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Alternative Workplace Labeling

Quick Tips #198

The Occupational Safety and Health Administration’s (OSHA's) Hazard Communication Standard (HCS) found in 29 Code of Federal Regulations (CFR) 1910.1200, also known as the Right-to-Know law, was first enacted on November 25, 1983. Since that time, the HCS has been the primary tool for providing employers and employees with information about the chemical hazards in their workplaces. The performance-orientated standard has allowed chemical manufacturers and importers to convey information on labels and material safety data sheets (MSDSs) in whatever format they desire.

The much-anticipated revision to the HCS was published in the Federal Register on March 26, 2012 (with an effective date of 60 days thereafter). One of the most significant changes in this revision was OSHA's adoption of portions of the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

The parts of the HCS not related to the GHS—basic framework, scope and purpose—remained largely unchanged. However, three major areas of change—hazard classification, shipped container labels and safety data sheets (SDSs)—were adopted.

The revised HCS still requires all labels to be in English. Bilingual chemical labels are allowed and may be offered as an option where a language barrier is present.

With adoption of portions of the GHS, the HCS now requires chemical manufacturers, importers and distributors to provide a GHS-compliant shipped container label that has six standardized elements for classified hazards:

  • Product Identifier – Must match product identifier on safety data sheet (SDS).
  • Manufacturer Contact Information – Including name, phone number and address.
  • Hazard Pictograms – There are nine pictograms used to convey health, physical and environmental hazards. The revised HCS requires eight of these pictograms, the exception being the environmental pictogram as environmental hazards are not within OSHA's jurisdiction. These pictograms have a black symbol on a white background with a red diamond frame (see illustrations below).
  • Signal Word – Either DANGER or WARNING depending upon hazard severity.
  • Hazard Statements – Standardized sentences that describe the level of the hazards.
  • Precautionary Statements – Steps employees can take to help protect themselves.

With the revision, OSHA is continuing to allow employers the flexibility to determine what types of workplace labels they will use. Two options are available:

  1. A label with the same information listed on the GHS-compliant shipped container label.
  2. An alternate label that meets the requirements of the revised HCS.

There are several alternate workplace labeling systems:

  • Right-to-Know (RTK)
  • National Fire Protection Association (NFPA)/National Fire Rating (NFR) - 704
  • Hazardous Material Identification Guide (HMIG)
  • Hazardous Material Identification System (HMIS)
Alternate Workplace Labeling

RTK

Consists of labels that list the chemical name, synonym or common name, hazard information, Chemical Abstract Service (CAS) number, and precautionary measures and first aid procedures.

NFPA/NFR 704

The NFPA/NFR labeling systems employ a color-coded rating guide in a diamond shape. Health is defined by the color blue, flammability is red and instability is represented in yellow. The numbers 0–4 are assigned according to the level of hazard the chemical(s) present (0 being no hazard and 4 the greatest hazard). The hazards are arranged spatially as follows: health at the nine o'clock position, flammability at the twelve o'clock position and instability at the three o'clock position. The six o'clock position on the symbol represents special hazards and has a white background. The special hazards in use include unusual reactivity with water (W), the material is an oxidizer (OX) or the material is a simple asphyxiant gas (SA). This labeling option offers books, charts and wallet cards to help explain the classification.

NFR signs are commonly seen on the exterior of a building or on a storage vessel containing a hazardous chemical. In the event of a fire or emergency these signs alert the fire department or emergency responders to the types of chemical hazards that are present.

HMIG

Presents a color formatted label and is rectangular in shape. The numbers used in this system to identify the hazard level of the chemical are based on the acute and chronic hazards present in normal day-to-day use in the workplace and range from 0 (no hazard) to 4 (greatest hazard). There are also charts, labels and wallet cards for this system.

The numbers for the HMIG labeling systems may be obtained by reviewing the Safety Data Sheets (SDSs) accompanying the chemical or in reference books that list chemical hazards by the numerical rating, such as The Fire Protection Guide to Hazardous Materials. These three labeling systems (RTK, NFR and HMIG) are all offered through Grainger.

HMIS III

This label system looks similar to the HMIG labeling system (using the color bar format and rectangular shape) and utilizes a rating system developed by the National Paint and Coatings Association. The HMIS III rating system has recently been revised. The most significant change to the label has been to the physical hazard section of the label. Along with the assigned number, an icon is now present (compressed gas, explosive, oxidizers, etc.). This allows for easier identification of the presence of a specific hazard to the employee.

Any of these alternate workplace labeling methods may be used as long as the employee understands the hazards being communicated and how to read the label. However, once a system has been chosen, OSHA prefers to see consistency throughout the workplace.

Commonly Asked Questions
 
Q. Is one of the chemical labeling systems better than another?
A: No. One labeling system is not better than the other. OSHA recognizes all of these except Workplace Hazardous Materials Information System (WHMIS). However, keep in mind consistency is the key. Once you choose a system, all chemicals should be labeled the same.
 
Q: I was told to buy an NFR Sign Kit to place outside of my building. How do I know what numbers should be assigned to the health, flammability, instability and special hazards areas on this sign?
A: If you are in doubt about the hazard ratings for your NFR sign, it is best to check with your local authorities, such as your local Fire Marshal, to obtain the appropriate hazard ratings for your facility. They are able to make an assessment of the chemicals being used and/or stored and will be able to inform you how this sign should read for responders in the case of an emergency. For a general guide to chemical hazard labeling on common industrial chemicals, Grainger offers the Hazardous Materials NFR Pocket Guide.
 
Q: What do I put in the special hazards section of the NFR labels and signs?
A: Special hazard symbols represent materials that offer a specific hazard, such as an acid, corrosive, oxidizer, radiation, or materials that react violently or explosively with water which are identified as water reactive chemicals. The Fire Protection Guide to Hazardous Materials references these symbols and their meanings to this particular rating system.
 
Sources

OSHA's 29 CFR 1910.1200 Hazard Communication Standard

NFPA 704: Standard System for the Identification of the Hazards of Materials for Emergency Response - 2012 Edition

OSHA Label and Pictogram Technical Brief, February 2013

The Fire Protection Guide to Hazardous Material

(Rev. 6/2015)


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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Please Note:
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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