PART TWO: GHS Labeling Requirements
This is the second of a three-part series which provides an overview of the GHS impact on the Occupational Safety and Health Administration’s (OHSA) Code of Federal Regulations (CFR) 1910.1200; the following pertains to new GHS labeling requirements for chemical hazards in the United States.

Systems which have been already in place may have labels which look different for the same product, this can lead to employee confusion, consumer uncertainty and the requirement of additional resources to maintain systems. In the United States and other countries, chemical products are regulated by sector; different agencies regulate workplace, consumers, agricultural chemicals and transport. In the U.S., regulatory requirements for workplace labels are performance-oriented. This means that a label has a product identity, hazard statement and supplier identification. Many companies follow the voluntary American National Standards Institute ANSI Z129.1 Precautionary Labeling Standard for workplace labeling. The ANSI Standard includes several label elements that are core to the GHS.

New GHS Standardized Labeling Requirements:

• Symbols (hazard pictograms): Health, physical and environmental hazard information, assigned to a GHS hazard class and category. Nine pictograms are used to convey health, physical, environmental hazards; HCS requires eight, the exception being the environmental pictogram which is not within OSHA’s jurisdiction; pictograms have a black symbol on a white background with a red diamond frame
• Signal Words: “Danger” or “Warning” used to emphasize hazards and indicate relative level of severity, assigned to GHS hazard class and category.
• Hazard Statements: Standard phrases assigned to a hazard class and category that describe the nature of the hazard
• Product Identifier–Must match safety data sheet
• Manufacturer Contact Information–name, phone number, and address
• Supplemental Information –Provides further details related to the hazard
• Precautionary Statements–Steps employees can take to protect themselves

The product name, company’s name, address and phone, standardized hazard statement, a pictogram and a precautionary statement must appear on the label. Under the former OSHA standard, a hazard could be expressed using any statement. With GHS, there is a prescribed hazard statement assigned to each hazard category. There’s also a requirement for a pictogram, or a symbol, conveying a visual idea of the hazard. A precautionary statement is how an individual should respond to the hazard information (i.e. first aid instructions, personal protective equipment, etc.) Lastly, there’s a requirement for a signal word: ‘Danger’ or ‘Caution’. This differs from the previous OSHA rule, which required name and address, the name of the product and appropriate hazard warnings, which could vary dramatically.

The HCS workplace labeling option (a common practice in many U.S. workplaces) is allowed in the GHS; as such, OSHA will continue to give employers the flexibility to determine what types of workplace labels will be required. Employers may label workplace containers either with the same label that the chemical manufacturer or importer used on shipped containers, or with alternate labels that meet the GHS labeling requirements of the HCS Standard. This makes it critical to initiate site-specific evaluation and safety training programs to mitigate risk onsite.

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