OSHA further clarifies in-plant labeling vs. "shipped containers" labeling under the GHS (1910.1200(f)(1) 1910.1200(f)(6) 1910.1200(f)(7)
Background: Your company has an internal communication method to communicate the identity of hazardous chemicals transported on company vehicles from one location to another location within the same building (intra-plant). This method uses words, pictures, and/or product identification number, NFPA, HMIS, or DOT identifiers. The company also uses this communication method when transporting hazardous chemicals from one company property to another company property (inter-company). The internal communications methods are included in the company's written hazardous communication plan, which covers multiple company properties. During transportation, the hazardous chemicals do not leave the custody of trained company personnel. Question: Do the workplace labeling requirements in 29 CFR 1910.1200(f)(6) and 29 CFR 1910.1200(f)(7) apply when moving hazardous chemicals intra-plant and/or inter-company? (emphasis by me) |
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