OSHA has answered four basic HAZCOM labeling questions posed by a chemical manufacturer regarding the upcoming labeling changes with the GHS. The four questions are:
Question 1: We purchase preprinted labels that have three empty frames with red borders so that we may place appropriate pictograms on them when making our product labels. We understand that OSHA does not allow a blank frame on the final product label. If our product requires only one or two pictograms, may we simply black-out the unused frame(s)? Also, is it acceptable to add “See Adjacent Pictograms” within the blacked-out area of the label?
Question 2: Are pictogram “stickers” or sets of two or more pictograms printed-On strips of paper with adhesive backing adequate to meet the requirements of Appendix C to 29 CFR 1910.1200?
Question 3: Since the U.S. Department of Transportation (DOT) has no pictogram requirement under 49 CFR 172.402, how should we interpret the statement from section C.2.3.3, “Where a pictogram required by the Department of Transportation under Title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in C.4 for the same hazard shall not appear?”
Question 4: What is the meaning of the term “shipped container” within the context of Appendix C.2.3.3? All containers destined for transport in commerce will eventually be shipped. Does OSHA require both the inside container and the outside box or overpack to be labeled when a chemical is classified as corrosive and/or flammable?
CLICK HERE (pdf) for the actual OSHA letter with answers.