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.
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.
The 6 Main Elements of a GHS Label
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.
- 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.
- 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.
- Manufacturer information – GHS labels must include the manufacturer’s name, as well as contact information including an address and phone number.
- 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).
- 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).
- 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.
A comprehensive hazard communication program includes not only GHS-compliant labeling, but also adequate training to ensure that employees understand the purpose of the chemicals and other hazardous materials in the workplace and how to properly handle them. When employees are well trained on precautionary measures, workplace safety is enhanced.
For more information on safety labels and regulations, visit the following resources:
Images via Safety.BLR and OSHA.gov