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GHS Training Countdown: OSHA’s HazCom 2012 Labeling Requirement

GHS TRAINING COUNTDOWN: OSHA’s HazCom 2012 Labeling Requirement

Originally published by Steve Stephenson on https://www.duralabel.com

On December 1, 2013, OSHA will expect all employers using or storing hazardous materials on premises to have their workers trained on the new GHS-aligned HazCom 2012 standard.

That doesn’t mean to start training on December 1. It means be done with training by December 1. That leaves you about five months from the beginning of July to get the job done.

There’s no need to panic, but there’s also no good reason to put it off.

To simplify matters, there are only two aspects that your workers need to know about in order to fulfill the OSHA requirement: labeling and safety data sheets. There are important differences from the current HazCom 1994 standard in both of these areas, however, and some of these changes will take some getting used to. In this article we’ll address the labeling requirements and what you’ll need to cover in your training.

HazCom 2012 Labeling Requirements

HazCom 2012-compliant labels won’t be completely phased in until June, 2016, but many chemical manufacturers and distributors are already onboard with the changes. Your workers need to know what the new labels include; it’s not mandatory that your company starts using them yet.

Because new hazards may be associated with familiar chemicals, your workers should be aware of where these hazard notices are found on both the safety data sheets and labels.

HazCom 2012 Label Elements

To be fully compliant, a HazCom 2012 label must have the following elements:

Supplier information (Name, address, telephone number). This contact information should represent the chemical manufacturer, importer, or other responsible party.

Product identifier. What exactly comprises this label element is up to the manufacturer, importer or distributor. Typically it includes the chemical name and numeric identifier (CAS, UN or EC numbers). This product identifier information must match the information in section 1 of the safety data sheet (SDS).

Signal words. There are only two signal words used for HazCom 2012: “Danger,” for more severe hazards, and “Warning” for less severe hazards. If a chemical’s various hazards comprise both levels of severity, only “Danger” is used on the label.

Hazard statements. The hazard statements section describes the nature of a chemical’s hazards, including the degree of hazard, where appropriate. A typical hazard statement of this kind might read, “Causes damage to kidneys through prolonged or repeated exposure when absorbed through skin.” All applicable hazard statements for the chemical must be included in this section, and can be combined to reduce redundancies such that they’re easier to read and understand. Hazard classification categories have specific hazard statements, and users should always see the same statement for the same hazard regardless of the chemical or its producer.

Precautionary statements.The precautionary statements section describes all recommended measures regarding prevention, response to exposure, storage, and disposal of a chemical. HazCom 2012 gives entities classifying chemicals several precautionary statements to be used for standardization and consistency. A typical statement might read, “Do not breathe vapors or spray. Get medical attention if you feel unwell. Dispose of contents in accordance with local regulations.” Precautionary statements are also set up like hazard statements in that they are predefined and must be used as is, with no alteration except in combining them. This is for uniformity and international translations, which are also provided in all EU languages.

Supplementary information (optional). This section of the HazCom 2012 label may include anything that the label producer thinks is important but that doesn’t fit perfectly into the other sections. It could include additional hazards not otherwise classified, and if there is an ingredient of unknown toxicity, and the percentage is equal to or greater than one percent (not based on testing the mixture as a whole), then that information must be included and can be listed here instead of as a supplementary label. PPE requirements may also be included in this section.

Pictograms. HazCom 2012 uses pictograms as a primary element to communicate important information about the hazards of a chemical. If hazardous chemicals are being shipped or transported from a manufacturer, importer, or distributor, labels must have hazard pictograms framed in a red square frame set at a point (like a diamond). The nine pictograms used are designed for quick recognition and conform to what other GHS users across the world expect to see.

Even though GHS uses nine pictograms, OSHA enforces for eight, since the environmental hazard pictogram represents the kind of hazard that the EPA enforces. It can certainly be included in your HazCom labeling, however.

These pictograms do not replace the diamond-shaped labels required by the U.S. Department of Transportation (DOT), which go on chemical drums, totes, tanks, and other containers for transport.

Because some international trading partners may need GHS pictograms, they are not considered a conflict and containers may have two kinds of pictograms on a label.

Whereas DOT diamond labels are required to be present on the outside of all shipping containers, chemicals in smaller containers within a larger shipped container only require the OSHA/GHS pictogram.

All labels must be in English, prominently displayed, and legible.

Once a chemical manufacturer, importer, or distributor becomes aware of significant information regarding a chemical hazard, it is their responsibility to revise the label within six months.

What about NFPA and HMIS Labels?

If you’re compliant with the older HazCom standard (that’s a good thing), your chemicals have NFPA or HMIS labels on them. They are still compliant, but won’t be regulated for long (see timeline chart below). Fortunately you don’t need to peel off the old labels; they may still be useful for first responders but no longer regulated for compliance. So to put it another way, when HazCom 2012 is implemented, it will still be OK to have NFPA and HMIS labels, although they won’t make you compliant and you’ll still need to have HazCom 2012 labels on the same containers.

Like NFPA, the GHS standard assigns numerical ranking to hazard levels. However, the two systems are inverse: NFPA ranks 1 as the lowest hazard level, and GHS ranks 1 as the highest. This conflicting approach does not affect labeling, as the hazard ranking by number does not appear on a GHS-aligned HazCom label. They could cause confusion when reading the SDS or attempting to create labels without proper training.

Additional GHS/HazCom 2012 Training Resources

We recommend you check out this OSHA HazCom label training document and our  HCS/HazCom 2012 Labeling Best Practices Guide for a look at what required. OSHA has also recently announced this special GHS training resources page that includes free “toolbox talks,” free online GHS training tutorials, and GHS training kits with DVDs.