Wednesday, April 29, 2015

Steps to an effective hazcom program for employers

3. Ensure Containers are Labeled

  • Keep labels on shipped containers
  • Label workplace containers where required
 Labels are the first part (paragraph (f) Labels and Other Forms of Warning) of the three-part approach
to communicating information downstream mentioned earlier. A label must be on the immediate container of every hazardous chemical. The label is an immediate type of warning since it is present in the work area, right on the actual container of a hazardous chemical. It is a snapshot of the hazards and protective information related to the chemical, and a summary of the more detailed information available on the SDS.
When you purchase a hazardous chemical from a supplier, you will receive a container that is labeled with the information required under the HCS. Employers can rely on the information provided by their suppliers. The label requirements in the HCS changed significantly with the publication of HazCom 2012. Under the prior standard, chemical manufacturers and importers were required to convey the hazards and identity of the products, but were not given specifications on how this was to be done. As a result, labels varied in terms of how the information was conveyed, the terminology used, and the design of the label. This made it more difficult for employers and workers to access and comprehend the information presented than if chemical manufacturers and importers follow the same approach.
The label requirements for the revised standard are more specific, which will lead to increased uniformity. This should benefit employers and workers by providing the information in standardized language and graphics, making it easier to understand, and helping to ensure that labels on containers of the same chemical from different suppliers have the same information.
HazCom 2012 provides chemical manufacturers and importers the information to be conveyed once they have determined the hazard of a chemical. The labels you receive on a shipped container must have the following information, located together (other information may also appear on the label):
■ Product identifier
■ Signal word
■ Hazard statement(s)
■ Pictogram(s)
■ Precautionary statement(s)
■ Name, address, and phone number of the responsible party
■ The product identifier is any chemical, common, or trade name or designation that the chemical manufacturer or importer chooses to use on the label. The term must also appear on the SDS. The signal word, hazard statement(s), pictogram(s), and precautionary statement(s) are the label elements that comprise the primary information about hazards and protective measures on the label.
■ A signal word is a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used in the standard are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for the less severe hazards. Signal words were not
previously used in the HCS, although they do often appear on consumer labels. It is important to be aware of—and train workers on—the way signal words convey a difference in the severity of the hazard. While the product is hazardous wherever a signal word is indicated, the signal word chosen can give a preliminary idea of the relative significance of the effect.
■ A hazard statement is a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. Example: Fatal if swallowed.
The hazard statement(s) for a hazardous chemical describe the hazard(s) in text, in a simple, direct manner. There is a hazard statement for each hazard category of a hazard class, and it will vary depending on the degree of hazard. The example presented above is a hazard statement for acute oral toxicity. The hazard statement conveys that the chemical is severely toxic, and ingestion of the chemical results in death. But for less toxic chemicals, the hazard statement may be “toxic if swallowed” or “harmful if swallowed.” As with
the signal words, this information conveys the relative severity of the hazard, which impacts how it is handled and controlled.
■ A pictogram is a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are designated under this standard for application to a hazard category. Under HazCom 2012, pictograms are black symbols, on a white background, with a red diamond border. For example, this is the pictogram for oxidizers:
Pictograms are an important addition to the hazard communication tools in the standard. A pictogram draws the attention of a label reader, and you and your workers should be aware that the appearance of a pictogram in a red diamond frame means that a hazard of concern is present in the product. Some of the
pictograms in the standard have symbols that resemble the hazardous effect, and others are merely meant to attract attention. Pictograms may be used for several different hazardous effects as well.
Pictograms have long been used internationally because they convey information without text. This allows users who are either literate in a different language than that used on the label or who are not literate at all to understand that the chemical is hazardous.
One of the systems that has long used pictograms is the international transport system. This system has been adopted by the U.S. Department of Transportation (DOT), and is familiar to those who handle shipping containers in the United States. The symbols have been harmonized as much as possible for the hazards covered both in transport and in the workplace. While both pictograms are diamond-shaped, the transport system’s pictograms have backgrounds of various colors. Where the shipping container is also the container used in the workplace, workers must be made aware of the DOT pictograms1, as they may appear on the label in addition to, or instead of, the HazCom 2012 pictograms used to represent the same hazard. See Figure 4 for examples of DOT pictograms. Note that the environment pictogram located in the center
of the bottom row in Figure 3 is not required under the OSHA standard since OSHA does not regulate environmental hazards. However, you may see this pictogram used on labels and SDSs to convey environmental hazards, and that will provide useful information for you to use in managing your chemicals.

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