Ensure Containers are Labeled
Paragraph (f) of HazCom 2012 mandates that employers keep labels on shipped containers and to label secondary containers if used.2,4 Labels provide the primary information about hazards and protective information. In addition to the product identifier, label elements must include pictogram(s), a signal word, hazard statement(s), precautionary statement(s), and the name, address and phone number of the source of the hazardous chemical (Figure 5).
The product identifier is any chemical, common, or trade name or designation that the chemical manufacturer or importer chooses to use on the label. The product identifier on the label must be the same as the one included in the SDS. A signal word (e.g., “danger” or “warning”) indicates the relative level of severity of hazard. The signal word “danger” is used for the more severe hazards, while “warning” is used for the less severe hazards.
A hazard statement describes the nature, and when appropriate, the degree of hazard. For example, “fatal if swallowed” is a hazard statement for acute oral toxicity. The hazard statement conveys that the chemical is severely toxic, and ingestion of the chemical results in death. For less toxic chemicals, the hazard statement may be “toxic if swallowed” or “harmful if swallowed,” which convey a less severe hazard.
A pictogram may be a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazard. Some pictograms are symbols that resemble the hazardous effect, others are merely meant to attract attention. The eight pictograms designated under HazCom 2012 are black symbols on a white background with red diamond borders (Table 3).
When the shipping container is also the container used in the workplace, workers must be made aware of the U.S. Department of Transportation (DOT) pictograms (Table 4), as they may appear on the label in addition to or instead of HazCom 2012 pictograms. The symbols have been harmonized as much as possible for hazards covered both by OSHA and DOT. The DOT pictograms are also diamond-shaped, but their backgrounds are of various colors.
Precautionary statements describe recommended measures to minimize or prevent adverse effects or events resulting from exposure to a hazardous chemical or improper storage or handling (e.g., do not eat, drink, or smoke when using this product). There are four types of statements: prevention, response, storage, and disposal. Supplemental information is permitted as long as it does not conflict with the required information.
Employers are required to ensure that containers of hazardous chemicals in the workplace are labeled. If the containers received from the supplier are used in the workplace, simply maintain the label received from the supplier. The HazCom 2012 label system is the best and easiest option, but, for secondary containers, other systems (e.g., National Fire Protection Association (NFPA) or Hazardous Materials Identification System (HMIS) are acceptable.
The employer must also make sure that the labels are legible and prominently displayed. While the label information must be in English, employers are free to add warnings in other languages if workers would find that helpful. OSHA has prepared QuickCards™ to describe the label elements (OSHA 3492)5, as well as to illustrate the pictograms (OSHA 3491)6. These are available on the OSHA website, or can be obtained from your local OSHA area office.5
Box C. Labels.4
Section C: Labels
(Name of responsible person and/or position) will verify that all containers received from a distributor for use are clearly labeled in accord with the requirements of HazCom 2012, including a product identifier, pictogram(s), hazard statement(s), signal word, and precautionary statements, as well as the distributor’s contact information (include name and name and address of supplier).
(Name of responsible person and/or position) in each work area will ensure that all secondary containers are labeled with the original distributor’s label or with an alternative workplace label. For help with labeling, see (name of responsible person and/or position).
We are using an in-house labeling system (describe any in-house system which conveys required workplace label information). (Name of responsible person and/or position) will review our labeling procedures every (provide a time period) and will update labels as required.