GHS 101: Labels
GHS: Hazard Communication Labelling
The development of a harmonized hazard communication system, including labelling, safety data sheets and easily understandable symbols, is one of the major objectives of the GHS.
To that end, the GHS includes appropriate labelling tools to convey information about each of the hazard classes and categories.
Using symbols, signal words or hazard statements, other than those which have been assigned to each of the GHS hazard classes and categories would be contrary to harmonization.
Nevertheless, it is recognized that in some circumstances the demands and rationale of systems may warrant some flexibility in whether to incorporate certain hazard classes and categories for certain target audiences.
The GHS takes into consideration the needs of the target audience that will be the primary end-users of the harmonized communication scheme as well as the manner in which these audiences will receive and use the information.
Additionally, the overlapping needs of target audiences was also taken into consideration. Those audiences include:
- Employers and workers need to know about the specific hazards related to the chemicals used or handled in the workplace, and about specific protective measures required to avoid adverse effects.
- Packaging and storing of a chemical can minimize hazards, however, workers and emergency responders need to know mitigation factors are appropriate in case of an accident – i.e. they may require information that can be read at a distance.
- In addition to the label, additional information is available to workers through the SDSs and workplace risk management system.
- The label is likely to be the sole source of information readily available to the consumer.
- Consumer education is more difficult and less efficient than education for other audiences.
- The issue of comprehensibility is of particular importance for this target audience since they may rely solely on label information.
- Emergency responders need information on a range of levels, including accurate, detailed and sufficiently clear information to facilitate an immediate response.
- Fire fighters need information that can be seen and understood at a distance, such as graphical and coded information.
- Wide-range of target audiences, especially transport workers and emergency responders.
- Information needed by different transport workers is dependent upon the type of work done and amount of contact they will have with hazardous items.
- i.e. Drivers may need only limited information unless they are also responsible for the loading and unloading of packages and/or filling of tanks.
Comprehensibility / Translation / Standardization
One aim of the GHS is to present information in a manner that the intended audience can easily understand. The following principles are meant to assist the communication process:
a. Information should be conveyed in more than one way
b. Comprehensibility of components of the system should take into account existing evidence from studies, literature and tests
c. Phrases used to indicate degree of severity should be consistent across different hazard types (This was a hotly debated topic – since it is difficult to directly compare physical hazards. In the end, it was felt that it is possible to help audiences put the degree of hazards into context and convey the same degree of concern)
Consideration was given to the comprehensibility of translated words to ensure they conveyed the same meaning.
For labels, the hazard symbols, signal words and hazard statements have all been standardized and assigned to each of the hazard categories and these should appear on GHS labels as indicated for each hazard class.
The GHS recognizes that other label elements may need to appear that have not been standardized, i.e. precautionary statements.
However, to prevent unnecessary variation, it is recommended that supplementary information be limited to:
a. Further detail that does not contradict or cast doubt on validity of hazard information
b. Information about hazards not yet incorporated into the GHS
The GHS also accepts that the Labeller should have the option of providing supplementary information related to the hazard in the hazard statement rather than in the supplementary information section on the label.
The GHS stipulates that all systems should specify a means of responding to new information and updating labels and SDS information.
Suppliers should respond to new and significant information about a chemical hazard by updating the label and SDS.
This applies to any information that changes GHS classification of the substance or mixture and leads to a change in the information provided on labels and SDSs.
This could include new information on a potential adverse chronic health effect – even if it hasn’t yet triggered a change in classification.
Updating should be carried out promptly on receipt of information that necessitates the revision.
Suppliers should also periodically review information on which labels and SDS for substances are based.
Competent authority may choose to specify a time (3-5 years) from the date of original preparation within which suppliers should review information.
Confidential Business Information
Systems should consider confidential business information (CBI): however, CBI provisions should not compromise health and safety of workers and competent authorities should consider:
a. Whether inclusion of chemicals in CBI is appropriate to the needs of the system.
b. What definition of CBI should apply – taking account of factors like accessibility of information to competitors, intellectual property rights, and potential harm disclosure would cause employer or suppliers business.
c. Appropriate procedures for disclosure of CBI where necessary
Provisions for CBI in different systems should be consistent with following principles
a. For information otherwise required on labels or SDS, CBI claims should be limited to the names of the substances and their concentrations in mixtures – all other information should be disclosed on label or SDS as required
b. Where CBI has been withheld should be indicated on label and SDS
c. CBI should be disclosed to competent authority upon request, which should then protect confidentiality of the information.
d. Where a medical emergency exists (as determined by medical professional), timely disclosure of CBI should be assured.
e. For non-emergency situations, CBI should be disclosed to safety or health professional providing medical or other safety and health services.
f. Where non-disclosure of CBI is challenged, competent authority should address such challenges or provide process for challenges. Supplier or employer should be responsible for supporting the assertion that information qualifies for CBI protection.
Training is an integral part of hazard communication and should be appropriate and commensurate with the nature of the work and exposure.
Procedures for preparing labels in the GHS:
a. Allocation of label elements
b. Reproduction of the symbol
c. Reproduction of the hazard pictogram
d. Signal words
e. Hazard statements
f. Precautionary statements and pictograms
g. Product and supplier identification
h. Multiple hazards and precedence of information
i. Arrangements for presenting the GHS label elements
j. Special labelling arrangements
The GHS provides tables for each hazard class. The tables detail the label elements (symbol, signal word, hazard statement) that have been assigned to each of the hazard categories of the GHS.
Here are the hazard symbols which should be used in the GHS. All of the symbols, aside from the environment symbol, are part of the standard symbols used in the UN recommendations on the transport of Dangerous Goods model regulations.
Pictograms and Reproduction of Hazard Pictograms
Pictogram means a graphical composition that may include a symbol plus other elements, such as a border, background pattern or color that conveys specific information.
All hazard pictograms should be in the shape of a square set on a point (diamond).
For transport, the pictograms prescribed by the UN Model Regulations on the Transport of Dangerous Goods should be used.
Transport pictograms must have minimum dimensions of 100mm by 100mm, with exceptions for smaller pictograms on very small packaging and gas cylinders.
Transport pictograms have symbol on upper half of label. The pictograms should be affixed to a background of contrasting colour.
Pictograms prescribed by the GHS, but not the transport pictograms, should have a black symbol on white background with a red frame sufficiently wide enough to be clearly visible.
***GHS gives the option of using a black border for packages that will not be exported (note – OSHA has indicated it plans to require a red framed border, whether the package is for domestic or international use.)
Competent authorities may choose to use a transport pictogram outside of an area not covered by transport regulations – such as the exclamation point which is used for skin irritant.
Allocation of label elements
On packages covered by the UN Model Regulations on the Transport of Dangerous Goods: where a transport pictogram appears, a GHS pictogram for the same hazard should not appear.
GHS pictograms not required for transport should not be displayed on freight containers, road vehicles or railway cars.
GHS Label Requirements
Information required on a GHS label:
1. Signal words
a. A word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. Signal words used in GHS are “Danger” and “Warning.” Danger is for the more severe hazard categories. Signal words are assigned to each hazard category
2. Hazard Statements
a. A phrase assigned to a hazard class and category that describes the nature of the hazards of a hazardous product, including when appropriate, the degree of the hazard.
b. Hazard statement and code: Hazard statement codes are intended to be used for reference purposes – they are not part of the text and should not be used to replace it.
3. Precautionary statements
a. Phrase (and/or pictogram) that describes the recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous product. GHS label should include appropriate precautionary information, the choice of which belongs to the labeler or competent authority.
b. Precautionary codes are used to uniquely identify precautionary statements and are for reference purposes – they are not part of the precautionary text and should not be used to replace it.
4. Product Identifier
a. Product identifier should be used and it should match product identifier used on the SDS. If mixture is covered by UN Model regulations for transport of Dangerous goods, UN proper shipping name should also appear on package
b. Label for substance should include the chemical identity of the substance. For mixtures and alloys – label should include chemical identities of all ingredients or alloying elements that contribute to acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, skin or respiratory sensitization, or specific target organ toxicity (STOT). When these hazards appear on the label
c. Where a substance or mixture is supplied exclusively for workplace use, competent authority may choose to give suppliers discretion to include chemical identities on the SDS, in lieu of including them on labels.
d. The competent authority rules for CBI take priority over the rules product identification and ingredients meeting criteria for CBI do not have to be included on the label
5. Supplier identification
a. Name, address and telephone number of the manufacturer or supplier of the substance or mixture should be provided on the label.
Substances or Mixtures with More than One GHS Hazard
There is a precedence of symbols depending upon the use and audience. For substances and mixtures covered by UN Model Regulations, the precedence of symbols for physical hazards should follow the rules of UN Model regulations. In workplace situations, competent authority may require all symbols be used. For health hazards, the following precedence apply:
a. If skull and crossbones applies, the exclamation mark should not appear [as used for acute toxicity]
b. If corrosive symbol applies, exclamation mark should not appear as used for skin or eye irritation
c. If health hazard symbol appears for respiratory sensitization, the exclamation mark should not appear where used for skin sensitization or skin or eye irritation.
Precedence for allocation of signal words
a. If signal word Danger appears, Warning should not appear
Precedence for hazard statements
a. All assigned hazard statements should appear on the label – except as provided below. Competent Authority may specify order.
b. To avoid duplication or redundancy – following rules may be applied
i. If statement H410 “very toxic to aquatic life with long lasting effects” is assigned, statement H400 “very toxic to aquatic life” may be omitted.
ii. If H411 “toxic to aquatic life with long lasting effects” is assigned, H401 “toxic to aquatic life” may be omitted.
iii. If H412 “harmful to aquatic life with long lasting effects” is assigned, H402 “harmful to aquatic life” may be omitted.
iv. If H314 “causes severe skin burns and eye damage” is assigned, H318 “causes serious eye damage” may be omitted.
Arrangements for Presenting the GHS Label Elements
Location of GHS information on the label
GHS hazard pictograms, signal word and hazard statements should be located together on the label. Competent authority may choose to provide specified layout for the presentation of these and for the precautionary information or allow supplier discretion.
Competent Authority may allow supplemental information to be used on label – in such instances they may also choose where it appears – in any case, it should not impede identification of GHS information
Color can be used on other areas of the label besides the pictogram as allowed by competent authorities
Labelling of Small Packages
a. All applicable GHS label elements should appear on the immediate container of a hazardous substance or mixture where possible
b. Where impossible to put all the applicable label elements, other methods of providing the full hazard information should be used in accordance with the definition of Label in GHS – factors influencing this include:
i. Shape, form or size of immediate container
ii. Number of label elements to be included
iii. Need for label elements to appear in more than one official language
c. Where volume of hazardous substance or mixture is so low and there is not likelihood of harm to human health and/or environment – with competent authorities okay – label may be omitted.
d. Certain label elements may be omitted with permission from competent authority where volume of substance or mixture is below a certain amount
e. Some labelling elements on the immediate container may need to be accessible throughout the life of the product, e.g. for continuous use by workers or consumers
Special labeling arrangements
Competent authority may allow communication of certain hazard information for carcinogens, reproductive toxicity and specific target organ toxicity through repeated exposure on label and SDS or on the SDS alone – same for metals and alloys when supplied in the massive, non-dispersible, form.
Products falling within the scope of GHS will carry the GHS label at the point where they are supplied to the workplace, and that label should be maintained on the supplied container in the workplace.
The GHS label or label elements should also be used for workplace containers
However, competent authority can allow employers to use alternative means of giving workers the same information in a different format when appropriate to the workplace and it communicates the information as effectively as the GHS label – for instance info could be displayed in the work area, rather than on individual containers.
Alternative means of communicating hazards are needed usually where hazardous chemicals are transferred from original supplier containers to secondary containers or where chemicals are produced in a workplace but are not packaged in containers for intended for sale or supply.
In many situations it is impractical to produce complete GHS labels and attach it to the container due to size limitations or access to a process container (e.g. containers for laboratory testing, storage vessels, piping or process reaction systems). In such instances, systems should ensure there is clear hazard communication and workers should be trained to understand the specific communication methods used in a workplace.
See GHS R3 184.108.40.206.5.1 for examples of how communications can be handled in such situations
Consumer product labelling based on the likelihood of injury
Competent authorities may allow labelling based on likelihood of harm, rather than based on hazard for consumer labelling.
Tactile warnings, if used, should conform to ISO 11683:1997 “Tactile warnings of danger: requirements