It seems that just about every month, even during the COVID Pandemic, we come across a safety professional, 3rd party auditor, and even an OSHA CSHO who will swear on his/her grandmother’s grave that the ONLY acceptable HAZCOM labels in the workplace are those that contain:
- Product identifier;
- Signal word;
- Hazard statement(s);
- Pictogram(s);
- Precautionary statement(s); and,
- Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party
It is quite often a passionate presentation of how they are 100% correct and those who don’t believe them are wrong. I am not sure where this kool-aid is coming from or who is even making it, but too many safety professionals are drinking it!
The safety professional, 3rd party auditor, and even an OSHA CSHO understand how easy GHS is, and their anger turns to those who misled them. Honestly, some of the confusion is “honest confusion,” as I, too, was a lost soul back in 2012/2013. Luckily I was consulting by then which drove me to dig deep into this new HAZCOM standard and with the help of my right-hand man, Mr. Dennis Collins, we got it all figured out and held training sessions for many of our clients.
But this labeling issue will not seem to go away; I have written 14 articles since 2013 on just GHS labeling requirements, and I have been called everything in the book by those who had drunk the kool-aid. The OSHA language and literature from the standard, Compliance Directive, LOIs, etc., are never enough to shine the light on the fact that we can STILL USE the NFPA 704 Diamond and HMIS labels on our SECONDARY CONTAINERS. Even the actual GHS Standard, all the way back to the 3rd Revision in 2009 from which OSHA revised the HAZCOM standard to meet, clearly states that NOT all “workplace labeling” has to contain the six (6) GHS label elements (as noted above)…
(emphasis by me)