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Hazcom labeling

April 1, 2013

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Under the revised Hazard Communication Standard, will NFPA and HMIS labeling be phased out?

Responding is Bob Ernst, editor – workplace safety, J.J. Keller & Associates Inc., Neenah, WI.

When it comes to the Hazard Communication Standard, OSHA is specific about the employer’s responsibility to provide information on chemical hazards in the workplace, including container labeling. The container label is the first link in protecting workers from chemical hazards.

Labels serve as immediate visual reminders of chemical hazards, and complement the information presented in training and on Safety Data Sheets.

Labeling requirement

The revised Hazard Communication Standard at 29 CFR 1910.1200(f)(1) requires shipped containers to be labeled with the product identification/ingredient disclosure, signal word, hazard statements, precautionary statements, pictograms and supplier identification.

Workplace labeling

OSHA has stated that workplace labeling systems such as NFPA and HMIS will be permitted in-house only, as outlined in the preamble to the revised Hazard Communication Standard. As discussed in the preamble, workplace labeling requirements are primarily intended to accommodate in-plant labeling systems for which the employer retains control over the entire hazard communication program.

In other words, any containers entering or leaving the workplace must have labeling that is compliant with the Globally Harmonized System of Classification and Labeling of Chemicals.

However, in-house use of alternative labeling systems, such as numerical or color-coding systems that indicate the type and severity of a particular hazard, may be acceptable as employers are complying with the other requirements of the Hazard Communication Standard.

OSHA also published an FAQ that states, “Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard.

“Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms.”

Even though the numbering systems are reversed for GHS hazard evaluation and HMIS/NFPA hazard ratings, OSHA said this will not be a problem for two reasons. First, HMIS and NFPA are hazard classification systems and GHS is a hazard rating system. Second, the GHS hazard classification number will not appear on the label as the hazard rating does.

However, the agency warns us, there can be no conflicting pictograms or symbols, such as a skull and crossbones being used for anything other than acute toxins.

Training is key

Employee training will be required to make sure employees understand the labels used in the workplace. Employers who use an alternative labeling system in-house must still train employees on the GHS-style labels, as well as the in-house labeling system used.

Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.

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