When OSHA aligned the Hazard Communication Standard 1910.1200 with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in 2012, it was with good reason. Prior to these modifications, numerous internal and external chemical labeling systems existed, which often meant confusion for workers, delays in shipping and loss of business revenue. This was especially true when products had to be shipped or received across national borders.
Moving to a harmonized system allowed a uniform structure for labeling, as well as hazard information, to be disseminated. Today, over 65 countries share the GHS system. And while each have country-specific versions, the increasing use of the GHS worldwide has brought greater ease and transparency to chemical safety use and shipping.
The merging of GHS with OSHA’s Hazard Communication Standard (HCS) did not replace the regulation. Instead, it augmented the main HCS purpose, which was to convey hazard information to workers in an effective and meaningful way.
That included changes to chemical labeling. Understanding the GHS-aligned chemical labeling that’s now part of OSHA’s HazCom Standard is quite simple, but there are key terminologies and components you’ll need to learn to use the system in your workplace.
We’ll explain those in this article.
Haz-Com Safety Data Sheets and Chemical Labels
GHS alignment of the OSHA HazCom Standard was meant to be a practical approach to:
- Express and define health and physical hazards of chemicals. (Environmental hazards of chemicals are also included in GHS, although these are outside of OSHA’s jurisdiction.)
- Apply classification methods that use available data to define hazard criteria
- Communicate hazard information in a uniform and systematic way on labels and SDS
Two of the best places for workers to learn about the hazards of chemicals at the workplace are safety data sheets (now called SDSs; these were known as MSDSs before the 2012 HazCom/GHS alignment) and the chemical labels.
Let’s learn a little more about each before we continue to discuss the chemical labels.
Safety Data Sheets (SDSs)
As part of the GHS-alignment of OSHA’s Hazard Communication 2012 Standard, the old material safety data sheets (MSDSs) were dropped and new safety data sheets (SDSs) were integrated. Safety Data Sheets are well-organized and comprehensive, with 16 different sections that are functional and easy to understand. As a result, the safety data sheet is the best place to look for in-depth explanations of the hazardous potential of a chemical at work.
This sample from our online Hazard Communication training course explains the different parts of an SDS.
Chemical Labels Under HazCom 2012
Labels on chemical containers are smaller than a safety data sheet and, as a result, they can’t include as much information. But they DO still have lots of important safety information that is easy accessible, at the point of use, and easy to understand.
Remember that labels are only meant as a fast reference for those who use, handle, transport or store hazardous chemicals.
The GHS-compliant Hazard Communication chemical label elements are illustrated in the sample from our online Hazard Communication training course below.
What Are the GHS-Aligned HazCom Label Elements?
The following elements are required on hazardous chemical labels:
- Supplier Identification. Name, Address and Telephone Number of the chemical manufacturer, importer or other responsible party.
- Product Identifier: For example, the chemical name, code number, or batch number. The manufacturer can choose how to identify their product.
- Signal Words: These indicate the severity of the chemical hazards. There are two options for signal words:“Danger” and “Warning.” “Danger” indicates more severe hazards, while “Warning” indicates less serious hazards.
- Hazard Statements: These are short, to-the-point statements that list physical, health, and environmental hazards of the chemical. Examples might include “Extremely flammable liquid and vapor” or “Harmful if inhaled.” Hazard statements, (like all things GHS) are standardized and are selected by the chemical manufacturer based on the classification of the chemical.Each hazard statement has a code, which begins with the letter H and is followed by three digits. According to the HCS, only the hazard statement phrase is required for labeling. However, at the chemical manufacturer’s discretion, the code may appear on labels with the assigned hazard statement, and is also featured on SDS.
- Precautionary Statements: These describe recommended measures to take to minimize or prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling of the chemical. There are four types of precautionary statements. These are brief and meant to convey important information rapidly. An example would be““Keep away from heat, spark and open flames.”See below for more information about these.
- Pictograms: These are graphic symbols used to communicate specific information about the hazards of a chemical. There are nine pictograms in use on GHS aligned labels, but only eight of them fall under OSHA’s jurisdiction, as one is used for environmental hazards. With their bright red, white and black color scheme, and clear graphics, pictograms stand out and serve as strong visual indicators of hazards. See below for more about pictograms.
Supplemental Information: In addition to these required label elements, chemical manufacturers may also opt to include supplementary information, such as expiration dates of products, recommended PPE or other pertinent details.
More about the GHS Pictograms
There are nine pictograms in use on GHS aligned labels, but only eight of them fall under OSHA’s jurisdiction, as one is used for environmental hazards. The eight pictograms called for by OSHA’s HazCom Standard are shown below.
According to OSHA, “The required pictograms consist of a red square frame set at a point with a black hazard symbol on a white background, sufficiently wide to be clearly visible.” With their bright red, white and black color scheme, and clear graphics, pictograms standout and serve as strong visual indicators of hazards.
The sample video from our online Hazard Communication training course walks you through the eight HazCom pictograms and the environmental pictogram as well.
And below we’ve got a closer look at the pictograms for you.
Flame Over Circle: Chemical Oxidizer
(Flammables, pyrophoric, self-heating, self-reacting, emits flammable gases, organic peroxides)
(Unstable explosives, explosives, self-reactive substances and mixtures, organic peroxides)
Skull and Cross Bones
(Acute toxicity and/or rapid death)
(Skin corrosion/burns, eye damage, corrosive to metals)
(Gases under pressure)
(Carcinogens, mutagenicity, reproductive toxicity, target organ toxicity, aspiration toxicity)
(Skin or eye irritant, limited acute toxicity, narcotic effects, respiratory tract irritant)
And, even though it’s not part of the OSHA HazCom Standard, it’s worth knowing about the GHS Pictogram for Environmental Hazards, as well. That’s it below.
More about Precautionary Statements
The four types of precautionary statements are:
- Prevention (ways to minimize exposure)
- Response (actions to take for first aid, spills, exposures)
- Storage (methods to safely store the product, incompatible storage conditions)
- Disposal (safe disposal methods of product and containers containing residual product)
Classification and Label Creation
To create a product label, chemical manufacturers or importers/distributors are required to classify chemicals according to designated criteria that is outlined in appendices of the Hazard Communication Standard.
Chemical hazards for the updated HCS have three groups; health, physical and environmental. Classification then is based upon 16 physical hazards, 10 health hazards and 2 environmental hazards.
Each hazard classification is then further divided into categories, according to different severity levels. Categories are rated 1-4, with 1 as the most severe. Stop here and let that sink in.
Many employers are familiar with the NFPA or the HMIS labeling systems, which applied a 0-4 rating hazard rating system, with zero being the lowest hazard and four as the most severe. These were the common chemical labeling systems in use in US businesses for several decades. It’s important to note that the GHS uses an inverse rating system. Don’t forget that or draw on previously learned knowledge about other chemical rating systems you’ve used before.
After the above steps, chemical manufacturers are to compare those hazards found with Appendix C of the HCS and select the appropriate label elements. This process is much more streamlined than in earlier years, prior to the GHS adoption. It eliminates the guesswork and uses available scientific data to place a chemical in the proper hazard classifications and categories.
HazCom Training for Employees Required by OSHA
OSHA spells out the requirements for Hazard Communication employee training in 1910.1200(h). They include the following:
- Employers must provide employee with information & training on hazardous chemicals in their work area at the time of their initial assignment plus whenever a new chemical hazard that the employee has not previously been trained about is introduced into the work area.
- Information and training may be designed to cover categories of hazards or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets.
The employee should be informed of:
- The requirements of 1910.1200(h)(2)
- Any operations in their work area where hazard chemicals are present
- The location and availability of the organization’s written hazard communication program, including the list of hazardous chemicals at the workplace and the safety data sheets
- Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, and more)
- The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area
- The measures employees can take to protect themselves form these hazards, including specific procedures the employer has implemented to protect employees form exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used
- The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by the employer; the safe data sheet, including the order of information and how the employees can obtain and use the appropriate hazard information.
This online hazard communication training course is a good addition to your employee HazCom training program.
Conclusion: HazCom and GHS Label Requirements, Symbols, and Classifications
Make sure your workers know the important aspects of chemical labeling, SDS and the new components of the GHS aligned HCS.
And for further details on the HCS and ways to comply, you can explore this article and the information links provided.
You may also find these Haz-Com related articles helpful:
And don’t forget the free guide to effective EHS/safety training, below.
Effective EHS Training: A Step-by-Step Guide
Learn how to design, create, deliver, and evaluate effective EHS training by following these best practices with our free step-by-step guide.