In the past several years the use of NFPA’s 704 “Diamond” as a means for secondary labeling has seen much scrutiny; however, even OSHA has stated that this label can be used as an in-house secondary label under the GHS labeling requirements. (SAFTENG members can see my earlier articles on this topic in the OSHA Compliance Section). But the use of the “Diamond” comes with some basic requirements which we can find in NFPA 704. For example, should we accept a “colorless” diamond when our program cites colors, our training materials cites colors, as well as our HAZCOM educational postings throughout the facility show colors. Do the colors matter? Is this label “compliant” with your written program, training, and postings?
Let’s be real – the color may not be a major problem IF the employees can state what the sections at 12 o’clock, 3 o’clock, 6 o’clock and 9 o’clock represent. In fact, it is not that unusual (unfortunately) to find personnel who can not state the sections even when they are color coded, but that is simply a training issue – not a code issue.
Let’s see what NFPA says about the use of their “Diamond”…