HazCom Labels

How to Comply with Label Requirements: Now & After GHS Takes Effect

Date First Published on SafetySmart Compliance: November 2nd, 2012
Topics: GHS Transition | HazCom |

Haz Com Labels The Hazcom label you’ve come to know is slated for extinction. Under OSHA’s final GHS Rule, all containers of hazardous chemicals will have to be marked with newfangled GHS labels by Dec. 1, 2015.  Complying with labeling requirements is already tricky; what’s going to happen when the new GHS label requirements take effect? This story will explain.

How Label Rules Work

The philosophy of Hazcom is that employees have a right to know about the hazards of the chemicals in their workplace. The Hazcom system is designed to ensure that the companies that manufacture and supply hazardous chemicals identify the hazards posed by their products and communicate information about these hazards to end users downstream, including the employees who work with or near those products.

The workplace label is one of the key methods of transmitting hazard information. Each party has a role to play in ensuring that labels fulfill their purpose:

  • The company that manufactures or imports the chemical must create the label for a particular product and ensure that each container of the product has a label attached that  lists the required information; and
  • The employer that uses hazardous chemicals must ensure that each hazardous chemical covered by Hazcom has an appropriate label that remains firmly attached and legible; just as importantly, the employer must make sure that all exposed employees know how to read the label and use the information it conveys to protect themselves. (Employers can also prepare the label themselves if they choose, but few actually do.)

THE PUNCHLINE: IMPACT OF GHS

Under GHS, labels will change but the labeling system won’t. In other words, all the parties—manufacturers and importers and employers—will have to keep doing what they’re doing now as far as labels are concerned; but the actual labels they use will look different from the way they do now. 

Let’s go through things one step at a time:

Step 1: Are You Subject to Workplace Label Requirements?

Current Hazcom Rule: You can stop reading now if you’re not covered by the Hazcom label requirements. Explanation: Labels don’t have to be on hazardous chemicals and substances that are subject to labelling requirements under other federal laws. The Hazcom labelling exemption applies to:

  • Pesticides;
  • Chemical substances or mixtures regulated by Toxic Substances Control Act;
  • Foods, food additives, drugs, cosmetics or medical or veterinary devices;
  • Distilled spirits (beverage alcohols), wine or malt beverages;
  • Consumer products or hazardous substances that must be labeled under the Federal Hazardous Substances Act;
  • Agricultural or vegetable seed treated with pesticides;
  • Hazardous waste and substances regulated by environmental laws;
  • Tobacco and tobacco products;
  • Wood or wood products which the chemical manufacturer or importer can show pose no hazard to employees other than the potential for flammability or combustibility (the exemption does not cover wood or wood products that have been treated with a hazardous chemical covered by Hazcom, or wood that may generate dust when cut or sawed);
  • Solid drugs like pills and tablets sold for direct administration to patients, over-the-counter drugs and other drugs packaged by chemical manufacturers for direct retail sale and drugs intended for personal consumption by employees while in the workplace, such as first aid supplies;
  • Consumer cosmetics;
  • Nuisance particulates that the chemical manufacturer or importer can show pose no physical or health hazard;
  •  Ionizing and nonionizing radiation; and
  •  Biological hazards.

 

Impact of GHS: The exact same exemptions will apply under GHS.

Step 2: Make Sure Labels List All Required Info

Current Hazcom Rule: If you are covered by the label requirements, recognize that primary responsibility for creating the label resides with the company that manufactures and/or imports the chemical. However, employers must ensure that each container of hazardous chemicals in the workplace is labelled, tagged or marked with the required information:

  • The identity of the hazardous chemical(s), i.e., its chemical name under IUPAC nomenclature, or common name (code name, code number, trade name, brand name or generic name) as listed on the MSDS (Click here to find out how to comply with MSDS requirements);
  • Appropriate hazard warnings or words, pictures, symbols or a combination, that provide: i. at least general information about the chemical’s hazards; and, ii.that, in conjunction with the other information immediately available to employees under the hazard communication program, furnish employees specific information about the chemical’s physical or health hazards; and
  • The name and address of the chemical’s manufacturer, importer or other responsible party.

The employer must also ensure that the label is legible, in English (or other languages employees speak to the extent that information is also listed in English) and prominently displayed on the container, or readily available in the work area through each shift.

Effect of GHS: GHS doesn’t change any of these requirements except with regard to the information a label must list, including:

  • Product identifier, i.e., name or number for a hazardous chemical;
  • Signal word, i.e., “danger” for more severe hazards or “warning” for less severe ones;
  • Hazard statement(s), i.e., statements assigned to a hazard class and category describing the nature of the hazard(s) of a chemical and, where appropriate, the degree of hazard. Example: “causes damage to organs (list all affected organs) through prolonged or repeated exposure (state route of exposure if no other routes of exposure cause the hazard)”;
  • Pictogram(s) in the shape of a square set at a point that include a black hazard symbol on a white background with a red frame wide enough to be clearly visible (Click here to find out about the GHS pictograms) Hyperlink to Mar30J.
  • Precautionary statement(s), i.e., phrases describing recommended measures to take to minimize or prevent adverse effects of exposure, improper storage or handling. Example: “keep away from heat, sparks and open flame”; and
  • Name, address & phone number of manufacturer, importer or other responsible party.

Compliance Timeline: The transition from the current label to the newfangled GHS label will be carried out in stages:

  • Dec. 1, 2013: Employers must have trained employees to use new GHS labels (and new Safety Data Sheet (SDS), which replaced the Material Safety Data Sheet (MSDS);
  • June 1, 2015: Manufacturers and importers must reclassify chemicals and prepare appropriate SDSs for each;
  • Dec.1,2015: Manufacturers and importers must prepare new GHS labels; and
  • June 1, 2016: Employers must ensure each hazardous chemical has GHS-compliant label and SDS.

Step 3: Make Sure Alternatives to Labels Comply

Current Hazcom Rule: Employers may use signs, placards, process sheets, batch tickets, operating procedures and other written materials in lieu of affixing labels to stationary process containers as long as the alternative method(s):

  • Identifies the containers to which it applies; and
  • Lists the other information required in a label, towit:
  • The identity of the hazardous chemical(s), i.e., its chemical name under IUPAC nomenclature, or common name (code name, code number, trade name, brand name or generic name) as listed on the MSDS; and
  • Appropriate hazard warnings or words, pictures, symbols or a combination, that provide information about the chemical’s characteristics.

Placards, signs and other alternative warning written materials must be readily accessible to employees in the work area through each shift.

Effect of GHS: GHS doesn’t change any of these requirements. So the same label alternative rules that you followed/are following under Hazcom, will remain in effect under GHS.

Step 4: Ensure Labelling of Portable Containers Comply

Current Hazcom Rule: Employers don’t have to label portable containers into which hazardous chemicals are transferred from labelled containers, and that are intended only for immediate use of the employee who performs the transfer. (Note: Drugs dispensed by a pharmacy to a healthcare provider for direct administration to a patient don’t have to be labelled.)

Employers may not remove or deface labels on incoming containers of hazardous chemicals, unless the container is immediately marked with the required information.

Effect of GHS: GHS doesn’t change these requirements.

Step 5: Train Workers on Labels

Current Hazcom Rule: Employers must train workers on Hazcom and that training must address workplace labels. Workers need to be able to understand how the labelling system works and what the information listed means.

Effect of GHS: The same information and training requirements apply under GHS. But the substance of training will change. By December 1, 2013, all employees will need to be trained on the GHS labels and how to use them.

CURRENT HAZCOM

GHS

Requires chemical manufacturer, importer or distributor to ensure each container of hazardous chemicals leaving workplace is labeled, tagged or marked with:

  • Identity of hazardous chemical, i.e., chemical or common name listed on the MSDS
  • Hazard warnings, i.e., words, pictures, symbols or combination that convey the chemical’s physical and health  hazards, target organ effects of chemicals in container
  • Name & address of manufacturer, importer or other responsible party
Requires chemical manufacturer, importer or distributor to ensure each container of hazardous chemicals leaving workplace is labeled, tagged or marked with:

  • Product identifier, i.e., name or number for a hazardous chemical
  • Signal word, i.e., “danger” for more severe hazards or “warning” for less severe ones
  • Hazard statement(s), i.e., statements assigned to a hazard class and category describing the nature of the hazard(s) of a chemical and, where appropriate, the degree of hazard
  • Pictogram(s) in the shape of a square set at a point that include a black hazard symbol on a white background with a red frame wide enough to be clearly visible (Click here to find out about the GHS pictograms) Hyperlink to Mar30J.
  • Precautionary statement(s), i.e., phrases describing recommended measures to take to minimize or prevent adverse effects of exposure, improper storage or handling
  • Name, address & phone number of manufacturer, importer or other responsible party


Click here
for a checklist you can use to train employees how to properly read an MSDS
Click here for a Hazcom training checklist you can use to comply with training requirements.

 
 
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