It seems that just about every month, even during the COVID Pandemic, we come across a safety professional, 3rd party auditor, and even an OSHA CSHO who will swear on his/her grandmother's grave that the ONLY acceptable HAZCOM labels in the workplace are those that contain:
- Product identifier;
- Signal word;
- Hazard statement(s);
- Pictogram(s);
- Precautionary statement(s); and,
- Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party
It is quite often a passionate presentation of how they are 100% correct and those who don't believe them are wrong. I am not sure where this kool-aid is coming from or who is even making it, but too many safety professionals are drinking it!
The safety professional, 3rd party auditor, and even an OSHA CSHO understand how easy GHS is, and their anger turns to those who misled them. Honestly, some of the confusion is "honest confusion," as I, too, was a lost soul back in 2012/2013. Luckily I was consulting by then which drove me to dig deep into this new HAZCOM standard and with the help of my right-hand man, Mr. Dennis Collins, we got it all figured out and held training sessions for many of our clients.
But this labeling issue will not seem to go away; I have written 14 articles since 2013 on just GHS labeling requirements, and I have been called everything in the book by those who had drunk the kool-aid. The OSHA language and literature from the standard, Compliance Directive, LOIs, etc., are never enough to shine the light on the fact that we can STILL USE the NFPA 704 Diamond and HMIS labels on our SECONDARY CONTAINERS. Even the actual GHS Standard, all the way back to the 3rd Revision in 2009 from which OSHA revised the HAZCOM standard to meet, clearly states that NOT all "workplace labeling" has to contain the six (6) GHS label elements (as noted above)...
(emphasis by me)
1.4.10.5.5.1 Workplace labelling
Products falling within the scope of the GHS will carry the GHS label AT THE POINT WHERE THEY ARE SUPPLIED TO THE WORKPLACE, and that label should be maintained on the supplied container in the workplace. The GHS label or label elements should also be used for workplace containers. However, the competent authority can allow employers to use alternative means of giving workers the same information in a different written or displayed format when such a format is more appropriate to the workplace and communicates the information as effectively as the GHS label. For example, label information could be displayed in the work area, rather than on the individual containers.
Alternative means of providing workers with the information contained in GHS labels are needed usually where hazardous chemicals are transferred from an original supplier container into a workplace container or system, or where chemicals are produced in a workplace but are not packaged in containers intended for sale or supply. Chemicals that are produced in a workplace may be contained or stored in many different ways such as: small samples collected for testing or analysis, piping systems including valves, process or reaction vessels, ore cars, conveyer systems or free-standing bulk storage of solids. In batch manufacturing processes, one mixing vessel may be used to contain a number of different mixtures.
In many situations, it is impractical to produce a complete GHS label and attach it to the container, due, for example, to container size limitations or lack of access to a process container. Some examples of workplace situations where chemicals may be transferred from supplier containers include containers for laboratory testing or analysis, storage vessels, piping or process reaction systems or temporary containers where the chemical will be used by one worker within a short timeframe. Decanted chemicals intended for immediate use could be labelled with the main components and directly refer the user to the supplier label information and SDS.
All such systems should ensure that there is clear hazard communication. Workers should be trained to understand the specific communication methods used in a workplace. Examples of alternative methods include use of product identifiers together with GHS symbols and other pictograms to describe precautionary measures; use of process flow charts for complex systems to identify chemicals contained in pipes and vessels with links to the appropriate SDS; use of displays with GHS symbols, colour and signal words in piping systems and processing equipment; use of permanent placarding for fixed piping; use of batch tickets or recipes for labelling batch mixing vessels and use of piping bands with hazard symbols and product identifiers.
As I pointed out before, the GHS label requirements APPLY ONLY TO "SHIPPED CONTAINERS"... (emphasis by me)
1910.1200(f) Labels and other forms of warning—
1910.1200(f)(1) Labels on shipped containers
...
"Workplace Labeling" falls under a DIFFERENT paragraph...
1910.1200(f)(6) Workplace labeling
Of course, businesses can choose to use the GHS labels on every single container in the workplace; however, for those who choose to continue using the NFPA 704 and HMIS labels on their SECONDARY CONTAINERS (e.g., the container they transfer the hazardous chemical into from the TRANSPORTATION container), it is perfectly acceptable and compliant.
Source: https://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev03/English/01e_part1.pdf
See page 34
