Safety Tidbit 2.40 - Workplace Labels

Safety Tidbit 2.40 – Workplace Labels

Reference:        OSHA Hazard Communication Standard 1910.1200

This week is an old topic but with an interesting twist. An employer asked me, how do they put labels on their workplace containers of materials when the SDS says there is nothing hazardous?

OSHA Hazard Communication Standard (HCS) requires each container of hazardous chemicals in the workplace to be labeled, tagged or marked with:

A. Product identifier - Signal word - Hazard statement(s) - Pictogram(s) - Precautionary statement(s); and, Name, address, and telephone number of the chemical manufacturer, importer, or other responsible parties.

OR

B. 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.

Logically, the container cannot go unlabeled. At a minimum identification of the name of the product must be on the label. However, how is the worker to know what is inside is nonhazardous after they spill it all over themselves or worse get it into their eyes? I often see a label that says Simple Green but when asked about the contents I find that it has not been diluted to the point where the manufacturer specifies it is nonhazardous. Or, worse, when I ask the worker for the SDS they are unable to locate it without sifting through the employer's entire SDS book looking. Both instances are indications that the employer’s HCS training is inadequate. 

Hazard communication is about communicating the hazard of the chemicals in the workplace. It also implies that the employer will communicate about the chemicals used that are not hazardous. What I find interesting is that on an SDS recently the manufacturer said there were no hazardous chemicals as defined by OSHA. Then under first aid, they say to use in a well-ventilated area or if splashed in eyes, rinse thoroughly with an eyewash or induce vomiting or call Poison Control Center if ingested.  Any of these statements make me think that this is not “non-hazardous.”

Bottom line, if you can use a label from the manufacturer or distributor do so. If you must make a new label for a specific workplace container put as much information from Part A above as the SDS has on it. If no pictograms or signal words are necessary so be it.  But I find most items can be hazardous and caution is the prudent course of action and please let the employee have the information by means of a label.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have a burning safety or health question please let me know.