Since the revised Hazard Communication Standard (HCS, or HazCom 2012) passed into law in March, many have discussed the modifications and impact on workers worldwide. One of the areas of major change involves the labeling of hazardous chemicals used at the work site. These labels provide information on a chemical’s hazards, as they always have, but the changes standardize the information presentation. Standardization ensures that, regardless of use or manufacture location, the hazard information will be complete and the same.
In some respects, the new labels are similar to the old: They need to include the chemical name or identity and contact information of the supplier, manufacturer or importer. The other information on the old labels may have been the same as what is mandated on the new version; however, appearance varied.
The new labels must include the following standardized elements:
• A hazard pictogram—a black symbol surrounded by a red diamond on a white background—illustrates the physical, health and environmental warnings.
• Signal words—danger and warning—indicate the severity of a hazard and alert users to its potential. Danger indicates more severe hazards, and warning indicates less severe hazards.
• Hazard statements, which are standardized phrases assigned to a hazard class, describe the nature of the hazard. There is a limited number of statements, and the wording is mandated and specific. Examples include the following:
• Extremely flammable material
• May be corrosive to metals
• Fatal if swallowed
• Causes skin irritation
• Harmful to aquatic life
• Precautionary statements will supplement the hazard information and provide ways to minimize or prevent adverse effects from the chemical. Again there is a finite number of statements, and the wording is mandated and specific. They fall into several categories: general, prevention, response, storage and disposal. Examples include the following:
• Keep container tightly closed.
• Get immediate medical attention.
The manufacturer, supplier or importer can add information to a label at its discretion. However, this information is not required or specified under the revised HCS.
Although revising the HCS to match the international Globally Harmonized System of Classifying and Labeling Chemicals (GHS) may have standardized the appearance and contents of labels, the basic rules of labeling haven’t changed much.
All chemical containers must be labeled, preferably with the manufacturer’s label. If the manufacturer’s label needs to be replaced, it must be with a label that contains the same information presented in the same way.
Manufacturers’ labels shouldn’t be removed, changed or tampered with unless the container is emptied of its original contents. To reuse a chemical container, the original label must be removed or covered by the replacement label. It isn’t acceptable to simply put an X through the label or cross out the information. If you put a different hazardous chemical into the container, you must label the container to identify the new chemical name and its hazard warnings.
During the typical workday, it may be necessary to break a large quantity of a chemical into smaller, more usable amounts. These smaller containers must be labeled with the chemical name and any potential hazards in the same manner that the original container was labeled. The exception is, if the same person will use the amount in the smaller container during only that shift, a label is not required on the container.
At times, the labels on chemical containers will need to be replaced. Replacement is necessary if labels become soiled or dirty, are unreadable, or fall off.
All labels must be written in English. The information also can be provided in a second language. The HCS revision does not dictate print size, style or color.
Although much of this information may be a review, when it comes to handling hazardous chemicals, you can never be exposed to this information too often.
KELLY is a safety and health specialist with Intec, a safety consulting, training and publishing firm that offers on-site assistance and produces manuals, training videos and software for contractors. She can be reached at 800.745.4818 and firstname.lastname@example.org. Joe O’Connor edited this article.