What are Hazard Pictograms?
Hazard pictograms are graphic symbols used on GHS labels to communicate information about the hazards of a chemical. Hazard pictograms may be referred to by other names, such as:
- GHS Hazard Pictograms
- GHS Pictograms
- HCS Hazard Pictograms
- OSHA Pictograms
- Hazard Communication Pictograms
- CLP Pictograms (in the European Union)
However, each of these names refers to the same thing – a symbol used on a GHS label to identify hazards.
OSHA's Hazard Communication Standard (HCS, or HazCom 2012) defines nine hazard pictograms, one of which is optional. By specifying standard hazard pictograms the HCS ensures consistency in the labeling of all chemicals, eliminating confusion and making the labels easier to understand.
OSHA's Requirements
OSHA requires that labels be used to inform workers about chemical hazards, and that those labels include hazard pictograms. The hazard pictograms quickly and accurately alert users to the types of hazards resulting from exposure to the chemical.
Labels, as defined in the HCS, are “written, printed or graphic informational elements concerning a hazardous chemical that are affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging.”
There are two types of labeling requirements, one for companies that sell chemicals to others, and simpler requirements for in-house labeling of containers that never leave a facility.
Chemical manufacturers, importers, and distributors are required by OSHA to ensure that every shipment of a container holding a hazardous chemical be labeled, tagged, or marked with the following information:
- Name, address, and telephone number of the importer, manufacturer, or distributor.
- A Product Identifier (for example, chemical name, code number, or batch number).
- A Signal Word indicating the relative level of severity of the hazard.
- Hazard Statement(s). These are standard statements that describe the nature of the hazards.
- Precautionary Statement(s). These are standard measures that are used to minimize or prevent adverse effects resulting from exposure to the chemical.
- Pictogram(s).
Labels must be legible, be in English, and they must be of a size and in a location such that they are easy to see. Labels may contain text in other languages, in addition to English.
GHS Requirements
For hazardous chemical containers shipped by an importer, manufacturer, or distributor, the pictograms are required to consist of a red diamond (a square on a point) containing a black hazard pictogram on a white background. The hazard pictogram must be sufficiently large so as to be clearly visible. A red diamond by itself (an empty red diamond) is not a hazard symbol and may not be included on the label.
There are nine hazard pictograms defined in the GHS Purple Book. OSHA has adopted eight of these. OSHA does not require the use of the environmental pictogram, but this pictogram may be used to provide supplementary information.
The symbols used in the GHS hazard pictograms should already be familiar to most chemical users, as they are the same symbols used for transportation.
Hazard Pictograms and the DOT
The U.S. Department of Transportation (DOT) requires that chemical containers such as drums, totes, tanks, or other types of containers, have external markings that conform with the requirements of 49 CFR 172, Subpart E. The GHS hazard pictograms do not replace these diamond-shaped labels, but are used in addition to the DOT required pictograms. This may cause some confusion because OSHA 1910.1200 Appendix C.2.3.3 states: “Where a pictogram required by the Department of Transportation under Title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in C.4 for the same hazard shall not appear.”
“C.4” provides the specifications for the OSHA HCS hazard pictograms.
The problem is that some international shipments must have both the GHS hazard pictograms and the DOT hazard pictograms on the container because the destination country requires a GHS label. Because of this conflict, OSHA is planning to revise C.2.3.3. and is not enforcing the current standard.
The DOT diamond label is required on the outside of shipping containers; however, OSHA also requires that smaller containers, inside the larger shipping container, have the appropriate GHS hazard pictograms.
Hazard Pictograms - Workplace Labels
There are some differences in hazard pictogram requirements when the labeling is being done in-house, for use solely within a single facility. Containers that do not leave the workplace may use GHS labels similar to the importer/manufacturer supplied GHS labels. However, they may also use simpler labels, that have just the product identifier, and words, pictures and symbols which, in combination with other information that is readily available to employees (such as the Safety Data Sheets), to provide the needed information about the hazards of the chemical.
If the employer chooses to use GHS type labels, or use the GHS hazard pictograms on signs or labels on workplace containers, the pictograms may have a black border, rather than a red border.
A third labeling option is available if an employer has been using an in-house system of labeling that meets the requirements of HazCom 1994. The employer may continue to use this existing labeling system, if it provides employees with the necessary information about the hazards of the chemical. The workplace “labeling” system may use signs, placards, process sheets, batch tickets, operating procedures, or other types of materials to identify and communicate information about hazardous chemicals. The key requirement is that employees have the information they need concerning the hazards of the chemicals in their workplace.
Employers may also use other symbols on labels, such as instructional pictograms, in addition to the eight GHS hazard pictograms specified by OSHA. An example of an instructional pictogram would be a pictogram of a person wearing goggles. This informs employees that goggles must be worn while handling or using the chemical. What is important is that:
- A standard for pictograms must be established and followed within the workplace.
- Workplace pictograms do not cause confusion or conflict with the GHS pictograms.
- Employees must be trained to recognize all of the pictograms that might be used.
NFPA Diamond vs. Hazard Pictograms
The NFPA diamond or color bars may be included on workplace labels, or employers may use NFPA diamond or color bar labels, provided the labels meet all of the requirements of the OSHA HCS. This includes ensuring employees have the information they need about chemical's hazards. This information may be provided either on the label, or by other means. The requirement is for employees to be fully informed about, and protected from the hazards associated with chemicals, without regard to how that information is communicated.
When are Hazard Pictograms Not Required?
Finally, there is one condition when a container holding a hazardous chemical does not need to be labeled. If a hazardous chemical is transferred from a labeled container to a portable container that will be used immediately by the employee who did the transfer, no label is required for the portable container.