There is a difference in labels on “shipped containers” and “workplace labeling”

I am guessing we may be having this debate for the next 20-30 years, as before OSHA revised their HAZCOM standard to the Globally Harmonized version we were still debating the requirements of the original HAZCOM standard up to the day it got changed (e.g., 30+years).  But it seems there are companies benefiting from the confusion and selling supplies and equipment that are NOT needed in order to comply with the GHS labeling requirements AND we are seeing chemical manufacturers, importers, and distributors who are NOT meeting their labeling obligations, which in turn are placing many workplaces at risk of non-compliance.  In this article, I hope to, once again, dispel the GHS labeling myths that seem to be so prevalent in our workplaces.

There are two (2) distinct labeling requirements in the GHS:

1. Shipped Container labeling (1910.1200(f)(1)
2. Workplace labeling (1910.1200(f)(6)

OSHA requires the following information to be on “SHIPPED CONTAINERS” from chemical manufacturers, importers, and distributors:

1. Product identifier (1910.1200(f)(1)(i)
2. Signal word (1910.1200(f)(1)(ii)
3. Hazard statement(s) (1910.1200(f)(1)(iii)
4. Pictogram(s) (1910.1200(f)(1)(iv)
5. Precautionary statement(s) (1910.1200(f)(1)(v)
6. Name, address, and telephone number of the chemical manufacturer, importer, or another responsible party (1910.1200(f)(1)(vi)

So that is the labeling requirements for the containers leaving the chemical manufacturer, importer, or distributor workplace and arriving at our workplace. 

When we receive these “shipped containers,” OSHA gives us two (2) labeling options for these containers as we use them within our workplace(s):

1. Using the labels on the shipped container(s) (1910.1200(f)(6)(i), OR
2. Using a new label that has the 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.

NOTE: SAFTENG members should also see my article “Workplace Labels (sometimes called secondary, internal or in-house labels) under OSHA’s GHS” for more on the use of NFPA 704 and HMIS labeling systems

So as we can see, OSHA does permit us to use the labeling on the “shipped container(s)” as long as that label provides AT LEAST the following information:

1. Product identifier (1910.1200(f)(1)(i)
2. Signal Word (1910.1200(f)(1)(ii)
3. Hazard Statement(s) (1910.1200(f)(1)(iii)
4. Pictogram(s) (1910.1200(f)(1)(iv)
5. Precautionary Statement(s) (1910.1200(f)(1)(v)

You may have noticed that there are only five (5) items listed above vs. the six (6) items required for shipping containers.  I am not quite sure why OSHA listed only the five (5) items, leaving off the Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party (1910.1200(f)(1)(vi) requirement, seeing how 1910.1200(f)(9) PROHIBITS a facility from removing or deface existing labels on incoming containers of hazardous chemicals, unless the container is immediately marked with the required information.  So when the container arrives, it must have the six (6) items on the label, we’re not allowed to deface the label, and then we can use that “shipping label” as long as it has the five (5) items.

I will add this if the workplace allows for the “shipped container” labels which are using the DOT Placard label, which OSHA says they will accept on “workplace labels,” be sure to include these placards in your training program.  Although they are both diamond shaped and the symbols are mostly the same, there are differences and employees need to recognize these differences.