One question people keep asking is how the new GHS-compliant shipping labels required by OSHA’s new Hazard Communication 2012 regulation will affect the use of other labeling systems, including the labeling system required by the Department of Transportation (DOT) and the commonly known National Fire Protection Association (NFPA) and Hazardous Materials Identification System (HMIS) labels.
The question is even more interesting and timelier because OSHA recently published a Brief that announced they plan to make a small change to the new HazCom regulation involving DOT labels.
So without further ado, let’s get down to business and explain what’s what.
The GHS-Compliant Shipping Labels
The first thing you need to know is that the new regulation requires that chemical manufacturers, importers, and distributors put a GHS-compliant shipping label on every chemical container they ship.
These GHS-compliant shipping labels are the new labels you’ve heard so much about, and they include standard elements, including a product identifier, supplier identification, precautionary statement(s), hazard pictograms, a signal word, hazard statement(s), and supplemental information (that last one is optional). If that all sounds new to you, check out this earlier post.
GHS Shipping Labels and DOT Transport Labels
Once the chemical containers are labeled with GHS-compliant shipping labels and prepared for transportation, it’s important to know that both OSHA HazCom labeling requirements and DOT’s labeling requirements are in effect. So both labeling systems will be used.
However, it’s also important to understand how those labeling systems will “coexist,” particularly in two situations.
The first situation is when the GHS-compliant labeled chemical containers are put inside a larger, “outside” container for shipping. For example, when four labeled plastic gallon containers are put inside a larger, “outside” cardboard box. In that situation, the GHS-compliant shipping labels are on the smaller, “inside” containers, and a DOT label will be on the outside box.
The second situation is when you’ve got a larger chemical container that won’t be put into a separate, “outer” container for shipping. An example is a large chemical tote or a 55-gallon drum. In this case, BOTH the GHS-compliant shipping label and the DOT transport label will go on the same container.
But, it’s not quite that simple, as explained in OSHA’s recent brief on HazCom 2012 labels and pictograms. As the regulation is written today, when both labels are on the same container, the GHS-complaint label is NOT supposed to have the GHS pictograms on it. But, OSHA has announced that they plan to change that regulation so that the appropriate pictograms will appear on each label, and OSHA will not enforce this part of the current regulation. Read here for more information on that.
GHS Shipping Labels and Alternative Workplace Labels Including NFPA and HMIS
Once the chemical has been transported and has reached a workplace, the employer has a few labeling options.
One is to keep using the GHS-complaint shipping label from the manufacturer, and another is to use a similar label with all the same elements on it.
In addition, however, employers are allowed to use what OSHA calls alternative workplace labeling systems, and these include the NFPA and HMIS labels. The following is directly from OSHA’s website: “Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms.”
Late-breaking news: After the publication of this blog post, OSHA held a July 25 webinar discussing GHS and HazCom 2012. During that webinar, OSHA health scientist Kathy Landkrohn (Office of Chemical Hazards – Metals) said that "HMIS labels and NFPA ratings, by themselves, are not sufficient for workplace labels" (go to the 48:00 point of the webinar to hear her talk about this).
Still curious? Here's a related article written by the NFPA about NFPA 70 and HazCom 2012/GHS labels.