When OSHA aligned the Hazard Communication Standard 1910.1200 with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in 2012, it was with good reason. Prior to these modifications, numerous internal and external chemical labeling systems existed, which often meant confusion for workers, delays in shipping and loss of business revenue. This was especially true when products had to be shipped or received across national borders.
Moving to a harmonized system allowed a uniform structure for labeling, as well as hazard information, to be disseminated. Today, over 65 countries share the GHS system. And while each have country-specific versions, the increasing use of the GHS worldwide has brought greater ease and transparency to chemical safety use and shipping.
The merging of GHS with OSHA’s Hazard Communication Standard (HCS) did not replace the regulation. Instead, it augmented the main HCS purpose, which was to convey hazard information to workers in an effective and meaningful way.
That included changes to chemical labeling. Understanding the GHS-aligned chemical labeling that's now part of OSHA's HazCom Standard is quite simple, but there are key terminologies and components you’ll need to learn to use the system in your workplace.
We'll explain those in this article.
GHS alignment of the OSHA HazCom Standard was meant to be a practical approach to:
Two of the best places for workers to learn about the hazards of chemicals at the workplace are safety data sheets (now called SDSs; these were known as MSDSs before the 2012 HazCom/GHS alignment) and the chemical labels.
Let's learn a little more about each before we continue to discuss the chemical labels.
As part of the GHS-alignment of OSHA's Hazard Communication 2012 Standard, the old material safety data sheets (MSDSs) were dropped and new safety data sheets (SDSs) were integrated. Safety Data Sheets are well-organized and comprehensive, with 16 different sections that are functional and easy to understand. As a result, the safety data sheet is the best place to look for in-depth explanations of the hazardous potential of a chemical at work.
This sample from our online Hazard Communication training course explains the different parts of an SDS.
Labels on chemical containers are smaller than a safety data sheet and, as a result, they can't include as much information. But they DO still have lots of important safety information that is easy accessible, at the point of use, and easy to understand.
Remember that labels are only meant as a fast reference for those who use, handle, transport or store hazardous chemicals.
The GHS-compliant Hazard Communication chemical label elements are illustrated in the sample from our online Hazard Communication training course below.
The following elements are required on hazardous chemical labels:
Supplemental Information: In addition to these required label elements, chemical manufacturers may also opt to include supplementary information, such as expiration dates of products, recommended PPE or other pertinent details.
There are nine pictograms in use on GHS aligned labels, but only eight of them fall under OSHA’s jurisdiction, as one is used for environmental hazards. The eight pictograms called for by OSHA's HazCom Standard are shown below.
According to OSHA, “The required pictograms consist of a red square frame set at a point with a black hazard symbol on a white background, sufficiently wide to be clearly visible.” With their bright red, white and black color scheme, and clear graphics, pictograms standout and serve as strong visual indicators of hazards.
The sample video from our online Hazard Communication training course walks you through the eight HazCom pictograms and the environmental pictogram as well.
And below we've got a closer look at the pictograms for you.
(Flammables, pyrophoric, self-heating, self-reacting, emits flammable gases, organic peroxides)
(Unstable explosives, explosives, self-reactive substances and mixtures, organic peroxides)
(Acute toxicity and/or rapid death)
(Skin corrosion/burns, eye damage, corrosive to metals)
(Gases under pressure)
(Carcinogens, mutagenicity, reproductive toxicity, target organ toxicity, aspiration toxicity)
(Skin or eye irritant, limited acute toxicity, narcotic effects, respiratory tract irritant)
And, even though it's not part of the OSHA HazCom Standard, it's worth knowing about the GHS Pictogram for Environmental Hazards, as well. That's it below.
The four types of precautionary statements are:
To create a product label, chemical manufacturers or importers/distributors are required to classify chemicals according to designated criteria that is outlined in appendices of the Hazard Communication Standard.
Chemical hazards for the updated HCS have three groups; health, physical and environmental. Classification then is based upon 16 physical hazards, 10 health hazards and 2 environmental hazards.
Each hazard classification is then further divided into categories, according to different severity levels. Categories are rated 1-4, with 1 as the most severe. Stop here and let that sink in.
Many employers are familiar with the NFPA or the HMIS labeling systems, which applied a 0-4 rating hazard rating system, with zero being the lowest hazard and four as the most severe. These were the common chemical labeling systems in use in US businesses for several decades. It’s important to note that the GHS uses an inverse rating system. Don’t forget that or draw on previously learned knowledge about other chemical rating systems you’ve used before.
After the above steps, chemical manufacturers are to compare those hazards found with Appendix C of the HCS and select the appropriate label elements. This process is much more streamlined than in earlier years, prior to the GHS adoption. It eliminates the guesswork and uses available scientific data to place a chemical in the proper hazard classifications and categories.
OSHA spells out the requirements for Hazard Communication employee training in 1910.1200(h). They include the following:
The employee should be informed of:
This online hazard communication training course is a good addition to your employee HazCom training program.
Make sure your workers know the important aspects of chemical labeling, SDS and the new components of the GHS aligned HCS.
And for further details on the HCS and ways to comply, you can explore this article and the information links provided.
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