HELPING YOUR CUSTOMERS MEET OSHA REQUIREMENTS WITH THEIR LABELS
BY REBECCA OSTERMAN
The United States Department of Labor requires that any business where employees “could be exposed to hazardous chemicals” is required to comply with OSHA’s Hazard Communication Standard (HCS). Beginning in 2012, the HCS was amended to align with the Globally Harmonized System of Classification and Labeling of Chemicals, also known as GHS. Let’s learn more about these important safety labels, and how you can help your customers.
GHS, or the Globally Harmonized System of the Classification and Labeling of Chemicals was developed by the UN beginning in 1992, so workers throughout the world can easily identify dangerous substances. Instead of each country having its own system for labeling hazardous materials, the symbols are standardized and easily recognizable. Additionally, GHS labels need to meet certain requirements for quality and durability.
GHS is not a global law, but recommendations that countries can incorporate into their own chemical management system and regulations. Countries can pick and choose which pieces of GHS they wish to incorporate into their own regulations to enforce within their jurisdiction. No country is obligated to adopt all or any of the GHS system. But more than 65 countries have. The U.S. officially adopted GHS in 2012, when OSHA adapted their Hazard Communication Standard to align with the 3rd edition of GHS.
OSHA’s Hazard Communication Standard (HCS) was originally established in 1983. The goal of these standards is to provide a standardized approach to communicating workplace hazards associated with exposure to hazardous chemicals. Under the HCS, chemical manufacturers and/or importers are required to classify the hazards of chemicals which they produce or import into the United States. All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train them to handle the chemicals appropriately.
In 2012, OSHA adopted a phased in revision of the HCS to align with the 3rd revised edition of the GHS. The final deadline for compliance with OSHA’s revised HCS was June 1, 2016. Prior to this, companies were required to provide information on dangerous chemicals, but it was up to the individual company to determine how it was provided. In addition to significant differences from company to company, it was also not uncommon for chemicals to be relabeled several times in order to comply with international and US regulations. By adopting the GHS, OSHA aimed to provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. It was also done to help reduce trade barriers and result in productivity improvements for American businesses.
Under the HCS, labels for hazardous chemicals are standardized and in addition to the name and manufacturer information are required to include four elements:
There are 9 basic universal pictograms.
Here's what they look like and what they mean:
The UN describes the GHS as a “living document.” Officials and regulators regularly meet to update the GHS to reflect how our understanding of hazards can change over time. When OSHA originally adapted their standards to the GHS, they adopted the 3rd revised edition. There have been a number of significant revisions since 2012, when OSHA adopted the 3rd revised edition of the GHS, and the most current GHS is the eighth revision.
OSHA has been reporting for several years that the HCS would be updated to reflect changes in the GHS. In early February 2021 OSHA issued proposed rules to update the HCS to align with the seventh revision of GHS (published in 2017). The proposed regulatory update is being issued as the United States’ major international trading partners, including Canada, Australia, New Zealand, and those in Europe, similarly prepare to align their own hazard communications rules with the seventh version of the GHS.
Among these proposed rules are new and revised hazard classifications, revised provisions for updating labels, and new labeling provisions for small containers. Once OSHA publishes the final rule, most labels will need to be revised.
This means that your current GHS/OSHA label customers will need new labels (as well as printers and ribbons). And if you’re looking for a new market to target, hazardous product manufacturers, importers and distributors in the US will all also need to update and replace their labels.
BS5609 is the British Standard for pressure-sensitive adhesive labels used for marine applications. It is recognized internationally as the standard labels must meet when used on hazardous chemical containers shipped by sea. In order to receive BS5609 certification, labels must use substrate, ink and printing methods that can withstand prolonged exposure to salt water (up to 3 months submersion).
OSHA’s HCS applies to the information that is required on the label, not the materials used to create the label. Therefore labels do not need to be BS5609 certified in order to be OHSA compliant. However, companies who are shipping hazardous chemicals by sea should still determine if BS5609 certification is necessary for their labels. DLS can help you provide BS5609 labels for your customers who need them.
DLS helps you provide your customer with GHS Labels to meet their employee safety needs. Contact us for more information on how you can grow your labels sales by targeting customers in these markets. And remember you can contact Contact our team anytime to place an order or request a quote.