OSHA Hazard Communication Standard | What’s in a Label?
Last June was the deadline for employers to update their hazard communication program to align with the Globally Harmonized System. Since then, how much time has your company spent reviewing programs, training workers, and ensuring compliance with the OSHA hazard communication standard? If you were to ask your employees to explain the information on a HazCom label, would they be able to? Even employees who were thoroughly trained in HazCom requirements can forget significant information, especially if they do not use it regularly. No one wants to find out that an employee needed a refresher on HazCom after an incident. Ensuring that your employees understand and comply with the OSHA Hazard Communication standard (1910.1200 and 1926.59) can prevent incidents and fines, making it a smart investment.
Labeling is critical for field employees, having a direct impact on employee responsibilities. They must be trained to read and understand the labels, know when to apply labels to new or secondary containers, and to ensure that the labels have the necessary information. Untrained employees put themselves and others at risk for serious, life altering, and potentially fatal exposures.
What’s on a label?
All labels must have six specific pieces of information. They are:
- Product Identifier – The product name or chemical number
- Signal Word – “DANGER” indicates that there are significant hazards; “WARNING” is used for less severe hazards
- Pictograms – Icons or pictures that are usually inside a red diamond; they provide a picture representation of the material’s physical and health hazards. There are nine standard pictograms, though only eight are mandatory according to OSHA.
- Hazard Statement – Standard phrases that warn about the hazard class and the nature of the hazards. Flammable liquid and vapor, toxic if swallowed, and may cause cancer are examples of hazard statements.
- Precautionary Statement – These provide information about what people need to do to reduce or prevent exposures to the substance’s hazards. They often indicate what types of PPE, such as gloves or eye protection, should be used.
- Supplier identification – This is the name, address, and phone number of who to contact if additional information about the substance is required.
This information comes directly from the safety data sheet (SDS) for the substance, and provides a short reference of the hazards and required protective measures. Think of it like an emergency card for the substance – the basic information necessary to reduce exposures and to get the right treatment quickly if someone does become exposed.
Manufacturers are required to label the containers that their hazardous substances come in. Sometimes, though, we only need small amounts to complete our work, and it isn’t practical to carry around the original container. When transferring a chemical or substance to another container, it becomes our responsibility to ensure that the new container is properly labeled with all 6 required pieces of information. Providing pre-made labels for commonly used substances is an excellent way to ensure that the labels have the right information and that your employees remain productive; otherwise, they must create a new label with all the required information, taking them away from their typical work.
Any container holding a hazardous substance must be labeled, with one set of exceptions. If a situation meets all the following criteria, then a label is not necessary.
- The container will hold the chemical for less than 1 work shift; AND
- Only the person who filled it will use it; AND
- The person who filled it will not leave the container unattended
If a container didn’t need a label originally, but the situation changes and any of these criteria are no longer true, then the container will need to be labeled.
Remember that only approved containers can be used, and that empty food or drink containers are never approved for storing a hazardous chemical.