Hazard communication standards impact 43 million workers and five million businesses in the United States who produce or handle hazardous chemicals. The goal of hazard communication standards is to reduce workplace injuries and illnesses resulting from exposure to hazardous materials. Recently, the HCS was updated to align these standards with international GHS standards, ensuring greater consistency in hazard communications for chemicals transferred internationally.
We’ve created this guide to provide a comprehensive overview of HAZCOM, including the requirements set forth by the HCS and GHS, roles and responsibilities for the various entities involved in the manufacture, import, or handling of hazardous chemicals, and specific labeling requirements for hazardous chemicals.
In this guide, we’ll discuss:
- Hazard Communication Standards
- Hazard Communication Label Requirements
- Hazard Communication Duties and Responsibilities
- Best Practices for HAZCOM Compliance
- Additional Resources on Hazard Communication Standards
Hazard Communication Standards
Hazard communication standards (HCS) are a set of guidelines and requirements, issued by the Occupational Safety and Health Administration (OSHA), related to the identification of hazardous chemicals, the health and safety hazards associated with those hazardous materials, and the appropriate safety measures that reduce the risk of illness and injury when handling these materials. HCS was first issued on November 25, 1983, and since that time, safety has dramatically increased in the workplace.
According to OSHA, 25 states, as well as Puerto Rico and the U.S. Virgin Islands, have adopted OSHA-approved State Plans, and they have adopted their own standards and enforcement policies that are largely identical to federal OSHA standards. Some states, however, have adopted different standards or may utilize different enforcement policies. Twenty-one states and one U.S. territory cover private and state and local government workplaces, while the remaining five states and one U.S. territory have implemented plans that apply only to state and local government workers. For this reason, it’s important for manufacturers, importers, and employers that handle hazardous chemicals to be familiar not only with the federal OSHA standards but also any applicable state requirements and enforcement policies to ensure compliance on both the state and federal level.
Most recently, OSHA issued changes to the HCS in alignment with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Aligning the HCS with GHS allows for a standardized approach to hazardous chemical classification, labeling, and safety data – on an international level, a logical step in today’s global marketplace. Employers were required to implement workplace labeling and hazard communication procedures to comply with the final rule by June 1, 2016.
The updated HCS includes the following:
- Hazard Classification: Chemical manufacturers and importers are responsible for determining the hazards of the chemicals they produce or import under the new, GHS-aligned hazard classification system.
- Labeling Requirements: Chemical manufacturers and importers are responsible for properly labeling all hazardous chemicals with required elements including a signal word, pictogram, hazard statement, and precautionary statement. Labels must include required elements for each hazard class and category.
- Safety Data Sheets: Under the final rule, safety data sheets (SDS) have a new format, which includes 16 sections to ensure that important safety information is communicated consistently.
The HCS falls under (29 CFR 1910), Subpart Z, Toxic and hazardous substances. The following appendices provide important information on both mandatory and non-mandatory elements of HCS:
- Appendix A, Health Hazard Criteria (Mandatory)
- Appendix B, Physical Criteria (Mandatory)
- Appendix C, Allocation Of Label Elements (Mandatory)
- Appendix D, Safety Data Sheets (Mandatory)
- Appendix E, Definition of “Trade Secret” (Mandatory)
- Appendix F, Guidance for Hazard Classifications Re: Carcinogenicity (Non-Mandatory)
In addition to these requirements, employers must develop and implement a written hazard communication program. This program should include:
- Provisions for container labeling
- Processes for collecting material safety data sheets (MSDSs)
- Availability of MSDSs
- An employee training program
- A list of hazardous chemicals
- Procedures for informing employees of hazards posed by non-routine tasks
- Hazards associated with chemicals in non-labeled pipes
A written hazard communication program must be available to all employees and any designated representatives of employees, as well as the Assistant Secretary of Labor for Occupational Safety and Health and the Director of the National Institute for Occupational Safety and Health (NIOSH). OSHA provides a draft model training program here.
Safety Data Sheet Requirements
Safety data sheets are now required to contain specific information, including 16 specified sections:
- Hazard(s) identification
- Composition/information on ingredients
- First-aid measures
- Fire-fighting measures
- Accidental release measures
- Handling and storage
- Exposure controls/personal protection
- Physical and chemical properties
- Stability and reactivity
- Toxicological information
- Ecological information
- Disposal considerations
- Transport information
- Regulatory information
- Other information
SDSs contain more detailed information than what appears on HAZCOM labels. As such, they must be readily accessible by employees for any and all hazardous chemicals used in the workplace. Additionally, they should include information about the data that was used in determining the hazards.
Generally, suppliers are responsible for creating safety data sheets and providing them downstream to customers. Manufacturers, importers, and distributors should supply SDSs to employers that are end users of chemicals, and these end users are not liable for the accuracy of the information contained in an SDS, provided that it was accepted from the manufacturer, distributor, or importer in good faith – in other words, the SDS contains no blank spaces and does not contain obvious inaccuracies. If such inaccuracies or missing information is identified by end users, it should be reported to the chemical manufacturer or distributor. One exception to this rule is when an employer opts to conduct their own hazard classification, in which case the employer is liable for the accuracy of the SDS.
Hazard Communication Label Requirements
The HCS relies heavily on labels and safety data sheets to convey important hazard information and safety precautions to workers who come in contact with or handle hazardous materials in the workplace. Because labels and SDSs are often the primary means of communication (along with employee training), properly following the label requirements and making SDSs readily accessible is paramount to creating a safe workplace.
The label requirements for hazardous chemicals has changed under the new, GHS-aligned HCS rule. Labels are now required to contain certain elements for each hazard class and category, including:
- Product Identifier: An alphanumeric code, number, or name that allows for the proper identification of the chemical. Product identifiers are unique to each chemical and are also used in SDSs, making it easy for workers to reference the more-detailed SDS for the hazardous chemicals they’re manufacturing or handling.
- Pictogram: A pictogram is a symbol combined with other graphic elements (i.e., borders, background patterns, or colors) that convey important information about the hazards of the chemical. Each pictogram is a symbol on a white background in a red square frame set on a point, such as a red triangle. The GHS includes a total of nine pictograms, eight of which are required under HCS. Many of the GHS pictograms are already in use in the transportation industry, thus, many chemical users may be familiar with the symbols.
- Signal Words: A signal word is a single word that conveys the risk level associated with a chemical (the severity level of the hazard). The signal word serves to alert the reader (the person handling the chemical) that a potential hazard exists. “Danger” is the signal word used for more severe hazards, while “Warning” is used for hazards that are less severe. When both signal words apply to a chemical due to the presence of multiple hazards of varying severity, only the word “Danger” should be used on the label.
- Hazard Statement: A hazard statement is assigned to a particular hazard class and category and is used to convey the nature of the hazard (or hazards, if multiple hazards exist). This may include the degree of the hazard. There are a variety of hazard statements, ranging from “May be harmful if swallowed,” to “Causes skin irritation,” to “Fatal in contact with skin.” ChemSafetyPRO maintains a complete list of hazard statements and codes.
- Precautionary Statement: A precautionary statement conveys the precautionary measures that should be taken to minimize the risks of exposure to a hazardous chemical, or minimize the risks of improper storage or handling. For example, precautionary statements include, “Wear eye protection,” or “In case of inadequate ventilation wear respiratory protection,” or similar phrases offering guidance on safety precautions. OSHA allows for some flexibility when it comes to precautionary statements. For instance, companies may opt to combine precautionary statements to save space and improve readability, list statements in order of importance, or eliminate an inappropriate statement. When multiple hazard classifications exist for a chemical, resulting in similar required precautionary statements, the most stringent precautionary statements should be used on the label.
- Contact Information: The name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.
- Supplementary Information: Supplementary information is additional information or instructions that a label producer opts to include when it’s not otherwise required. Supplementary information may include hazards that aren’t otherwise classified. Supplementary information must identify the percentage of ingredient(s) with an unknown acute toxicity for any ingredient present in a concentration of ≥1% (unless the classification is based on testing of the mixture as a whole). One example of supplementary information is the environmental hazard pictogram, a pictogram used under GHS but not required by OSHA.
There are no formal, standardized requirements on the appearance of these labels, nor is there a particular format that employers must use. The only restrictions on aesthetics and format are that they cannot detract from the required information or contradict the required information in any way. In addition to containing the required elements and information, labels:
- Must be legible and in English
- Must be prominently displayed
- May contain other languages (in addition to English)
- Must be revised within six months of companies becoming aware of significant information that would impact hazard communication
All information on labels must remain legible, meaning that employers must take steps to ensure that the information does not fade or otherwise become defaced. Employers should opt for durable custom labels or compliance tags, such as labels constructed of Metalphoto® photosensitive anodized aluminum, to eliminate the cost of replacing labels that have become defaced. Metalphoto labels include a photographic image sealed inside anodized aluminum, offering excellent resistance to degradation from exposure to sunlight, as well as corrosion, abrasion, extreme hot or cold temperatures, and even exposure to chemicals –an important consideration for HAZCOM labels. Employers that opt for durable label solutions not only save on the cost of label replacements but are also able to devote more time and resources to other HAZCOM compliance demands.
Other Requirements Related to HAZCOM Labels
For in-plant labeling, OSHA offers a flexible approach for workplaces. Employers are able to create their own labeling system, or continue to use their existing labeling system, provided that labels contain all of the required information and elements.
Employers may also use other written communication materials, such as signs, placards, process sheets, batch tickets, or operating procedures instead of labeling individual stationary process containers. However, employers using this alternative method must ensure that it identifies the containers that these written communications apply to. Additionally, written communication materials must contain the information required on labels under 29 CFR 1910.1200 (f)(6). Finally, written materials must be readily accessible to all employees in a work area throughout their shifts.
Labels on shipped containers must contain all information and elements required under 29 CFR 1910.1200(f)(1)). Labels must be affixed to, attached to, or printed on either the immediate container of a hazardous chemical or to outside packaging.
Image via Wikimedia Commons
Pictograms are an important component of hazard communication labels, providing a visual representation of the hazards associated with a chemical to readily alert anyone handling hazardous materials of the risks. As mentioned, there are a total of nine GHS pictograms, eight of which are required by OSHA. These pictograms fall into three categories: chemical risk, health risk, and environmental risk:
Chemical Risk Pictograms:
- Corrosion – Identifies corrosive metals and chemicals that pose a risk of skin corrosion or eye damage. This pictogram may also be used under the health risk category.
- Gas cylinder – Identifies gasses under pressure.
- Oxidizing – Identifies oxidizers, depicted by a fire placed over the letter “O.”
- Flame – Identifies flammable and self-heating materials, self-reactives, and organic peroxides, pyrophorics and any materials that emit flammable gas.
- Explosives – Identifies explosives, self-reactives, and organic peroxides.
Health Risk Pictograms:
- Corrosion – Identifies chemicals that pose a risk of skin corrosion or eye damage. Also used in the chemical risk category.
- Acute toxic – An exclamation point pictogram that identifies skin and eye irritants, skin sensitizers, and any materials that pose a risk of acute toxicity. Also used to identify any materials that may have narcotic effects and materials that pose a risk of respiratory tract infections. The acute toxic pictogram is also used for materials that may pose a hazard to the ozone layer; however, this is not required.
- Health hazard – Identifies carcinogens, respiratory sanitizers, and any materials posing a risk of target organ or aspiration toxicity. Also used to identify materials that pose a risk of reproductive toxicity or mutagenicity.
- Severe toxic – Identifies materials that pose a risk of acute toxicity, including potentially fatal toxicity. Illustrated as a skull and crossbones.
Environmental Risk Pictograms:
- Environmental – Identifies materials posing a risk of aquatic toxicity. This pictogram is not required under OSHA in the US.
While many pictogram symbols are shared by the transportation industry, OSHA pictograms do not replace the U.S. Department of Transportation (DOT) pictograms that are required for transporting chemicals (including drums, totes, tanks, and other containers). DOT labels must be placed on the exterior of a shipped container and must meet requirements in 49 CFR 172, Subpart E. In some cases of international trade, both DOT and HCS pictograms are required on labels, even when the pictograms are the same. (OSHA plans to revise Appendix C.2.3.3. to better address this issue.) The DOT diamond label is required on outside shipping containers for all hazardous chemicals, while chemicals inside smaller containers inside the outside shipping container require only OSHA pictograms.
Hazard Communication Duties and Responsibilities
Hazard communication standards place certain responsibilities on different types of entities that are involved in the manufacture, handling, or use of hazardous chemicals.
Manufacturers and importers of hazardous chemicals are responsible for determining the hazards associated with each material. They are required to evaluate available scientific evidence related to the potential hazards of the chemicals they manufacture or import, and then communicate this information to employees as well as any other entities that distribute or use the products. Downstream employers rely on the evaluations conducted and information provided by chemical manufacturers and importers to establish the hazards of the chemicals they use.
Manufacturers, importers, and distributors, as well as any employers that evaluate hazards are responsible for the quality of hazard determinations they perform. All chemicals must be evaluated for the potential to cause adverse health effects, as well as the potential for physical hazards, such as flammability. All chemicals listed in 29 CFR 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration (OSHA) should be deemed hazardous in all circumstances, as well as all chemicals listed in Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment, American Conference of Governmental Industrial Hygienists (ACGIH).
These entities are responsible for communicating hazard information and all associated protective measures downstream through the supply chain – to their customers – through the use of labels and material safety data sheets.
Companies that use hazardous chemicals in the workplace have several responsibilities. These include identifying and listing the hazardous chemicals in the workplace, obtaining SDSs and labels for hazardous chemicals (if labels are not provided by the manufacturer, importer, or distributor), develop and implement a written hazard communication program (including labels, SDSs, employee training, and communicating hazard information to workers through labels, SDSs, and training programs.
Employers must ensure that labels remain legible – and that the required information does not become defaced (faded, washed off, etc.) or removed. If labels become defaced, employers are responsible for replacing them; however, employers are not responsible for updating labels on shipped containers. If an employer becomes aware of newly-identified hazards that are not addressed on the current label, they must ensure that workers are informed and aware of these hazards. If hazardous chemicals are transferred to a portable container intended only for immediate use by the employee who transferred the chemical, a label for the portable container is not required.
Employers do have the option to use additional instructional symbols that are not included in HCS label requirements, such as a symbol depicting a person wearing goggles to inform workers that goggles should be worn when handling the chemical. Environmental pictograms and PPE pictograms from the HMIS are also allowable.
Employers are also able to continue using National Fire Protection Association (NFPA) diamonds or follow HMIS requirements for workplace labels, provided that they are consistent with HCS requirements and that workers have immediate access to the information. Employers that opt to utilize one of these alternative rating systems must ensure that workers are adequately trained and have a complete understanding of the hazards of the chemicals they come in contact with.
Best Practices for HAZCOM Compliance
When it comes to Hazard Communication Standards compliance, the best resource is the source itself: OSHA. The Occupational Safety and Health Administration offers a few clear tips to ensure compliance:
- Know the standard.
- Develop a chemical inventory list.
- Label all containers containing hazardous chemicals.
- Obtain relevant safety data sheets.
- Develop a written hazard communication program.
- Provide comprehensive hazard communication training for all employees.
Employers should have a clear understanding of their responsibilities under HCS and implement policies and procedures to ensure that these responsibilities are met. Implement procedures to ensure that safety data sheets are readily accessible for all chemicals in your database, and request any missing SDSs from suppliers. It’s also helpful to perform a periodic HAZCOM safety audit to identify any compliance concerns.
When it comes to meeting labeling requirements, work with an established label producer offering durable label options designed to withstand the elements and other harsh conditions to ensure readability throughout the usable lifespan of your chemical containers. Some label manufacturers are experienced in producing GHS-compliant labels, providing an added layer of assurance that your labels meet all requirements.
Additional Resources on Hazard Communication Standards
For more information on hazard communication standards and compliance requirements, visit the following resources:
- Hazard Statements (H-Statements)
- Agency for Toxic Substances and Disease Registry (ATSDR)
- Process Safety Management
- Training Requirements in OSHA Standards
- Chemicals: Managing Chemical Safety in the Workplace
- Chemical Reactivity Hazards
- Hazard Communication – Safety Data Sheets
- OSHA Releases New Guidance To Assist GHS Compliance
- Guidance: Hazard Communication and the Globally Harmonized System of Classification and Labeling
- Hazard Communication Standard for Chemical Labels and Safety Data Sheets In GHS Format
- HazCom: 2017 Year in Review
- OSHA Issues Enforcement Guidance on June 1 HAZCOM Compliance Deadline: What Industry Needs to Know