HAZCOM chemical labels

Do all chemical containers need GHS labels?

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Responding is Joel Gregier, lead trainer and instructor mentor, and Roger Marks, content writer, Lion Technology Inc., Sparta, NJ.

U.S. employers have been subject to the Globally Harmonized System of Classification and Labeling of Chemicals for about a year and a half. OSHA adopted the global hazard communication system for U.S. workplaces in 2012, and the extended transition period ended in June 2016. For facilities that use hazardous chemicals, incoming shipments should now display container labels that comply with OSHA’s 2012 Hazard Communication Standard.

But what about chemicals onsite since before GHS took effect? Do all workplace chemical containers now need GHS labels? This question continues to cause confusion for employers – and the answer is simpler than it may seem.

Which containers must have GHS labels?

OSHA’s GHS implementation put the burden for updating labels and Safety Data Sheets on chemical shippers. As such, OSHA now requires all shipped containers to display proper GHS labeling.

Although new shipments of chemicals now should arrive at employers’ facilities properly labeled, not all chemical containers are new. Employers are not explicitly required to relabel any chemical container (bottle, tote, drum, etc.) unless the container is offered for transportation. For workplace containers, OSHA allows employers to comply with the previous HazCom Standard (sometimes called HazCom 1994) and label chemical containers using voluntary systems such as those from the National Fire Protection Association and the Hazardous Materials Identification System.

Employers that choose this option still must meet OSHA’s minimum general requirements for workplace hazard labels – a product identifier and words, pictures or symbols that provide general information regarding the hazards of the chemicals [29 CFR 1910.1200(f)(6)].

Best management practices for HazCom labels

Although OSHA permits the use of existing hazard communication systems such as NFPA and HMIS, employers should strongly consider replacing these labels with those that are GHS-compliant.

Employers that use multiple hazard communication systems must train employees on all hazard communication systems in use in the workplace. For this reason, adopting the GHS-style labels for all covered containers may help streamline future hazard communication training and protect workers by limiting confusion.

Exclusions from GHS chemical container labeling

Labeling chemicals in the workplace is not a new idea. Far from it. Given the volume of environmental and safety chemical labeling requirements already in place for certain substances, OSHA has long offered exclusions [29 CFR 1910.1200(b)(5) and (b)(6)] from its HazCom labeling rules for containers that contain:

  • Hazardous wastes regulated under the Resource Conservation and Recovery Act
  • Chemicals subject to the Toxic Substances Control Act labeling standards
  • Pesticides subject to the Federal Insecticide, Fungicide, and Rodenticide Act labeling rules
  • Articles defined at 1910.1200(c), e.g., lithium batteries
  • Biological hazards
  • Foods and seeds regulated by the U.S. Department of Agriculture
  • Consumer products and hazardous substances that require consumer safety labels
  • Distilled spirits and tobacco products
  • Drugs and cosmetics intended for personal consumption
  • Wood and wood products, in certain cases
  • Ionizing and non-ionizing radiation

One other major HazCom exclusion relates to portable chemical containers intended for the immediate use of one, and only one, employee. These portable containers are not subject to HazCom labeling, provided that the employee fills the portable container from another properly labeled container, and does not transfer the portable container to any other employee [29 CFR 1910.1200(f)(8)].

For workers, chemical exposures can result in severe health problems, medical treatment, time away from work and even death. To maintain an effective, up-to-date workplace safety program, protect employees and avoid costly OSHA fines, employers must know which containers are covered by the HazCom standard and recognize that some extra effort to relabel hazardous chemicals may simplify compliance and enhance safety in the end.

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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