Tuesday, April 23, 2013

OSHA Brief: Hazard Communication Standard: Labels and Pictograms Part 3

Label Elements

The HCS now requires the following elements on labels of hazardous chemicals:
• Name, Address and Telephone Number of the chemical manufacturer, importer or other responsible party.
• Product Identifier is how the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in section 1 of the SDS.
• Signal Words are used to indicate the relative level of severity of the hazard and alert the reader to a potential hazard on the label. There are only two words used as signal words, “Danger” and “Warning.”
Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. There will only be one signal word on the label no matter how many hazards a chemical may have. If one of the hazards warrants a “Danger” signal word and another warrants the signal word
“Warning,” then only “Danger” should appear on the label.
Hazard Statements describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.” All of the applicable hazard statements must appear on the label. Hazard statements may be combined where appropriate to reduce redundancies and improve readability.
The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards no matter what the chemical is or who produces it.
• Precautionary Statements describe recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling.
There are four types of precautionary statements: prevention (to minimize exposure); response (in case of accidental spillage or exposure emergency response, and first-aid); storage; and disposal. For example, a chemical presenting a specific target organ toxicity (repeated exposure) hazard would include the following on the label: “Do not breathe dust/fume/gas/mist/vapors/spray. Get medical advice/attention if you feel unwell. Dispose of contents/container in accordance with local/regional/national and international regulations.”
A forward slash (/) designates that the classifier can choose one of the precautionary statements. In the example above, the label could state, “Do not breathe vapors or spray. Get medical attention if you feel unwell. Dispose of contents in accordance with local/regional/national/international regulations.” See Examples 1 and 2A of this document as an example.
In most cases, the precautionary statements are independent. However, OSHA does allow flexibility for applying precautionary statements to the label, such as combining statements, using an order of precedence or eliminating an inappropriate statement.
Precautionary statements may be combined on the label to save on space and improve readability. For example, “Keep away from heat, spark and open flames,” “Store in a well-ventilated place,” and “Keep cool” may be combined to read: “Keep away from heat, sparks and open flames and store in a cool, well-ventilated place.” Where a chemical is classified for a number of hazards and the precautionary statements are similar, the most stringent statements must be included on the label. In this case, the chemical manufacturer, importer, or distributor may impose an order of precedence where phrases concerning response require rapid action to ensure the health and safety of the exposed person. In the self-reactive hazard category Types C, D, E or F, three of the four precautionary statements for prevention are
• “Keep away from heat/sparks/openflame/hot surfaces. - No Smoking.”;
• “Keep/Store away from clothing/…/combustible materials”;
• “Keep only in original container.”
These three precautionary statements could be combined to read: “Keep in original container and away from heat, open flames, combustible materials and hot surfaces. - No Smoking.”
Finally, a manufacturer or importer may eliminate a precautionary statement if it can demonstrate that the statement is inappropriate.

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