New GHS-aligned HazCom 2012 rules for Chemical Labeling in the Workplace

Z

zelwood

#1
I am a bit confused about how the new HazCom 2012 hazardous material labeling standards apply to instances of companies storing chemicals in the workplace, on their own property.

It was my impression that, in the U.S., the new GHS-aligned HazCom 2012 labeling requirements only applied to people originally packaging or shipping the chemicals. And that ?workplace labels? could vary in appearance as long as the labels met the requirements for the required information.

In OSHA's FAQ about the new standard, it says (highlight added):

Q. What are the major changes to the Hazard Communication Standard?



A. The three major areas of change are in hazard classification, labels, and safety data sheets.
  • Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result.
  • Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
  • Safety Data Sheets: Will now have a specified 16-section format.
Other mentions of ?chemical manufacturers and importers? in these documents lead me to believe that the HazCom rules are focused on the chemical creators.

Then, in that same FAQ, it says this:


Q. How will workplace labeling provisions be changing under the revised Hazard Communication Standard?
A. The current standard provides employers with flexibility regarding the type of system to be used in their workplaces and OSHA has retained that flexibility in the revised Hazard Communication Standard (HCS). Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard. Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms.


The fact that they have a separate section for ?workplace labeling provisions? makes me think it?s an entirely different thing, and it sounds like there is more ?flexibility? when it comes to workplace labeling.
 
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Randy

Super Moderator
#2
Workplace labeling is in reference to situations when small quantities of material are transferred from a a larger (original) container into a smaller one (example...material from a 1 gallon can to a 4 oz spray bottle)

There's a bit more language to it (refer to 29cfr 1910.1200) but all non original containers have needed labeling for close to 40 years with the type of lable being a decision of the organization as long as the minimum information is on it.

The 16 part msds transition will take quite a while for implementation
 
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