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Responding is Tomasz Szalajko, global market manager for Brady Worldwide Inc., Milwaukee.
Hazard Communication is one of the most important occupational safety standards for facilities. One of the essential components to a safe and compliant hazcom program is container labeling. So let’s break down the different types of labeling and the time frame you need to be aware of to meet these regulations and protect your employees from hazards.
Primary container labeling
Containers that ship chemicals are called primary containers. To comply with the requirements of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), your primary container labels must contain a product identifier (the chemical name on the Safety Data Sheet), signal word (e.g., “Danger” or “Warning”), relevant hazard and precautionary statements, relevant hazard pictograms, and the contact information for the chemical supplier. The label producer may provide additional information it deems helpful if it does not contradict or detract from the required information.
Secondary container labeling
Secondary containers, such as cans, bottles or bags, are used to transfer, store and dispense chemicals within the workplace. Here are two ways you can choose to label your secondary containers to ensure compliance with the new standard:
- Copy the product identifier, signal word, hazard pictograms, and the hazard and precautionary statements as displayed on the primary shipping container label or listed on the chemical’s SDS. Although it is not required, it can be beneficial to include the supplier’s contact information in case of emergency. This provides employees with the most detailed information at the point of use; however, it may result in a very large label, which many not fit on small containers.
- Display the product identifier and some abbreviated form of the text and symbols used on the primary container label. This provides the general information necessary about the chemical’s hazards. If you go with a secondary container label that displays only general information, you should be sure to provide extra training for your employees.
Workplace labeling exemptions
Certain types of containers are exempt from the workplace labeling requirements. For example, labels are not required on stationary containers such as tanks and reaction vessels. Instead, the employer may elect to use signs, placards, process sheets, batch tickets, operating procedures, or other materials in lieu of affixing labels to individual stationary process containers.
Timeline of critical compliance dates
With GHS deadlines fast approaching, it is extremely beneficial to begin your updates now. Here are the key time frames to comply with the new regulations:
- Dec. 1, 2013: Every U.S. employee affected by this regulation needs to be trained on the changes to labeling and the SDS format.
- June 1, 2015: All manufacturers and distributors have to reclassify chemical hazards and update label formats and SDSs.
- Dec. 1, 2015: This is the last day distributors are allowed to ship chemicals with old format labels and SDSs.
- June 1, 2016: You must be fully compliant with GHS. You must ensure your worksite has an updated hazard communication program, all workplace labeling is in place and all affected employees are trained.
Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.