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.

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