Under the previous OSHA Hazard Communication Standard (HCS), the manufacturer or importer had to label containers with the identity of the chemical, and the appropriate hazard warnings. How this was done was left to the manufacturer and importer. The new HazCom 2012 standard, which is aligned with GHS, provides a system for labeling containers. It specifies the information that is to be included for each hazard class and category. HazCom 2012 labels are required to have:
Pictogram: A pictogram consists of a symbol on a white background within a red diamond. The symbol visually conveys hazard information about the chemical. Under the new OSHA HCS there are nine pictograms that may be used on GHS labels. However, only eight of the pictograms are required under the OSHA HCS, the exception being the environmental pictogram. (Environmental hazards are not within OSHA's jurisdiction.)
Signal words: The new OSHA HCS specifies that one of two words be used to indicate the relative level of severity of the hazard. This signal word quickly communicates the level of the potential hazard. The two signal words that are used are "danger" and "warning." "Danger" is used for the more severe hazards which pose a risk of death or serious injury, while "warning" is used for less severe hazards.
Hazard Statement: The new OSHA HCS assigns a hazard statement to each hazard class and category. The hazard statement describes the nature of the hazard(s) associated with the chemical, including, where appropriate, the degree of the hazard.
Precautionary Statement: This is a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical. It also provides storage precautions, and identifies improper storage or handling methods.
How have workplace labeling requirements changed under the converted system?
The old HCS gave employers flexibility regarding the type of system to be used for right-to-know labeling in their workplaces. The new HazCom 2012 standard has retained that flexibility. Employers may choose to label workplace containers either with:
- The same GHS label that is on shipped containers for the chemical
- Label alternatives that meet the requirements of the new HazCom 2012 standard.
- NFPA 704 Hazard Rating
- Hazardous Material Information System (HMIS) aka Color Bar Labels
The information supplied on these labels must be consistent with the revised HazCom 2012 standard. For example, there can be no conflicting hazard warnings or pictograms.