Hazard Communication 2012 (HazCom 2012) and GHS - Everything You Always Wanted to Know (But Were Afraid to Ask)

By now, you’ve probably heard that the new HazCom 2012 standard has been revised to align with the Globally Harmonized System, or GHS. If we just caught you 100% unaware, you are now excused to go read the information on OSHA’s website about the GHS alignment.

However, we suspect most of you know about this, but that you have been wondering just exactly what it means. Or maybe you’ve wondered about a few of the details. If so, the following is for you.

What and when do I have to train my workers?

Before December 1, 2013, you have to train your workers on the new elements of a GHS-compliant shipping label and on the new safety data sheet (SDS) format.

Is there a transition period?

Yes. A few, really.

June 1, 2015 is the deadline for compliance with all modified parts of the HazCom standard.

An exception is made for distributors, who can continue shipping chemicals from manufacturers and importers that do not have GHS-compliant shipping labels until December 1, 2015.

And, employers have until June 1, 2016 to update their hazard communications programs as necessary, update alternative workplace labels as necessary, and to provide additional training to employees for any newly identified physical or health hazards.

OSHA has more details about effective dates for HazCom GHS on their site.

What does a GHS-compliant shipping label look like?

Here's an example:


The labels that chemical manufacturers, distributors, and importers must put on containers of hazardous chemicals don’t have to be exactly alike, but they do have to have the following elements.

The label elements are:

  • A product identifier that explains what the product is.
  • The name, address, and telephone number of the manufacturer or importer.
  • Precautionary statements that list measures to follow in order to use or store the chemical more safely.
  • A pictogram that represents the type of hazard.
  • A signal word that indicates how severe the hazard is. The signal word will be “Danger” for severe hazards or “Warning” for less severe hazards.
  • A hazard statement which describes the hazard or hazards in words.

Sample GHS-compliant label from OSHA website.

Which parts of the GHS label are “harmonized?”

In addition to the six label elements that must appear on all shipping labels as described above, the following are standardized:

  • Any pictogram on the label must be one of the nine GHS pictograms (see list and images below)
  • The signal word on the label must be either “Danger” or “Warning”
  • The hazard statement on the label is drawn from a list of hazard statements in the HazCom Standard

Finally, the pictogram(s), signal word, and hazard statement(s) used on the label are all determined by matching the hazard(s) that the chemical presents to specific classes and categories of hazards defined in the HazCom standard (for more on this, see Appendix A for health hazards and Appendix B for physical hazards). The standard then assigns an appropriate pictogram, signal word, and hazard statement to use for each category/class of hazard (see Appendix C for more on this).

What do the GHS label pictograms look like?

There are nine GHS label pictograms, though OSHA only requires the use of eight.

The mandatory pictograms, and the types of hazards they represent, are:


The ninth pictogram represents environmental hazards. Although OSHA doesn’t require its use, other agencies (such as the EPA) may.

You can download free vector GHS symbols here.

Will DOT labels still be used for transport?

When a chemical is being transported, DOT regulations still apply. As a result, “outside” shipping containers still must be labeled with the DOT label or placard (featuring the DOT pictograms).

Read more about the DOT and GHS here.

Can one chemical container have both a GHS shipping pictogram and a DOT transport pictogram?

No. When a DOT pictogram is put on a container, a GHS pictogram should not be on the same container.

What kind of labels can be used at the workplace?

Once a chemical is at a workplace, employers have a few labeling options. First, they can continue to use the GHS shipping label or a label with the same format. Or, they can use alternative workplace labels, including the NFPA and HMIS labels you may already be familiar with.

For more on this, see 1910.1200(f)(6)(ii).

What kind of labels can be used at the workplace?

A safety data sheet, or SDS, is very similar to what you know of as a Material Safety Data Sheet, or MSDS. In addition to the slight name change, the SDS now has a standard format with information presented in 16 sections. Those sections are:

  • Section 1, Identification
  • Section 2, Hazard identification
  • Section 3, Composition/information on ingredients
  • Section 4, First-aid measures
  • Section 5, Fire-fighting measures
  • Section 6, Accidental release measures
  • Section 7, Handling and storage
  • Section 8, Exposure controls/personal protection
  • Section 9, Physical and chemical properties
  • Section 10, Stability and reactivity
  • Section 11, Toxicological information
  • Section 12, Ecological information
  • Section 13, Disposal considerations
  • Section 14, Transport information
  • Section 15, Regulatory information
  • Section 16, Other information

See the brief on the OSHA website for details about the SDS.

What about other types of hazards?

Read our separate posts about requirements for what OSHA is calling hazards not otherwise classified and for pyrophoric gases, simple asphyxiants, and combustible dusts.

2 comments:

Anonymous said...

For Warehousing activities, will a company who stocks inventory in their own warehouses need to re-label containers to be GHS compliant post Dec. 1, 2015 if they will end up shipping (interstate, intrastate, and outside the country) material to their other site locations...for their employee use? Does this company meet OSHS's definition of a "distributer"?

Jeffrey Dalto said...

Hi, Anon.

Here's the definition of "distributor" from the regulation:
""Distributor" means a business, other than a chemical manufacturer or importer, which supplies hazardous chemicals to other distributors or to employers."

Source: https://www.osha.gov/dsg/hazcom/HCSFinalRegTxt.html

And this page on our blog gives a free interactive glossary: http://blog.convergencetraining.com/2012/10/free-interactive-hazard-communication-2012-hcs-glossary.html