazard category Types C, D, E or F, three of the four precautionary statements for prevention are:
- Keep away from heat/sparks/open flame/hot surfaces. - No Smoking.
- Keep/Store away from clothing/…/ combustible materials
- Keep only in original container.
These three precautionary statements could be combined to read: “Keep in original container and away from heat, open flames, combustible materials and hot surfaces. - No Smoking.”
Finally, a manufacturer or importer may eliminate a precautionary statement if it can demonstrate that the statement is inappropriate.
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Supplementary Information. The label producer may provide additional instructions or information that it deems helpful. It may also list any hazards not otherwise classified under this portion of the label. This section must also identify the percentage of ingredient(s) of unknown acute toxicity when it is present in a concentration of ≥1% (and the classification is not based on testing the mixture as a whole). If an employer decides to include additional information regarding the chemical that is above and beyond what the standard requires, it may list this information under what is considered “supplementary information.” There is also no required format for how a workplace label must look and no particular format an employer has to use; however, it cannot contradict or detract from the required information.
An example of an item that may be considered supplementary is the personal protective equipment (PPE) pictogram indicating what workers handling the chemical may need to wear to protect themselves. For example, the Hazardous Materials Identification System (HMIS) pictogram of a person wearing goggles may be listed. Other supplementary information may include directions of use, expiration date, or fill date, all of which may provide additional information specific to the process in which the chemical is used.
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Pictograms are graphic symbols used to communicate specific information about the hazards of a chemical. On hazardous chemicals being shipped or transported from a manufacturer, importer or distributor, the required pictograms consist of a square red frame set at a point with a black hazard symbol on a white background, sufficiently wide to be clearly visible. A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label.
The pictograms OSHA has adopted improve worker safety and health, conform to the GHS, and are used worldwide. While the GHS uses a total of nine pictograms, OSHA will only enforce the use of eight. The environmental pictogram is not mandatory but may be used to provide additional information. Workers may see the ninth symbol on a label because label preparers may choose to add the environment pictogram as supplementary information. The below figure shows the symbol for each pictogram, the written name for each pictogram, and the hazards associated with each of the pictograms. Most of the symbols are already used for transportation and many chemical users may be familiar with them.
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Secondary / Stock Container Labels Unless being used in the same period by the same person who made the transfer, when chemicals are transferred from an original container to a secondary (stock) container, the new container should be labeled with the chemical's name as well as all relevant hazard information. Salisbury University utilizes the MSDSOnline chemical inventory and safety data sheet library system. Through this system, users of hazardous chemicals can print secondary container labels. These labels follow the GHA labeling convention.
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Non-GHA standardized labels Prior to OSHA’s adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), OSHA mandated a performance-based labeling standard. Since chemical containers with these earlier labels still remain on campus, users of hazardous chemicals must also be familiar with other hazardous chemical labeling systems.
Chemical labeling developed and approved by the American National Standards Institute
(ANSI) includes a word warning, identification of key hazards, and statements of precautions to avoid the hazard. Hazard warnings on labels may consist of words, pictures, symbols, or any combination thereof.
Word warnings are generally intended to capture immediate attention by identifying severe hazards (such as flammable, poison, fatal if swallowed). Word warnings may also indicate the degree of hazard. CAUTION indicates the lowest degree of hazard. WARNING indicates an intermediate degree of hazard. DANGER indicates the highest degree of hazard.
Picture warnings identify classes of hazardous compounds (such as a flaming letter "O" to indicate oxidizers or a skull and crossbones to indicate toxic chemicals).
Chemicals may also be labeled with the National Fire Protection Association symbol system (NFPA 704). Numbers are used to denote the severity of hazards associated with flammability (red), reactivity (yellow), health (blue) and other special hazards (white) on a color-coded diamond. Higher numbers indicate more severe hazards. Specifically:
0 = no unusual hazard
1 = minor hazard
2 = moderate hazard
3 = severe hazard
4 = extreme hazard
Special hazards include OX (oxidizer), ACID, ALK (alkali), CORR (corrosive), and W (water-reactive).
This system is useful for alerting emergency response personnel to hazards and also for assessing storage and emergency needs. However, it does not adequately indicate precautionary measures or occupational hazards.
