7 HazCom Label Questions For OSHA

7 HazCom Label Questions For OSHA

Hazcom label rules are confusing. Get chemical labeling answers direct from OSHA on their Hazard Communication Standard, HCS, implemented June 1st.

Hear important information about pictograms, labeling bulk shipping containers, refillable containers, secondary containers and more.

In this podcast, we bring you highlights about HazCom labeling from a webcast presented by the SCHC OSHA Alliance featuring OSHA’s Lana Nieves and Sven Rundman of The Directorate of Enforcement Programs. SCHC is The Society for Chemical Hazard Communication.


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Dan Clark: OSHA’s June 1st deadline for chemical labeling has come and gone. Still, questions remain about the new Hazard Communication Standard requirements for labels. Two OSHA experts answer seven HazCom label questions next.

Hi there. I’m Dan Clark of The Safety Brief, tackling health and safety hazards in today’s demanding industrial and construction worksites, a service of Creative Safety Supply. Go to creativesafetysupply.com and use coupon code BIG10 to save yourself 10 percent.

OSHA has a new Hazard Communication Standard.

Sven Rundman: Directive 02-02-079

It’s aligned with GHS, the Globally Harmonized System. Chemical labeling needs to follow this new HazCom label standard as of June 1st of this year, but many are still confused.

OSHA, on September 9th, hosted a webinar with their experts to answer questions.

Sven: Hello everybody.

Lana Nieves: Hello everyone.

Webinar highlights included seven questions with OSHA HazCom label experts Sven Rundman and Lana Nieves.

#1. Sven, what are the HazCom label requirements for refillable containers?

Workplace Label

Sven: Well, for those that are refillable, it may be considered secondary container labeling and we could use workplace labeling for that. But if the contents of the refillable container came from a larger one and is being used by the individual who transported for their immediate use, then that portable container does not need to be labeled.

#2. Lana, what info has to be included on workplace labels? Some companies use NFPA labeling but have found that recent Safety Data Sheets don’t provide NFPA information.

Lana: Workplace labelings pretty much follow (f)(1) or else they use a product identifier, words, pictures or symbols or a combination of those, unless they fall under (f)(7) or (f)(8)—which is placards under (f)(8) and then (f)(7) is immediate containers. However, we don’t have jurisdiction over NFPA, so we can’t really enforce that on our SDSs. That would be out of our jurisdiction.

#3. If the original container has a pictogram on it, does the same pictogram need to be on the secondary container label?

Sven: Yes. But that pictogram on a secondary container does not need to have a red border. It can be a black border for the pictogram.

#4. Can you take a picture of the label on the original container, print it, and use that as a label for secondary containers?

Lana: Yes. As long as they can’t be defaced or tape fall off or come off. And, since it’s a secondary container, I would consider it an immediate container if they were going to use it immediately.

#5. Sven, is a HazCom label required for bulk shipping containers?

Sven: Under the Hazard Communication Standard, the label requirements are dependent on “Is it a stationary? Is it an in-house transport type container?” Depending on where it’s at in the shipping “mode,” I guess you could say, it could be, actually, DOT may have jurisdiction versus Hazard Communication. But I would refer to the compliance directives, specific on pages 48 and 49 of the compliance directive, labeling those types of containers.

HMIS label

#6. Will using HMIS labels for secondary containers after the June 1st, 2016, deadline still be in compliance with the standard?

Lana: If it’s used as supplemental information, then it can be in compliance as long as it has the HCS 2012 information.

#7. Please give us the workplace labeling requirements for secondary containers, such as spray bottles. Also does the Hazard Communication Standard cover consumer items in the workplace?


Secondary container image by Oregon OSHA

Sven: If a consumer product is used in the manner that one would normally use it in our home, then that product is not covered. Those types of spray bottles that you may buy at a hardware store and things of this nature are going to be labeled in compliance with the Consumer Product Safety Commission. So, there’d be no responsibility to providing the labeling of that information.

However, if it’s being used in a fashion above and beyond a normal consumer and you transfer that to a secondary container, then we would look at having workplace labeling on that secondary container, workers are properly trained and the safety data sheets are available.

Okay. Important answers to a few chemical labeling questions.

That’s all for this episode, 7 HazCom Label Questions For OSHA. Come back for more ways to stay safety compliant in today’s ever-changing landscape of safety requirements. I’m Dan Clark of The Safety Brief, a service of Creative Safety Supply. Save 10 percent off your entire order at creativesafetysupply.com with coupon code BIG10.


This podcast features highlights from the SCHC OSHA Alliance webcast Hazard Communication 2012 – Inspection Procedures for the Hazard Communication Standard: CPL 02-02-079. Hear and see the complete webcast here.

Tank image by US Dept Of Energy. Question mark graphic by PixaBay / Tumisu.

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