Tuesday, September 8, 2015

Does OSHA's HazCom Standard Prohibit NFPA / HMIS Labeling Systems?

It seems like once every week or two I get a call or email from someone asking me if I’d help clarify for them OSHA’s requirements on labeling of in-house containers and secondary containers per the revised Hazard Communication standard. Apparently many people think that OSHA now requires all in-house containers be labeled with the pictograms and other information adopted from the Global Harmonized System of Classification and Labeling of Chemicals (GHS), and that OSHA no longer allows the use (some even say they “outlaw” the use) of other hazard labeling systems such as those created by the National Fire Protection Association (NFPA) and the Hazardous Materials Identification System (HMIS).
 
In actuality, it is only those containers shipped by manufacturers, importers, and distributors that are required by OSHA’s updated Hazard Communication standard to be labeled with all the GHS-related information (specifically, a product identifier, signal word, hazard statement(s), pictogram(s), precautionary statements, and the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party). But when it comes to labeling of in-house containers . . .
 
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10 comments:

  1. My facility currently (plans to transition) uses HMIS is house. Having the two label system only confuses workers, especially when you tell them ABC has 4 major sections and XYZ has 6.

    I have been looking for "Generic", adhesive, self laminating, GHS labels for our spray bottles. Another Idea is to label the area of bottle use with one big label.

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  2. I usually teach that the labeling of secondary containers, like spray bottles or squirt bottles can be labeled with "wd-40" or "alcohol" as long as the name on the containers lead the employee to the proper SDS. Is this correct? I read in this blog that you are nearly recommending that the employee or employer must duplicate the original label for all spray bottles.

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  3. I usually teach that the labeling of secondary containers, like spray bottles or squirt bottles can be labeled with "wd-40" or "alcohol" as long as the name on the containers lead the employee to the proper SDS. Is this correct? I read in this blog that you are nearly recommending that the employee or employer must duplicate the original label for all spray bottles.

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    Replies
    1. The answer to your question is found at 1910.1200(f)(6)(i) and (ii). There are two options for labeling the secondary (or in house) containers. Option 1 (in paragraph (I)) requires the containers be labeled with the same info as the manufacturer's label, whereas paragraph (ii) gives us a second option, that being to label the container with "Product identifier AND 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."

      As you can see, option 2 is less onerous than providing full labeling requirements, but does go beyond simply placing the name of the product (product identifier) like you described. Hope this helps.

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  4. We were using the HMIS labels for years but decided that it would be too confusing to continue. We have updated our written program, completed employee training again, and have converted in-house labels to GHS format (orange or green workplace labels, and placards with pictograms). We have worked hands-on with the staff at most of our facilities and heard all the complaints. The GHS system may be an improvement for shipping but it is more difficult for the worker using the chemical to know what they need to do to protect themselves. Many more labels on low-risk oil-based materials now say "Danger" or extreme verbiage. More materials are classified in 'flammable' category. The labels are too cluttered with precautionary statements, and the real information they need is obscured..

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  5. We are currently using HMIS labels for our internal chemicals and I do not see a reason to switch. Our process works well, everyone understands the numbering on the HMIS label (1-4, 4 being the most hazardous), and everyone understand chemicals coming in are labeled differently. Over 90% of our employees never see the manufacturing labels nor transfer chemicals from the manufacturing container to the workplace "secondary" container. For me, it is a matter of ensuring employees understand the hazards they are working with and know how we protect them from the hazards. Our employees have been trained in the new GHS labels and understand that we, non-chemical manufacturers, can stick with what we are currently doing.

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  6. We are sticking with both. Yes, it takes a bit more training, however, it is REALLY hard to label small containers with all the words required by the new standard (can you say writer's cramp!?!). Also, our employees don't want to spend their day writing out labels. Some of these labels are so big they can't even fit on the larger containers! We made one label for shipping that you can add the pictograms from a dropdown list and you can pull down or write in the statements and the hazard warning needed. Then, we updated our earlier HMIS labels for in-house use (which already had a slight variation from HMIS) to add two new warnings in the special section ("HH" for health hazard and "PG" for pressurized gases) and it's totally working for us!

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  7. We have multiple above ground storage tanks and are continuing to use NFPA 704 along with the product identifier, capacity & tank id number which is posted on each tank. This (seems) to satisfy the intent of the labeling standard by linking the product identifier back to the SDS. It also gives first responders the immediate information they would need.
    Will the 704 labeling method ever become obsolete? Maybe, but this is a universal method of communicating hazards to any and all US first responders.
    In my opinion, the conflicting hazard 'category' numbering system of the GHS is the major flaw in the transition. Realizing the 'new' way might have been the way of the world - except here, may have been the driver for changing.

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    Replies
    1. All facilities should keep using NFPA on tanks, buildings, rooms and containers, as appropriate, to communicate the presence of hazards with emergency responders. NFPA labeling is part of most state and community building codes so I dont' see this changing any time soon.
      Don't get hung up with the ratings. GHS ratings are used to determine classification and appropriate wording of phrases but are not a required label element. They are very complex (i.e. some are 1-5 and others 1, 2A, 2B) so other than low is worst than higher ratings, it may be better to train employees to the how the signal words, pictograms and the phrases change as the severity increases. Using NFPA labeling for secondary containers may be appropriate in bulk plants.

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  8. What about non-GHS products that have an SDS with ratings in the H, F, R fields? Do I have to label these secondary containers with HMIS labels or since it isn’t a GHS product I can go with no label at all?

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