Safety Tidbit #9: Hazard Communication Labeling

I’m sure all you readers are aware the 2012 Hazard Communication Standard permitted a phased compliance.  By June 1, 2015 (now obviously past) all chemical manufacturers, importers, distributors, and employers were to comply with the new provisions with labeling being the last item.  Labeling has two compliance dates, six months (December 1, 2015) following everyone’s supposed compliance with the 2012 revision manufacturers will no longer be permitted to ship containers not labeled appropriately.  The extra six months was based solely on economic reasons is supposed to give manufacturers and the like a chance to get rid of their previously labeled stock. The second compliance date for labeling gives employers a full year (June 1, 2016) from when they were supposed to comply with the 2012 Hazard Communication Standard to update their workplace labeling. Also, employers are to provide any additional training as necessary.

So why the extra time for labeling?  Simple, there is a lot of information on the new labels, tags, or marks.  Each original container must have the following: the product identifier, signal word, hazard statement, pictogram(s), precautionary statement(s), and the name, address and telephone number of the chemical manufacturer, distributor, etc. (1910.1200(f)(1)).

Now workplace labeling is getting a full year for compliance. Let’s start with the two exceptions. First, batch containers can continue use signs, placards, process sheets, batch tickets, operating procedures, or other written materials instead of affixing labels to individual stationary process containers.  The alternative method must identify the containers to which it is applicable and conveys the required information. The employer must ensure the written materials are readily accessible to the employees in their work area throughout each work shift (1910.1200(f)(7)).

The second exception is the same as from the 1994 Standard.  The employer does not need to label containers of hazardous materials that are for use by a single employee or immediate use.  The exception assumes that since the employee that is likely to be affected by the material already knows what is in the container because that worker put the material into the container.  Now if you find an unlabeled container lying around the shop, all bets are off, and it’s a good time to challenge the whole Hazard Communication Program implementation.  Specifically, ask them what is in the bottle, their knowledge of the hazard, where is the SDS, can they get the SDS, etc.

Therefore, other than the two exceptions above, all containers are to be labeled with all of the information I presented in the second paragraph.  However, the employer is still permitted to use a reduced labeling system. They can use a product identifier and words, pictures, symbols (NFPA), or a combination, which provide at least general information regarding the hazards of the chemicals. However, the other information required by the hazard communication program must be immediately available to employees.  The tough part of this alternative to having a label that meets all of the requirements is the training necessary.  As I mentioned above if you challenge the employee as to their knowledge of the hazard of the substance how many could pass? They may be able to find the SDS but can they read it and provide the hazard information?  Most often I find they cannot.

So my take home message is to get the label from the manufacturer or use a label that is equivalent to the manufacturer’s label with all of the information and leave nothing to doubt.  Remember, the standard is the Hazard Communication Standard so let’s make sure we are communicating.