Take the Mystery Out of Your Chemical Container Labeling
Dec 16, 2019
It’s that time of the year when folks are carefully wrapping boxes in brightly colored paper and labeling them with just enough information to help get the gifts to the right person but keep the contents a secret until they’re opened. After all, it’s the mystery of what’s inside that creates so much holiday magic. But when it comes to the chemical containers in our workplace, we need to take exactly the opposite approach, because what we don’t know can hurt us, or our coworkers.
Labeling requirements under OSHA’s HazCom Standard and other global hazard communication regulations are designed to address these kinds of uncertainties.
During my previous roles as an EHS regulatory consultant and Global EHS Coordinator, I can recall many times where confusion about the contents of containers posed real safety concerns. I recall one instance in which there was a small glass jar containing a bright yellow-orange liquid. It looked a lot like a sports drink, but was it? The yellow mystery liquid could also have been a highly toxic chemical. Since the container wasn’t labeled, workers in that area didn’t have enough information to handle it safely, and were at risk of mistakenly ingesting a chemical that could lead to serious injury or even a fatality.
OSHA’s HazCom Standard, which is currently aligned with Revision 3 of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals, seeks to protect workers by establishing labeling requirements for all containers, whether they are the original shipped chemical containers or secondary containers that chemicals are transferred to, sometimes referred to as workplace containers.
Shipped Container Labels
Requirements for shipped containers are prescriptive, meaning that there are six label elements that a manufacturer absolutely needs to include on the container. These six elements are:
- Manufacturer identification: The name, address and telephone number for the chemical manufacturer. An OSHA letter of interpretation from 2018 clarified that if you import chemicals, and the SDSs authored outside the United States list foreign phone numbers and addresses as primary contacts in Section 1, you may be responsible for authoring new SDSs containing domestic contacts in Section 1.
- Product identification: The identification of the hazardous chemical, either by the chemical name, CAS registry number or batch number.
- Signal word: This is a word used to indicate the severity of the chemical hazards. There are only two possible signal words you’ll see: “Danger” and “Warning.” The most severe hazards are designated by the signal word “Danger.” What if the same chemical product has hazards that merit a “warning” and others that merit a “danger?” You’ll still only see “danger” on the label, because it’s the more severe of the two.
- Hazard statement: These are statements describing the specific hazards of a chemical, such as “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.” Chemical manufacturers should always use the same exact statement for the same chemical hazards, so that the dangers are completely clear to all users.
- Precautionary statement: These are recommendations for measures users can take to minimize risks of use and storage, or to respond to chemical incidents. These statements may address storage practices, including incompatible materials to avoid. For example, keep drums of strong acids away from strong bases! (As a consultant, I once observed a location that had drums of sulfuric acid stacked directly on top of drums of sodium hydroxide. If you know even a little bit about chemistry, you know that’s probably not a good idea!) Statements may also include clean-up and disposal measures in the event of a release, and first-aid treatment following an exposure.
- Hazard Pictograms: There are 9 pictograms that can be used to represent the various hazard classifications. Eight of them are mandatory if triggered by the hazard classification process, while the ninth pictogram (for environmental hazards) is optional. The nine allowable pictograms under the GHS-aligned HazCom Standard are shown below:
The requirements for the secondary/workplace container labels are more flexible. For employers, you have the option to either replicate the manufacturer’s shipped container label, or you can create your own workplace labels containing the product identifier and a combination of other pieces of chemical hazard information. The image below shows what these container label formatting options might look like.
That’s not to say that these options are created equal. Since the manufacturer’s shipped label requirements are prescriptive, if you simply replicate those labels, you’ve quickly met your obligations. Choose an option other than that, and you’ll need a system in place to supplement whatever information you’re including on the label. That additional information may include training, work instructions, risk assessments, signage, and the SDSs for the chemical in use.
The key point here is that any alternative workplace labeling system, consisting of the label plus other information, must provide your workers with immediate access to specific information regarding the physical and health hazards of the chemical. Even more importantly, you’ll need to be ready to demonstrate to OSHA that your system works in the event they ever ask – such as during an inspection. That’s why we recommend simply replicating the shipped label whenever possible.
Also, remember that workplace labeling is challenge in large part because most workplaces have so many secondary containers, including solvent cans, oil transfer buckets, and benchtop spray bottles. The reality for many workplaces is that employees are often more likely to be exposed to chemicals within workplace containers than they are to chemicals in the original shipped containers, because once the shipped container arrives, the contents are transferred to many different secondary containers for multiple points of use. Compounding the problem, many secondary containers such as vials and test tubes may be very small, which poses additional labeling difficulties.
As an employer, you’re also responsible for ensuring that labels remain on both shipped and workplace containers, and that the labels are visible and legible. If you identify containers where the labels are missing or defaced, you must immediately replace them.
Employers should consider the benefits of a chemical management software platform that enables fast, easy printing of workplace labels that replicate the shipped label for most of your containers. If you have small secondary containers in your workplace, these systems can also help you with printing of smaller labels containing the product identifier and selected HazCom elements.
Save the surprises for your holiday gift-giving! Take the mystery out of chemical container labeling, and give yourself and your workers the best present of all — a safer workplace.
Let VelocityEHS Help!
Don’t forget that when you use MSDSonline for SDS and chemical management, you get the ability to quickly print workplace labels for the full range of container sizes in your workplace, helping you simplify HazCom compliance and give your workers the knowledge they need to work safely.