Small Container Labeling for HCS 2024

I’m not sure how many people realize; OSHA has finally been amended. This is a good thing. Now the United States is more align with Canada and other countries around the world. OSHA has amended many aspects to the Hazard communication of chemical regulations. One aspect that has been amended is labeling on small packaging.

HCS 2012 (old) vs HCS 2024 (new)

On the old system the requirements where straight forward. The minimum size of the small package was not defined, unlike Canada where there was a requirement that the container must be less than or equal to 100 mL. Basically, the restrictions allowed for small labeling when containers were too small to show all the labeling requirements and pull-out labels, fold back labels, tags or other methods were not feasible. In these situations, you only needed to show at a minimum:

Product identifier;
Appropriate pictograms;
Manufacturer’s name and phone number;
Signal word; and
A statement indicating the full label information for the chemical is provided on the outside package.

Whereas before there were no guidelines for size of container. Now, they have incorporated different labeling rules for unique sizes. The first involves containers less than or equal to 100 mL, and the other is intended for sizes less than or equal to 3 mL in capacity. For a container that is less than or equal to 100 mL the following information is required on the immediate container:

Product identifier;
Pictogram(s);
Signal word;
Chemical manufacturer’s name and phone number; and
A statement that the full label information for the hazardous chemical is provided on the immediate outer package

A container that is less than or equal to 3 mL in size must display at least a product identifier. The outer container must display all label information, must not be removed or defaced in any manor, as well as a statement that the small container(s) inside must be stored in the immediate outer package bearing the complete label when not in use.

Another difference in labeling in general is that labels can only bare a United States address. Whereas before any address would have been acceptable. This goes for any size not just for small labeling.

In conclusion, it appears OSHA has put a lot of thought into amending small package labeling. This could explain why it took so long to amend and adopt these new regulations that we have been waiting so long for. These new changes will make it easier for companies to align with Canada and other countries as a well as making the labels more comprehensible. There may be some initial costs up front to switch to different packaging. But at the same time this also gives companies more options for their packaging needs in order to accommodate product labeling.

ICC Compliance Center has a team of full-time Regulatory Experts who have years of experience and are certified/recognized in their field of expertise. Ask us your tough questions by calling 855.734.5469 or send us an email, we’re happy to help.