The Complete Guide to GHS Label Requirements

In 2012, OSHA revised its hazard communication standards to align with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The GHS is an international system created by the United Nations (UN) to achieve unified labeling and classification of chemicals. OSHA’s revision of the previous hazard communication standard is known as HazCom 2012.

The (GHS) of classification plays a crucial role in ensuring workplace safety. As part of OSHA’s hazard communication standards, GHS labels provide essential information to protect workers from chemical hazards. In this guide, we’ll walk you through every aspect of GHS label requirements.

What is the GHS?

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is an internationally agreed-upon standard for hazard communication of chemical products. Developed by the United Nations, this system aims to replace the various classification and labeling schemes previously used around the world with a single, comprehensive approach.

The key aspects of the GHS include:

1. Standardized hazard classification criteria
2. Universal warning pictograms
3. Harmonized safety data sheets
4. Consistent labeling requirements

The primary objectives of the GHS are to:

• Enhance protection of human health and the environment
• Provide a recognized framework for countries without existing systems
• Reduce the need for testing and evaluation of chemicals
• Facilitate international trade in chemicals

By implementing the GHS, countries and organizations can ensure that chemical hazards are communicated consistently across borders, improving safety and efficiency in the global chemical industry.

HazCom and GHS Compliance

In order to comply with OSHA’s 29 CFR 1910.1200(e) regulation, companies must develop and maintain a written HazCom plan to document how the company responds to hazardous chemicals. While proper labeling is the foundation of GHS compliance, labels also enable companies to effectively organize inventory and keep it updated.

These labels, however, must contain required information and other elements, and they must be easily understood. For instance, all shipped hazardous chemical containers must be labeled with a signal word, pictogram, hazard statement, and a precautionary statement for each hazard class and category.

These requirements impact chemical manufacturers, importers, and distributors.

More than 65 countries are using the GHS system or are currently in the process of adopting it, resulting in enhanced transparency in chemical safety use and shipping.

What to Include in a Hazard Communication Plan

Decades before the Globally Harmonized System was created, OSHA had its very own import/export chemical safety regulation program called the Hazard Communication Standard, or HazCom. As described above, when OSHA became the governing agency of the United States’ GHS, it merged many of the previously-instated standards from HazCom with the new components included in the global standard program.

One of these key standards is what is called the written hazard communication plan. Along with supplying each chemical container with the proper labeling, chemical-makers, laboratories, distributors, etc. are also required to create their own written hazard communication plans that can be easily referenced by employees, board members, third-party auditors, and, of course, OSHA, itself.

Here are the elements that must be displayed in each written hazard communication plan, via OSHA’s 1910.1200(e) regulation:

• An explanation of in-house GHS/HazCom compliance: this is meant to be a brief description that can include organizational elements, training procedures, and an account of responsible parties.
• A comprehensive list of hazardous chemicals: these product identifiers must be referenced on a corresponding data safety sheet and can be organized either by the facility or individual workspace for optimal clarification.
• An explanation of employee communication programs: this should include ways in which the employer communicates hazards for non-routine tasks. Example of these tasks includes cleaning protocol and unlabeled pipes in the workspace. Note: this explanation must also feature ways in which the employer (facility owner) plans to communicate these hazards to other workers, including contractors, in multi-employer workplaces.
• A copy must be made available upon request: a copy of the employer’s written hazard communication plan must be provided to employees, their designated representatives, and OSHA’s Assistant Secretary and Director on demand.
• A copy must be stored on-site: the written hazard communication plan must be stored at the primary work facility.

Though compiling a comprehensive chemical safety standard like the written hazard communication plan may seem like a laborious task, it’s required to ensure that all of the bases are covered in one, centralized

GHS Label Requirements: 6 Main Elements

GHS-compliant labels contain six main elements. Note that these requirements apply to primary containers (which includes the containers received from the manufacturer), but not specifically to secondary containers (such as smaller jars or spray bottles that hold chemicals transferred from the primary container).

Secondary containers are typically used by employers that make use of hazardous chemicals and products received from manufacturers.

Secondary containers may contain information required by the National Fire Protection Association (NFPA) or Hazardous Materials Identification System (HMIS), while some companies opt to include all or some combination of the information provided on primary container labels. Secondary labels should contain elements consistent with the HazCom 2012 / GHS standard.

Here’s a look at each requirement for GHS-compliant primary container labels.

1. Signal word – The signal word, such as “Danger,” or “Warning,” is used to indicate the hazard level. Danger indicates the most serious hazard level, while Warning indicates a lower level of risk.
2. Pictograms – A pictogram, or GHS hazard symbol, is a visual representation of hazardous products. Pictograms are used to group products according to risk level, including health risks, chemical/physical risks, and environmental risks.
3. Manufacturer information – GHS labels must include the manufacturer’s name, as well as contact information including an address and phone number.
4. Precautionary statements – Precautionary statements are phrases included with a hazard statement that provide information about preventative, response, storage, and disposal precautions that should be taken when handling or using the hazardous material. Precautionary statements are included in the Safety Data Sheet (SDS), as well, and they may be identified using a P-code (e.g., P230).
5. Hazard statements – Hazard statements are used to describe the degree of hazard and the nature of the hazardous material. Like precautionary statements, hazard statements are also included in the Safety Data Sheet, and they are also identified by a code – in this case, an H-code (e.g., H367).
6. Product identification – A product identifier is used to disclose the chemical’s or product’s name. If additional identifiers are needed beyond the product name, these identifiers can be placed to the right of the manufacturer’s information on a GHS label.

Understanding GHS Pictograms

GHS pictograms are the visual, graphic element present on GHS-compliant labels. They’re used to communicate the type of risk across three different categories: environmental risk, chemical/physical risk, and health risk.

In all, there are nine pictograms, each representing certain risks in one or more categories:

Chemical Risk Pictograms: 

• Corrosion – The corrosion pictogram identifies corrosive metals as well as chemicals that pose a risk of eye damage or skin corrosion. This pictogram is also used for the health risk category.
• Gas cylinder – The cylinder pictogram identifies gasses under pressure.
• Oxidizing – This pictogram illustrates a fire over the letter “O.” It’s used to identify oxidizers.
• Flame – The flame pictogram identifies flammable and self-heating materials, self-reactives, and organic peroxides, as well as pyrophorics and materials that emit flammable gas.
• Explosives – This pictogram identifies explosives, self-reactives, and organic peroxides.

Health Risk Pictograms: 

• Corrosion – As mentioned, the corrosion pictogram is used for both the chemical risk and health risk categories, identifying chemicals that may cause eye damage or skin corrosion. 
• Acute toxic – This pictogram, which is illustrated by an exclamation point, identifies skin and eye irritants, skin sensitizers, materials that pose a risk of acute toxicity, those that may have narcotic effects, and those that may cause respiratory tract infections. Additionally, this pictogram is used for materials that may pose a hazard to the ozone layer, although this is optional.
• Health hazard – The health hazard pictogram identifies carcinogens, respiratory sanitizers, and those that pose a risk of target organ toxicity and aspiration toxicity. Materials that pose a risk of reproductive toxicity are also represented by this pictogram, as well as those that pose a risk of mutagenicity.
• Severe toxic – Represented by a skull and cross bones, this pictogram identifies materials that pose a risk of acute toxicity, including potentially fatal toxicity.

Environmental Risk Pictograms: 

• Environmental – The environmental risk pictogram, while not mandatory in the United States, is used to identify materials that pose a risk of aquatic toxicity.

GHS Label Design Specifics

Although it might seem as if OSHA’s GHS/HazCom requirements are stringent ones, surprisingly, there are few requirements in regards to label design. This means that the employer is free to order and/or design their GHS labels with any company or using any material they choose.

Here are the label design specifics that must be followed, according to OSHA:

• All information must be entirely legible
• All printed information must be written in English
• All printed information can include other languages in addition to English, if necessary
• The label must be large and prominently displayed on the outside of the container
• Must be revised within 6 months if the employer becomes aware of new information that could affect GHS/HazCom compliance

Metalphoto of Cincinnati’s photosensitive anodized aluminum custom labels or compliance tags are an ideal choice for long-lasting readability, even when the label is consistently exposed to sunlight, corrosion, abrasion, heat, extreme cold, and even exposure to chemicals. The labels also come equipped with a customized design that can be used to properly describe the container’s contents.

Primary vs. Secondary Container Labeling

We already know what the GHS label should include, but one of the regulations that is particularly confusing, at first glance, is the standard of primary and secondary container labeling. Primary and secondary container labeling is meant to differentiate the materials and designs of the containers, specifically, so that the labels are placed at the most strategic points possible.

Let’s take a look at primary container labeling first:

Primary Container Labeling:

• Primary containers constitute bags, barrels, bottles, boxes, cans, cylinders, and drums that are used to store chemicals, typically straight from the manufacturer.
• Primary containers must contain all of the label elements, including product identifiers, signal words, pictograms, hazard and precautionary statements, and responsible party information.
• The label can never be removed, altered, or defaced.
• If the label is accidentally removed or wear-and-tear makes it illegible over time, the exact same information must be re-printed.

Secondary Container Labeling:

• Generally speaking, secondary containers are much smaller than their primary counterparts. These containers include spray bottles, jugs, or jars. Many times, these containers hold chemical products that are have been transferred from the primary container.
• Secondary containers must display the same labels EXCEPT when 1) the transfer from primary to secondary is made by one individual or team during a single work shift, 2) the transfer is completed in a singular work area, and/or 3) the secondary container stays in one work area with the same worker.

More in-depth information concerning chemical container transfer can be found in OSHA’s Laboratory Safety Labeling and Transfer of Chemicals guide.

Safety Data Sheet Essentials

Safety data sheets have been a requirement of chemical manufacturer’s since HazCom’s conception, but it’s easy to leave them by the wayside when the labels are so prominently featured. Even so, safety data sheets are relatively straightforward once your operation makes a centralized template.

Here is what every data sheet should include, according to 1910.1200(g) in OSHA’s HazCom standards:

• Each chemical manufacturer or distributor must have a separate data sheet for every hazardous chemical they import, produce, or use.
• All safety data sheets must be written in English in addition to other applicable languages. The formatting of the sheets must include sections numbers and headings with the appropriate information organized under each heading. The headings are as follows: 1) Identification, 2) Hazards Identification, 3) Composition/information on ingredients, 4) First-Aid measures, 5) Fire-fighting measures, 6) Accidental release measures, 7) Handling and storage, 8) Exposure controls/personal protection, 9) Physical and chemical properties, 10) Stability and reactivity, 11) Toxicological information, 12) Ecological information, 13) Disposal considerations, 14) Transport information, 15) Regulatory information, and 16) Other important information, including date of preparation and last revisions.
• If no information is applicable for a particular subheading, the employer must indicate so.

In addition to preparing the safety data sheet, the manufacturer must either send a copy to the customer with or prior to the shipment. These regulations stand for all responsible parties, including manufacturers, suppliers, and distributors, as well as customers using the chemicals.

Final Thoughts

In conclusion, understanding and complying with GHS label requirements is essential for maintaining a safe and efficient workplace. Key elements of GHS labels, including signal words, pictograms, and precautionary statements, are designed to clearly communicate chemical hazards and safety measures.

By ensuring your labels meet these standards, you help protect your workforce and stay in line with OSHA’s regulations. Regularly reviewing and updating your chemical labeling system is crucial to maintaining compliance and fostering a culture of safety in your organization.