Hazard Communication Labeling
Hazard communication labeling is about communicating and training workers to do their jobs safely every day. OSHA's 29 CFR 1910.1200 hazard communication standard (HazCom), which is also known as the "Right-to-Know" law, was enacted in 1983 for general industry and includes nearly one-fourth of the nation's workforce. It routinely is one of OSHA's most-frequently cited standards with 6,704 citations in 2006.
The purpose of the standard is to protect workers from the chemicals they encounter in the workplace. Labeling is one of the main focuses of the standard. But by itself, it is inadequate to protect workers from the hazards of chemicals. Training workers to understand and read material safety data sheets and labels is necessary for safe chemical awareness and proper hazard communication labeling. For more information on hazard communication labeling, refer to Quick Tips #150: Hazard Communication Standard, 29 CFR 1910.1200.
Chemical manufacturers and distributors must identity hazardous chemicals, appropriate hazard warnings, the names and addresses of chemical manufacturers, and importers or other responsible parties on their labels, according to 29 CFR 1910.1200(f)(i).
The employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information: Identity of the hazardous chemical(s) contained therein and appropriate hazard warnings. [29 CFR 1910.1200(f)(5)]
The haz-com standard sets only general guidelines. All labels must be in English, but it is a matter of personal preference as to which system or combination of systems is adopted. Grainger offers three types of label systems: Right-to-Know (RTK), National Fire Rating (NFR), and Hazardous Material Identification Guide (HMIG).
RTK labels offer an easy-to-understand, complete labeling system. These labels list the chemical name, common name or synonym, signal word, hazard information, precautionary measures, first aid procedures and the Chemical Abstract Service number. No chart for interpretation of hazards is necessary. Personal protection pictorials can be added to the RTK system for additional worker awareness.
The NFR system uses a hazard rating colored diamond code for ranking the health, flammability and reactivity of hazardous chemicals in the presence of fire. Substances are assigned a rating of 0 to 4, with 4 being the most hazardous. Several pictorials alert workers to hazards such as water reactive and radioactivity. Books, charts and wallet cards are available for an explanation of the rating system.
The HMIG system is similar to the NFR system, except the label is in a color-bar format and rectangular shape, rather than a diamond shape. The definition of the health ratings is not based on fire exposure, but on acute and chronic hazards present in normal day-to-day operations. It includes 12 icons for personal protective equipment. Charts and wallet cards are available in English and Spanish for interpretation of colors, numbers and symbols.
Sources and hazard determinations can be found in 29 CFR 1910.1200(d), hazard determinations; appendix A, health hazard definitions; appendix B, hazard determinations; and Appendix C, information resources. Hazard determinations are best left to product toxicologists or other comparably trained health professionals. Hazard-rating numbers can be obtained from several books including the "Fire Protection Guide to Hazardous Materials" and the "National Fire Rating Guide" for more than 1000 common chemicals. Information also may be taken off the MSDS, or you can contact the chemical manufacturer.
Labels do not always have to adhere to a container. Labels, placards, batch tickets or signs can be placed on shelves or posted where similar stationary containers are stored. No labels are required on portable transfer containers of 10 gal. or less, as long as the chemical is used, discarded, or returned to the labeled mother container by the end of the work shift, according to 29 CFR 1910.1200(f)(7). Although it is not required, it is suggested that transfer containers be labeled for safety and liability.
A U.S. Court of Appeals case ruled Sept. 15, 1993, that it is reasonable for manufacturers to include the proper target organ warning on hazardous chemicals. The interpretation of 29 CFR 1910.1200(f)(1)(ii) and appendix A was that "appropriate hazard warnings" include target organ labels. The court rejected the OSHA review commission's ruling that the standard did not require such warnings on labels.
Each labeling system requires training so employees can interpret the icons, numerical indexes and color meanings on labels. Designate someone to conduct employee label training. Train workers to take the time to read material safety data sheets and labels before working with a chemical. Make sure the labels and the MSDS use the same chemical or common name so they can be easily cross-referenced. Keep a signed sheet of all employees who attend training programs.
A survey of the U.S. workforce done at the University of California-Berkeley revealed that nearly half of all workers cannot understand training materials or warning signs. After the initial training, there is no requirement for annual training unless a new chemical is added. However, refresher trainings are essential if workers are expected to understand and remember the details of the hazard communication labeling and chemical labeling system.
|Q.||How do I label a 10% bleach solution using the NFPA ratings?|
|A.||The NFPA standard does not allow reduction of the hazard rating if chemicals are stored in small quantities or diluted concentrations without testing. Label this as a full-strength solution.|
|Q.||Is there any way I can protect my paper labels from being defaced?|
|A.||Use polyester overlays to extend the wear life of paper labels. Just peel off the backing and place over your paper labels. The clear, polyester, self-adhesive material protects paper labels from moisture, UV fading, scratches, and wear and tear.|
Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.
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The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.
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