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OSHA amended its hazard communication standard in 2012 to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Under the new standard, hazardous chemical labels are changing dramatically to feature pictograms, signal words and hazard and precautionary statements. Employers that use hazardous chemicals in their operations are required to upgrade their plans for labeling secondary workplace containers – that is, containers into which a hazardous chemical is transferred from its original bottle, canister or receptacle. The deadline mandated by OSHA for updating workplace labeling programs is June 1, 2016.

One question that’s come up from companies looking to re-label hazardous materials with the GHS labels we provide, is this:

When re-labeling chemicals and in secondary containers, should we use the NFPA/HMIS numbering system or the GHS numbering system? Or is it our choice so long as we instruct our employees how to read the label?

We asked hazmat specialist and former OSHA compliance officer, Chris Palmisano to help us answer this question and offer some tips to those trying to figure out to best re-label hazardous chemicals in the workplace. InSite Solutions consulted with Palmisano to develop our GHS secondary container labels. Here’s what Chris had to say:

InSite Solutions: Chris, what’s best for companies trying to comply with GHS labeling guidelines – use the new numbering system, or the older HMIS system?

Chris: We recommend that employers don’t use either system on our label. Let me explain why.

We placed the HMIS option on our label for those old school safety professionals that feel that they don’t want to get away from the old HMIS/NFPA system.

But be aware, the GHS Hazard Categories and HMIS Classifications are in reversed order and can cause great confusion for employees. HMIS ratings run 4 thru 0 with 4 being the most hazardous versus The GHS ratings which run 1 Thru 5 with 1 being the most hazardous.

In my opinon, there is no consistency regarding the presence of either the GHS Hazard Category numbers and/or HMIS/NFPA Classification numbers in Section #2 of the new SDSs (safety data sheets).

It is important to remember that since we are now in a global chemical market, many foreign distributors do not recognize HMIS and NFPA ratings. The system is home grown in the U.S. and was started by the painting industry. It is primarily utilized in North America. These rating systems are not part of the new GHS standards. Distributors may place HMIS data in the Section #16 as a courtesy for customers, but it is not a mandatory requirement of the new SDS and will not always be found.

InSite Solutions: So OSHA doesn’t require a classification number on secondary labels?

Chris: Here’s exactly what the new OSHA Hazcom Standard states about labeling workplace containers:

For the workplace label, the container must be labeled, tagged, or marked with either the Product identifier, signal word, pictogram(s), hazard statement(s) and precautionary statement(s) of the hazardous chemical,

OR

labeled, tagged, or marked with product identifier and words, pictures, symbols, or a combination of these that provide at least general information about the hazards of the chemicals, and which, in conjunction with the other information immediately available, provides employees with the specific information about the physical and health hazards of the hazardous chemical.

How-To-Use-GHS-Chemical-Label

InSite Solutions: So what’s your final recommendation?

Chris: I believe that using the GHS label “elements”, including pictograms directly from the parent container label and/or obtaining this hazard data from an SDS and transferring that data to our label, is the most accurate, consistent and safest method of transferring hazard information to a secondary container label.

The use of hazard number ratings is optional – we don’t believe employers should use either numbering system, because, 1) they are not required by OSHA on a workplace label and, 2) due to the unreliability of the data found in an SDS.

InSite Solutions: Some of our customers have said the initial switch-over to the new hazard category numbers are confusing – so you think so too?

Chris: Well, if you choose to have employees continue to use HMIS on workplace labels, it is important to teach them that the GHS Hazard Category Numbers sometimes found in Hazard Section #2 of the new SDS ARE NOT HMIS numbers and that confusing them for HMIS numbers for labeling a workplace container can create a hazardous condition in the workplace.

I believe that the use of the HMIS system and NFPA 704 Diamond is best suited for fixed objects such as buildings and large storage tanks/containers to comply with NFPA regulations and alert Emergency Responders of the chemical hazards they may encounter at an emergency on your site.

InSite Solutions offers a simple, straightforward, highly effectivelabeling system that will help companies and organizations meet the OSHA deadline.