Labeling for Hazardous Communication

Introduction

OSHA's 29 CFR 1910.1200 Hazard Communication Standard (Haz-Com), which is also known as the "Right-to-Know" law, was enacted in 1983 for general industry and includes nearly one-fourth of the nation's workforce. It is routinely one of OSHA's most frequently cited standard with 6,704 citations in 2006.

The purpose of the standard is to protect workers from the chemicals they encounter in the workplace. It is about communicating and training workers to do their jobs safely every day. Labeling is one of the main focuses of the Haz-Com Standard, but by itself it is inadequate to protect workers from the hazards of chemicals. Training workers to understand and read both the Material Safety Data Sheet (MSDS) and the label is necessary for safe chemical awareness. [For more information on Hazardous Communication please refer to EZ Facts document number 150, "Hazard Communication (Right-to-Know) 29 CFR 1910.1200."]

What Needs To Be On a Label

Chemical manufacturers or distributors must provide the following information on chemicals that leave their facility: Identity of the hazardous chemical(s), appropriate hazard warnings, and name and address of the chemical manufacturer, importer or other responsible party. [29 CFR 1910.1200(f)(i)]

The employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information: Identity of the hazardous chemical(s) contained therein and appropriate hazard warnings. [29 CFR 1910.1200(f)(5)]

Which Label Should I Use?

The Haz-Com Standard sets only general guidelines. All labels must be in English, but is is a matter of personal preference as to which system or combination of systems are adopted. Lab Safety Supply offers three different types of label systems: Right-to-Know (RTK), National Fire Rating (NFR), and Hazardous Material Identification Guide (HMIG).

RTK labels offer an easy-to-understand, complete labeling system. These labels list the chemical name, common name or synonym, signal word, hazard information, precautionary measures, first aid procedures and the CAS number. No chart for interpretation of hazards is necessary. Personal protection pictorials can be added to the RTK system for additional worker awareness.

The NFR system uses a hazard rating colored diamond code for ranking the health, flammability and reactivity of hazardous chemicals in the presence of fire. Substances are assigned a rating of 0–4, with 4 being the most hazardous. Several pictorials alert workers to hazards such as water reactive and radioactivity. Books, charts and wallet cards are available for an explanation of the rating system.

The HMIG system is similar to the NFR system except the label is in a color bar format and rectangular, rather than diamond, shape. The definition of the health ratings is not based on fire exposure, but on acute and chronic hazards present in normal day-to-day operations. It includes twelve icons for personal protective equipment. Charts and wallet cards are available in English and Spanish for interpretation of colors, numbers and symbols. The Spanish version may help promote safety in a bilingual workplace. [29 CFR 1910.1200(f)(9)]

Hazard Rating Numbers

Sources and hazard determinations can be found in 29 CFR 1910.1200(d), Hazard Determinations; Appendix A, Health Hazard Definitions; Appendix B, Hazard Determinations and Appendix C, Information Resources. Hazard determinations are best left to product toxicologists or other comparable trained health professionals. Hazard rating numbers can be obtained from several books including the Fire Protection Guide to Hazardous Materials and the National Fire Rating Guide for over a thousand common chemicals. Information may also be taken off the MSDS, or you can contact the chemical manufacturer.

Labeling Exemptions

Labels do not always have to adhere to a container. Labels, placards, batch tickets or signs can be placed on shelving or posted where similar stationary containers are stored. No labels are required on portable transfer containers of ten gallons or less, as long as the chemical is used, discarded, or returned to the labeled mother container by the end of the work shift. [29 CFR 1910.1200(f)(7)] Although it is not required, labeling of transfer containers for safety and liability reasons is suggested.

Target Organ Labels

A new court case has ruled that it is reasonable for manufacturers to include the proper target organ warning on hazardous chemicals. A September 15, 1993 ruling by the U.S. Court of Appeals involving a major chemical manufacturer concluded that, "labels should have been more explicit as to what organs could be affected." The interpretation of 29 CFR 1910.1200(f)(1)(ii) and Appendix A was that "appropriate hazard warnings" include target organ labels. The Court rejected the OSHA review commission's ruling that the standard did not require such warnings on labels.

Training

Each labeling system requires training so employees can interpret the icons, numerical indexes and color meanings on labels. Designate someone to conduct training of employees and to be responsible for labeling. Train workers to take the time to read both the MSDS and the label before working with a chemical. Make sure the labels and the MSDS use the same chemical or common name so they can be easily cross-referenced. Keep a signed sheet of all employees who attend training programs.

A survey of the U. S. workforce done at the University of California Berkely revealed that nearly half of the workforce cannot understand training materials or warning signs. After the initial training, there is no requirement for annual training unless a new chemical is added. However, refresher trainings are essential if workers are expected to understand and remember the details of the chemical labeling system.

Commonly Asked Questions

Product Reference

Lab Safety Supply has the products you need to keep your workers safe and comply with current regulations. Please refer to the Books, Labels, Right-to-Know and Training sections of your Lab Safety Supply General Catalog for details.

Sources for More Information

29 CFR 1910.1200 Hazard Communication