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A Comparison of Chemical Labeling Systems
Document Number: 198
OSHA’s 29 CFR 1910.1200 Hazard
Communication Standard (Haz Com), also known as the “Right to Know”
law, was first enacted on November 25, 1983 by OSHA.
The purpose of the standard is to protect workers from the chemicals
they work with in their workplace. This standard requires training and
the conveying of safety information to workers regarding the chemicals
they come into contact with on the job.
These labels are required to contain specific information that apply
to the chemicals used in the workplace;
1910.1200(f)(1)
“The chemical manufacturer, importer, or distributor shall ensure that
each container of hazardous chemicals leaving the workplace is labeled,
tagged or marked with the following information”
1910.1200(f)(1)(i)
“Identity of the hazardous chemical(s)”
1910.1200(f)(1)(ii)
“Appropriate hazard warnings; and”
1910.1200(f)(1)(iii)
“Name and address of the chemical manufacturer, importer, or other responsible
party.”
1910.1200(f)(5)(ii)
“Appropriate hazard warnings, or alternatively, 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.”
Although the Haz Com standard sets only general guidelines for labeling
it does specify that all labels must be in English. Bi-lingual
chemical labels (i.e. English and Spanish) are allowed and offered
as an option where a language barrier is present.
There are several labeling systems common to the workplace. These include:
RTK—Right to Know
NFPA 704/NFR National Fire Rating
HMIG—Hazardous Material Identification Guide
HMIS—Hazardous Material Identification System
WHMIS—Workplace Hazardous Material Information System (a Canadian based
chemical identification labeling system)
This document's purpose is to identify the characteristics that each
of these systems have to offer.
The RTK
labeling system consists of labels that list the chemical name, synonym
or common name, hazard information, CAS (Chemical Abstract Service) number
and precautionary measures and first aid procedures. (See below)
NFPA 704 / NFR (National Fire Rating)
The National
Fire Protection Association labeling system employs a color-coded
rating guide in a diamond shape.
Health is defined by the color blue, Flammability is red and Instability
is represented in yellow. The numbers are assigned according to the level
of hazard the chemical(s) present 0-4. Thus 0 being no hazard and 4 the
greatest hazard. This labeling option offers books,
charts and wallet cards to help explain the classification.
NFR Signs
are commonly seen on the exterior of a building or storage vessel containing
chemical storage. In the event of a fire or emergency these signs alert
the fire department or emergency responders to the types of chemical hazards
that are present. See below for an example of this type of sign or label;
The HMIG labeling
system also presents a color formatted label and is rectangular in
shape. The numbers used in this system to identify the hazard level of
the chemical are based on the acute and chronic hazards present in normal
day to day use in the workplace. There are also charts,
labels
and wallet cards for this system. (For example see below)
The numbers for the HMIG
labeling systems can be obtained from MSDS sheets accompanying the
chemical or reference books that list chemical hazards by number rating
such as The Fire Protection Guide to Hazardous Materials as well as the
National Fire Rating Guide.
These three systems (RTK,
NFR and HMIG)
are all offered through Lab Safety Supply.
Another common labeling system similar to the HMIG system that Lab Safety
Supply offers is called HMIS III. It is It looks similar in nomenclature
to the HMIG labeling system (using the color bar format and rectangular
shape) and utilizes a rating system similar to the HMIG system. HMIS III
refers to Hazardous Materials Identification System. The HMIS III rating
system has recently been revised. The most significant change to the label
has been to the physical hazard section of the label. Along with the assigned
number, an icon is now present: compressed gas, explosive, oxidizers,
etc. This is to allow for easier identification of the presence of a specific
hazard to the employee. (See an example below.)
WHMIS is the Canadian version of the OSHA Right To Know
labeling system. WHMIS labels are required on all controlled products.
A controlled product is defined as “a material or product, which is imported
or sold in Canada that meets the guidelines of the hazardous material
classification.” With this system the employer is required to educate
and train their workers that are exposed to hazardous materials in their
workplace. (See example below)
All of the above labeling systems (except WHMIS) are acceptable
according to OSHA. However, once a system has been chosen, OSHA prefers
to see consistency and that all chemicals are labeled according to the
labeling program that has been chosen by the workplace. Also it is required
that all employees must be trained to, and understand the system that
is being implemented and used by the facility.
Commonly Asked Questions
| Q. |
Is one of the labeling systems better than another? |
| A. |
No. One labeling system is not better than the other. OSHA recognizes
all of these, however keep in mind consistency is the key. Once, you
choose a system all chemicals should be labeled the same. |
| Q. |
I was told to buy an NFR Sign Kit to place outside of my
building; How do I know what numbers should be assigned to the Health,
Flammability, Instability and Special Hazards areas on this sign? |
| A. |
If you are in doubt about the hazard ratings for your NFR sign,
it is best to check with your local authorities such as your local
Fire Marshal to obtain the appropriate hazard ratings for your facility.
They are able to make an assessment of the chemicals being used and/or
stored and will be able to inform you how this sign should read for
responders in the case of an emergency. For a general guide to chemical
hazard labeling on common industrial chemicals LSS offers the 14683
Hazardous Materials NFR Pocket Guide. |
| Q. |
What do I put in the Special Hazards section of the NFR Labels
and Signs? |
| A. |
Special Hazard symbols represent materials that offer a specific
hazard such as an acid, corrosive, oxidizer, radiation or materials
that react violently or explosively with water which are identified
as water reactive chemicals. The Fire
Protection Guide to Hazardous Materials (LSS PN# 5013) references
these symbols and their meanings to this particular rating system.
|
Sources for More Information
OSHA's
29 CFR 1910.1200 Hazard Communication Standard
National Fire Protection Association
EZ FACTS Documents:
150 The
Hazard Communication Standard
157 WHMIS-Canadian
Right to Know System
178 NFPA
704 Standard System for the Identification of Hazardous Materials
200 Labeling
for Hazard Communication
OSHA
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Please Note: The information contained in this publication
is intended for general information purposes only. This publication is not
a substitute for review of the applicable government regulations and standards,
and should not be construed as legal advice or opinion. Readers with specific
questions should refer to the cited regulation or consult with an attorney.
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