Tuesday, May 12, 2015

Steps to an effective hazcom program for employers

3. Ensure containers are labeled cont'd


Some employers use third-party workplace label systems, such as those that have numerical ratings to indicate the hazards (e.g., National Fire Protection Association (NFPA) or Hazardous Materials Identification System (HMIS)). These may be used in conjunction with the supplemental information on the label to ensure that workers have complete information, as long as the ratings are consistent with the hazard definitions in HazCom 2012, i.e., the criteria used to assign the numerical ratings reflects the hazard categories in each hazard class in HazCom 2012. One note with regard to numerical ratings—these systems
generally use the number 1 to indicate the lowest degree of hazard, and the number 4 as the highest degree. This is the opposite of the hazard category numbering in HazCom 2012. Therefore, if as an employer you are preparing such labels based on information on the SDS, you must ensure that the numbers are properly applied to reflect the accurate degree of hazard information. Category numbers do not appear on HazCom 2012 shipped container labels, and are not equivalent to the hazard rating systems.


The employer must make sure that labels in the workplace are legible and prominently displayed. While the label information must be in English, employers are free to add warnings in other languages if workers would find that helpful. OSHA has prepared QuickCards™ to describe the label elements (OSHA 3492), as well as illustrate the pictograms (OSHA 3491). These are available on the OSHA web page, or can be obtained from your local OSHA area office.

If your workplace is inspected by OSHA, CSHOs will be looking for at least the following aspects of your labeling approach:
1. Designation of person(s) responsible for ensuring compliant labeling of shipped and inplant containers;
2. Description of written alternatives to labeling of stationary process containers (if used);
3. Appropriate labels on all workplace containers, including those received from a supplier, secondary containers, and stationary process containers;
4. A description and explanation of labels on both shipped and workplace containers included in the employee training program; and,
5. Procedures to review and update workplace label information when necessary.

Wednesday, May 6, 2015

Steps to an effective hazcom program for employers

3. Ensure containers are labeled cont'd

Figure 3. HazCom 2012 Pictograms
HCS Pictograms and Hazards

Health Hazard

Health Pictogram
  • Carcinogen
  • Mutagenicity
  • Reproductive Toxicity
  • Respiratory Sensitizer
  • Target Organ Toxicity
  • Aspiration Toxicity

Flame

Health Pictogram
  • Flammables
  • Pyrophorics
  • Self-Heating
  • Emits Flammable Gas
  • Self-Reactives
  • Organic Peroxides

Exclamation Mark

Health Pictogram
  • Irritant (skin and eye)
  • Skin Sensitizer
  • Acute Toxicity
  • Narcotic Effects
  • Respiratory Tract Irritant
  • Hazardous to Ozone Layer (Non-Mandatory)

Gas Cylinder

Health Pictogram
  • Gases Under Pressure

Corrosion

Health Pictogram
  • Skin Corrosion/Burns
  • Eye Damage
  • Corrosive to Metals

Exploding Bomb

Health Pictogram
  • Explosives
  • Self-Reactives
  • Organic Peroxides

Flame Over Circle

Health Pictogram
  • Oxidizers

Environment

(Non-Mandatory)
Health Pictogram
  • Aquatic Toxicity

Skull and Crossbones

Health Pictogram
  • Acute Toxicity (fatal or toxic)

■ A precautionary statement is a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling. Example: Do not eat, drink, or smoke when
using this product.

Precautionary statements are key to helping you decide what you need to do to protect workers and your workplace. There are four types of statements: Prevention, Response, Storage, and Disposal. These have been assigned to hazard classes and categories.

Therefore, a compliant HazCom 2012 label on a shipped container will have at least the following information as shown in Figure 5 (supplemental information is permitted as long as it does not conflict with the required information).

You are required by paragraph (f)(6) of the standard to ensure that containers of hazardous chemicals in your workplace are labeled. For those containers that are received already labeled from the supplier, and are used in the workplace, simply maintaining the label received from the supplier is the best and easiest option. However, the standard is flexible, and employers may relabel these containers, or label other containers used in the workplace with various options as long as workers have immediate access to the specific information
about the physical and health hazards of the chemical. This could be included in the workplace hazard communication program.

Under paragraph (f)(7), employers may use signs, placards, process sheets, batch tickets, operating procedures, or other written material instead of affixing labels to individual stationary process containers, as long as the alternative method identifies which containers it applies to and conveys at least general information regarding the hazards of the chemicals. Paragraph (f)(8) of the standard also addresses portable containers into which the hazardous chemicals are transferred from a labeled container, and which are for the immediate use of the employee who performs the transfer. These portable containers do not have to be labeled.