OSHA recently published a brief relating to the new hazardous chemical labeling requirements under the Hazard Communication Standard, 29 CFR 1910.1200 (HCS), which brought the standard into alignment with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
The brief outlines the labeling requirements under the new standard. OSHA also discussed an exciting change, that it intends to make to Appendix C, Allocation Of Label Elements, along with a clarification.
Previously, OSHA did not allow a GHS pictogram to be shown on a shipped container label if it conflicted with the DOT hazmat label. Section C.2.3.3 stated:
“Where a pictogram required by the Department of Transportation under Title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in C.4 for the same hazard shall not appear.”
This statement caused a lot concern for those companies shipping 55 gallon drums and/or smaller containers. Those companies would be forced to have various label designs and train workers to recognize the hazards, even without the pictogram showing (on the drum label due to the 4 x 4 hazmat label). OSHA was petitioned to change the requirement almost immediately after the final rule was published in March of 2012.
In the recent brief, OSHA announced its intent to make the change, allowing the use of both the pictogram and the hazmat label.
“However, DOT does not view the HCS pictogram as a conflict and for some international trade both pictograms may need to be present on the label. Therefore, OSHA intends to revise C.2.3.3. In the meantime, the agency will allow both DOT and HCS pictograms for the same hazard on a label.”
I would imagine that many companies will read this and breathe a sigh of relief. This is a welcome change that should make everyone’s job easier.
For more information, you can view the complete blog here: http://www.osha.gov/Publications/OSHA3636.pdf
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Training is an integral part of any hazard communication program. Under the OSHA Hazard Communication Standard (29 CFR 1910.1200), all employers are required to inform and train their employees at the time of their initial assignment to a work area where hazardous chemicals are present, and wherever a new hazard is introduced into the work area.