Globalized System Labeling

October 28, 2014

By:  Bill Cosgriff, Environmental, Health & Safety Manager

Many product labels will soon be very different in the United States.

OSHA is currently implementing some of the most sweeping changes to Hazard Communication regulations since it was created in 1983. The first part is the standardization of Safety Data Sheets (see the Q2 2014 Amerimulch® newsletter). Part II regards the changing requirements for container labeling. The purpose of the changes is:

  • To standardize labeling content.
  • Assure the important information is always on each label.
  • Harmonize the system internationally.
  • Communicate hazards regardless of language.

GHS labels will be required to have all of the following:

  • Product name or chemical name.
  • Hazard pictogram.
  • Signal word.
  • Hazard statements.
  • Supplemental information.
  • Precautionary statements.
  • First aid information.
  • Name and address of the manufacturer.
  • Telephone contact information of the manufacturer.

PRODUCT IDENTIFIER

The product identifier must match exactly the name of the substance on the Safety Data Sheet or SDS. The product identifier at the top of the label will be a chemical name which accurately describes the substance, and should include a CAS number for chemicals. For mixtures a product name must list each of the chemical ingredients that contribute to acute toxicity, including those causing skin corrosion, eye damage, mutagenic or carcinogenic affects, reproductive affects, skin or respiratory sensitization or target organ toxicity.

HAZARD STATEMENTS

Hazard Statements are standardized phrases determined by clearly defined hazard classes of the product and its constituents in the case of mixtures. These will match the SDS for the product.

SIGNAL WORDS

Signal words will always be either “Warning” for less hazardous substances and “Danger” for more hazardous substances. Only one signal word may be used.

PRECAUTIONARY STATEMENTS

Precautionary statements and supplemental information will list the precautions that must be taken in order to control the hazards listed in the hazard statements.

PICTOGRAMS

Pictograms must match those on the SDS. Pictograms are symbols that can be understood internationally regardless of language or literacy. They are standardized internationally. Each symbol will always be the same for each hazard class. Hazard classes are assigned by OSHA for worker safety. They are similar to that used US DOT for transportation. Some of these may look similar, but keep in mind that these are two different labeling systems. Pictograms must be shaped as a four sided diamond on point. They must have a white background with a red border. The symbol itself must be black. A hazard statement must match each pictogram and be listed on the same label. There are regulated sizes for labels depending on the size of the container. However, there is no specification on label location on the container. There can be more than one pictogram if the single product has more than one hazard.

MANUFACTURER IDENTIFICATION

The name of the manufacturer or supplier of the substance must appear on the label along with contact information for the manufacturer or supplier including an address and telephone number. Company logos and brand names may still be used on the labels. The layout or design of the labels has not been mandated by OSHA except that signal words must be located where the pictograms appear on the label.

WORKPLACE CONTAINERS

Workplace containers are such things as storage tanks, vessels, pipes, cabinets or other storage devices. These too will have the same hazard communication requirements. Pipes should be labeled at intervals along the pipe.

TRANSPORTATION

Transportation labels are still required. In most cases the DOT label will appear on outer packaging while the safety labels will appear only on inner packages. However, you could see both labels on containers such as drums and totes. Different countries are adopting the (GHS) or Global Harmonized System at different rates. Make sure you know the labeling requirements of any nation in which transport products.

IMPLEMENTATION

The changes are being phased in over time. Currently the following deadlines apply.

  • Employee training completed by Dec. 1, 2013.
  • Revised SDS completed by June 1, 2015. Container labeling can begin.
  • Revised Hazard Communication plans completed by June 1, 2015.
  • Container Labeling required by Dec.1, 2015.
  • Changes to EPA and DOT regulations have been proposed but have not been formalized.

EXEMPTIONS

Not all products are required to have the new labeling system. There are exceptions. Products that have no hazards as defined by OSHA will not have them. Human and veterinary pharmaceutical products are not covered under the new regulations for consumer packaging, but these products and their components could have labeling requirements for larger containers in the work place. Also food additives and cosmetics will not be covered at the point of consumption. However, again these products and their raw materials may be covered in the worplace for occupational safety. Pesticide residue on the surface of products is not considered an additive and does not require additional labeling. Food products are not covered under Hazard Communication regulations. GHS labeling is not required for consumer safety, but it is required for occupational safety in the workplace.

With a little foresight employees will be properly prepared for the changes coming to communications regarding the safe handling of chemicals in our workplaces.

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