DISCLAIMER: I am NOT suggesting we do this; just asking the group for their thoughts on a challenge I got this week.
In all the discussions about using NFPA 704 Diamonds on Secondary Containers, from laboratory squirt bottles to bulk storage tanks, today I was asked if DOT Placards could be used to label STATIONARY storage tanks?
I said NO, those are for Transportation Containers, but then I began to question my answer. Why not?
Sure, they are intended for transportation containers, but they are COLOR CODED, contain pictogram images, the HAZMAT Class, and a 4-digit UN #. Add the chemical name above/below the placard, and do we have an OSHA-compliant label for a secondary container?
It should go without saying that the facility would have to include these in its HAZCOM training, which most already do.
The question is… does it meet 1910.1200(f)(6)?
1910.1200(f)(6) Workplace labeling. Except as provided in paragraphs (f)(7) and (f)(8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either:
1910.1200(f)(6)(i) The information specified under paragraphs (f)(1)(i) through (v) of this section for labels on shipped containers; or,
1910.1200(f)(6)(ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.