Nola Murphy’s Story
It was in a soft-drink bottle. It looked like lemonade. But 73-year-old Nola Murphy discovered, after pouring herself a glass, that it wasn’t. In fact, it was a toxic mould-remover that a cleaner had left sitting on a restaurant bar. The cleaner had poured the product from a larger container into the soft drink bottle for easier handling.
Mrs. Murphy was lucky – she survived the experience, although she required emergency hospital treatment. But her story, given in an article in the New Zealand Medical Journal, shows how putting hazardous chemicals in unlabeled containers can be a recipe for disaster. (More: The New Zealand Herald)
Many countries, including the United States and Canada, require hazardous chemicals sold to the workplace to be labeled by the supplier. Regulations such as the U.S. Occupational Safety and Health Act (OSHA), and Canada’s WHMIS (Workplace Hazardous Materials Information System), set out the basic requirements for such labels (called “supplier labels” under WHMIS, and “labels for shipped containers” by OSHA). But as Mrs. Murphy’s experience shows, many hazardous chemicals still end up in unlabeled containers. They may be poured (“decanted”) from larger containers for convenience. The original supplier label may have been damaged or removed. Or two or more chemicals in separate containers may be mixed together to make a new product. No matter how it happens, unlabeled chemicals create a serious workplace hazard.
Workplace Labels are Essential in Safety
The solution is the “workplace label”. This is a label created by the workers to provide minimal information for people in that specific workplace. Such labels may not include all required information for selling to product to another user, but they are adequate for use by workers in one location who have been trained to understand how workplace labels provide essential information.
Under WHMIS, a workplace label must contain three basic pieces of information:
- The product identifier (trade name, product code or other identifier that matches the identifier on the Safety Data Sheet);
- A reference to the Safety Data Sheet for more detailed information; and
- Adequate information on safe handling to protect workers in that workplace
OSHA’s “Hazcom 2012” standard requires that employers label containers either with the information required for shipped containers, or:
- The product identifier, and
- Words, pictures, symbols or a combination of such, which provide at least general information regarding the hazardous of the chemical, and which will provide employees with the specific information regarding the health and safety hazards of the chemical (when combined with appropriate training)
There are many ways that the employer can provide this information. The WHMIS and OSHA standards for workplace labels are purposefully made less specific than those for supplier labels, so that employers can find a solution that is the best fit for their particular workplace.
Common workplace labeling methods include:
- Text-only – this solution is adequate in workplaces where employees are literate in a common language. However, it is not a good fit for workplaces with workers who speak many different languages, or who may have trouble reading. Also, there is the issue of who decides what the text should be. Some workplaces have created a database of warnings for specific chemicals, often with the option of printing them directly from the database
- Symbolic systems – Both WHMIS and the new Globally Harmonized System (GHS) adopted by OSHA use symbols on supplier labels. Since workers must be familiar with these, many employers use systems that include these symbols. For example, ICC Compliance Center Inc. has created a GHS-based workplace labelling system that allows users to remove or display GHS symbols based on the symbols shown on the original supplier label
- Colour-coded/Numerical systems – Information can be provided to workers using codes, such as colours and numbers, as long as the employees have been trained in understanding the system. There has been some concern that some popular systems that use numerical hazard ratings may create confusion with GHS, because these hazard-rating scales conflicts with the GHS category numbers. However, proper training in the system should help prevent problems
- Custom systems – The flexibility of the workplace labelling system allows employers to use their own creativity to solve their specific workplace issues. Any system that provides their workers with adequate information is a good system
The introduction of GHS has provided an opportunity for employers to rethink their workplace labelling systems. The ideal solution is one that is as easy for workers to use as to understand. Systems that are unnecessarily complex lead to workers skipping the step of applying the label. The worker who left out the cleaner that Mrs. Murphy drank probably thought it was “too much trouble” to put a label on the bottle. Inconvenient or poorly understood workplace labelling systems defeat their purpose, because workers will avoid using them.
Do you have questions about workplace labelling? Are you looking for an easy, convenient and customizable solution? Contact ICC Compliance Center at 888-442-9628 (U.S.) or 888-977-4834 (Canada) to find out the many options we can provide for safe and effective workplace labelling.