Friday, March 30, 2018

Safety Tidbit 3.32 - Labelled, Tagged, or Marked


Safety Tidbit 3.32 – Labelled, Tagged, or Marked

Reference:      OSHA Hazard Communication Standard


This week our topic is labeling on irregular containers, in this case, plastic pails of materials and very small squirt bottles. The OSHA Hazard Communication standard requires the employer to ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the information specified under paragraphs (f)(1)(i) through (v) of the standard for labels on shipped containers. Namely:
    Product identifier
    Signal word
    Hazard statement(s)
    Pictogram(s)
    Precautionary statement(s)
    Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.

In one of my cases this week the container was a plastic pail in a dusty environment. The other was small, one and two-ounce squirt bottles. When I walked through the facilities, there was no identification on any of the containers in either location so, hazard identification was easy. However, the employers’ concern was with how to abate the issue. They explained a label wouldn’t stay on the pails and to put all the required information on the small bottles was infeasible.

The answer for both became tagging. The employer must put all the required information on the tag then affix it to the containers. Interestingly, at the facility with the pails, we did find some old containers in the back that had tags already on them (but the information was illegible).

Ultimately, it doesn’t matter how small or irregular the container, OSHA’s Hazard Communication Standard requires the container to have some form of identification communicating to the user what the contents (and the hazards) are of the material within. Thus, the name of the standard – Hazard Communication.

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

P.S. If you have an interesting safety or health question please let me know.

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