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With the new Hazard Communication (HazCom) standards requiring a specific Global Harmonization Standard (GHS) format for safety data sheets (SDS) and shipping labels, do I need to change my process tank labels to comply with the GHS?

The short answer is no.  When it comes to workplace labels, secondary labels and the like, under HazCom, OSHA gives employers a bit of flexibility.  OSHA is leaving it up to the employer, allowing them to use whatever system is best for their specific workplace and employees.  The following are labeling systems that can be used:

  1. Employers can provide on their workplace label all the information found on the shipping label.
  2. Employers can use some combination of the shipped label elements, which, in conjunction with the training they provide employees with their labeling system and other information available in the workplace, provide workers with all of the relevant hazard information.
  3. Use a customized labeling system which, in conjunction with training on the labeling system and other information available in the workplace, provides workers with all of the relevant hazard information.
  4. Use a National Fire Protection Agency (NFPA) or Hazard Materials Information System (HMIS) styled system.  Employers need to ensure employees are aware of all hazards of the chemicals to which they are exposed, based on the employer labeling system, training, and other information available in the workplace.

According to OSHAs HazCom Web page, in its FAQs:

The current standard provides employers with flexibility regarding the type of system to be used in their workplaces and OSHA has retained that flexibility in the revised Hazard Communication Standard.  Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule or with label alternatives that meet the requirements for the standard.  Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers.  However, the information supplied on these labels must be consistent with the revised Hazard Communication Standard, e.g., no conflicting hazard warnings or pictograms.

Under the previous HazCom standard, many companies used the NFPA/HMIS labeling system to meet the requirements of the standard.  Both the NFPA and HMIS are voluntary systems and have never been mandatory under the HazCom standard. 

Haz Com Label

The NFPA system uses a diamond-shaped diagram of symbols and numbers to indicate the degree of hazard associated with a particular chemical or material.  These diamond-shaped symbols are placed on containers, chemicals, or materials to identify the degree of hazard associated with the chemical or material.  The rating system utilizes a numeric system beginning with 0 as the least hazardous to 4, the most hazardous.

The HMIS is a numerical hazard rating incorporating the use of labels with color-coded bars as well as training materials.  It was developed by the American Coatings Association as a compliance aid for HazCom.

Haz Com Label2

The GHS includes criteria for classification of health, physical, and environmental hazards, as well as specifying what information should be included on labels of hazardous chemicals and on the SDS. OSHAs revised HazCom standard includes one of the biggest changes to shipping labels.  With the GHS adoption, labels on shipped containers include six standard elements:

  1. Product Identifier matching the product identifier on the safety data sheet
  2. Supplier Information including name, address and phone number of responsible party
  3. Signal Word, either Danger or Warning depending upon severity
  4. Pictogram(s), black hazard symbols on white background with red diamond borders that provide a quick visual reference of hazard information
  5. Hazard Statement(s) that describe the nature of the hazard and/or its severity
  6. Precautionary Statement(s) that provide important information on the safe handling, storage, and disposal of the chemical.  
Haz Com Label3

The difference between the GHS and NFPA/HMIS is in the numbers.  In the GHS, the lower the categorization number is the greater the severity of the hazard.  This is opposite for the NFPA/HMIS.  For example, with NFPA, the higher the number, the greater the severity.  This document compares the NFPA 704 and the new HazCom standard on labels. 

Another important difference is the numbers in the GHS system, as adopted by OSHA, do not show up on the label. Instead, they are used to determine what goes on the label.  The numbers do appear on the GHS formatted safety data sheets but in Section 2.  In the NFPA and HMIS systems, the numbers themselves appear on the label and are used to communicate information about the hazard.

OSHA stated in a brief on labels published in February 2013, employers may continue to use rating systems such as the NFPA or HMIS requirements for workplace labels as long as they are consistent with the requirements of the HazCom standard and the employees have immediate access to the specific hazard information.  An employer using NFPA or HMIS labeling must ensure through training its employees are fully aware of the chemical hazards being used.

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