HAZCOM Labels

The requirements for labeling hazardous chemicals have been revised by OSHA under its updated Hazard Communication Standard (also called HCS).

 The updating of the HCS by incorporating the labeling requirements of the Globally Harmonized System of Classifying and Labeling of Chemicals (GHS) has been performed by OSHA to align the HCS standard to international standards while ensuring improved consistency and quality in the labeling of all chemicals.

 Labels are critical tools for communicating hazard information to workers and employers, and the more they convey the information clearly and comprehensively the more they help in preventing workplace exposures, accidents, injuries and illnesses associated with hazardous chemicals.

 The benefits of the improved labels include:

  • Provide immediate and powerful visual reminders of chemical hazards
  • Better worker comprehension of hazards involved in handling, using and storing of various chemicals
  • Decreased risks of exposure to hazardous chemicals
  • Easier training of workers on precautionary and remedial measures to exposure to hazardous chemicals
  • Reduced workplace injuries and illnesses related to accidental exposures to hazardous chemicals
  • Greater productivity and increased savings
  • Enhanced international trade on hazardous chemicals

What Is a Hazcom Label?

According to the HCS, a label is an appropriate group of printed, written or graphic information elements about a hazardous chemical, which is affixed, printed or attached to the actual container or the outside packaging of the hazardous chemical.

OSHA’s HCS requires chemical suppliers and manufacturers to label, tag or mark every container of hazardous chemical before dispatching or selling for use in the workplace. A standard Hazcom label must have:

  • Product identifier
  • Signal word
  • Hazard Statement (s)
  • Precautionary Statement (s)
  • Pictogram (s)
  • Name, telephone number and address of the chemical importer, manufacturer or other responsible party

Before the adoption of GHS in 2012, OSHA did not place specific requirements for container labeling, allowing chemical distributors and manufacturers to label chemical containers as they wished.

As a result, NFPA (National Fire Protection Association) and HMIS (Hazardous Material Information System) labeling systems were the most common labeling methods for communicating hazards. But with the alignment of HCS labeling to GHS, OSHA is implementing a whole new system in which every manufacturer or distributor is applying the same underlying criteria for classifying and labeling chemicals.

Hazcom 2012 has changed the labeling of chemicals from a performance-based model to one that has specific and more structured elements. The revised Hazcom label requires that accurate information about chemical hazards is conveyed and that labels must provide:

  • Quick striking and visual notations that alert users of the hazards of chemicals.
  • Clear information on nature and degree of specific hazards.
  • Clear instructions on handling hazardous chemicals and clear precautionary measures to avoid exposure.
  • Clear information about supplier or manufacturer of the chemical and how to reach him/her.

While Hazcom labels provide crucial information on handling, usage, storage and transportation of hazardous chemicals, they are usually limited by design in the scope of information they can contain. Therefore, hazardous chemicals must be accompanied by Safety Data Sheets (SDSs), which act as the more complete resources for details about the hazardous chemicals.

hazcom label

Label Elements

Label elements refer to the specific signal word, pictogram, hazard statement and precautionary statement for every hazard class and category. A typical Hazcom label must contain:

Contact information: The name, telephone number and address of the chemical manufacturer, distributor or importer.

Product identifier: Batch number, code number or chemical name used to identify a hazardous chemical. The identifier permits cross-references and comparison of a list of hazardous chemicals in a written hazard communication program, SDS or label. Manufacturers, distributors and importers have to give chemicals their identifiers, but when they have done so, they must make sure that the same identifier is used in both the label and the SDS of a product.

Signal Word: Word used to show the relative degree of severity of the hazard and to alert workers (readers) of the potential hazards of the chemical. The most common signal words are “Danger” and “Warning”. “Warning” is used for less severe hazards while “Danger” is used for more severe hazards. There can only be one signal word on a label regardless of how many hazards a chemical has. Therefore, if one hazard warrants the signal “Danger” and another warrants “Warning”, then “Danger” is used on the Hazcom label.

Hazard statement: Statement assigned to a specific hazard class and category and is used to describe the nature of the hazard of the chemical. Sometimes, it may be used to indicate degree of hazard. Examples of hazard statement: “Highly flammable gas”, “Cause kidney damage through prolonged exposure”, and “Causes acute eye damage at a temperature above 50 degrees Celsius.” All applicable hazard statements must be included on the Hazcom label, but it is advisable to combine the statements appropriately to avoid redundancy and to boost readability. Besides, hazard statements must be specific to hazard categories to ensure that chemical users see the same hazard statements for similar hazards not matter what a chemical is or who produces it.

Precautionary statement: Phrase describing the recommended measures for minimizing or preventing adverse effects of exposure, mishandling or improper storage of a hazardous chemical. There are 4 types of precautionary statements: prevention (instructions on minimizing exposure), response (instructions on remedial measures and first aid in case of accidental exposure or spillage), storage and disposal.

Pictogram(s): A pictogram a black symbol placed on a white background and within a red diamond (square) frame. However, a red diamond frame that is set at a point on the label is not a pictogram if it does not contain a hazard symbol. In fact, such empty frames are not permitted on labels. Besides, a pictogram must be sufficiently wide to be seen clearly. Under the GHS, there are 9 pictograms, but only 8 of the pictograms are necessary under the revised HCS because the environmental pictogram is not obligatory and may only be used to offer additional information. Workplace Hazcom labels may use black borders instead of red ones.

Language of a Hazcom Label

Hazcom 2012 labels must be legible, created in English and displayed prominently. However, the manufacturer, importer or distributor of a chemical is allowed to use another language in addition to English.

The label may also provide additional information that the manufacturer or supplier consider helpful to chemical users, such as the percentage of ingredients in the hazardous chemical which are of unknown acute toxicity.

Any supplementary information provided on a label must never contradict or detract users from fundamental information. OSHA also requires that manufacturers and suppliers of hazardous chemicals revise labels after 6 months when new and significant hazard information becomes available.

Labeling Solid Materials

For solid materials such as solid wood, metal or plastic items, labeling should occur during initial shipment to a customer, and may not be included during subsequent shipment of the same materials to the same employer/customer unless the labeling information changes. This exception to requiring labels on every container applies only to solid materials but does not apply to hazardous chemicals that may cause adverse effects if exposure occurs during transit (such as pesticides in grains or cutting fluids).

hazcom label

Labeling in the Workplace

At the workplace, employers can choose to provide the necessary hazard information through manufacturer labels or create their own workplace labels (using unique product identifiers, symbols, words or pictures). Therefore, all containers of hazardous chemicals that are handled, used or stored in the workplace must be labeled, marked or tagged with either:

  • Product identifier, words, pictures, symbols or a combination of elements which provide accurate information about the hazards of the chemicals. Or,
  • Signs, process sheets, placards, operating procedures, batch tickets or other relevant written materials which aid in identifying the chemical and provide the relevant information that can prevent workplace exposure

Employers are not required to label portable containers of hazardous chemicals which are intended for immediate use or for transfer of chemicals from labeled containers. For example, drugs dispensed in the pharmacy for immediate direct administration into patients are exempted from labeling.

The responsibilities of employers in Hazcom Labeling at the workplace include:

  • Must ensure that workplace labels and all forms of warning are prominently displayed on chemical containers and written in English. Employers with workers who speak other languages may ensure the material is presented in both English and the language frequently used by the workers
  • Employers must ensure that labels are not removed or defaced from incoming containers, unless the containers have been marked with necessary information. Workplace labels must be available in the working areas throughout all work shifts and employers must re-label items whose labels have been defaced or removed
  • Whenever employers come across newly-identified hazards or information not disclosed on labels, they must provide the information to workers promptly
  • Employers may also continue to use other hazard rating systems such as NFPA or HMIS requirements for workplace labels as long as the labels conform to HCS and the workers have immediate and full access to the hazards of the chemicals
  • It is not the responsibility of employers to update labels on shipped containers even if the chemical containers are labeled under Hazcom 2012. However, just as manufacturers, distributors and importers, employers must revise their workplace labels within six months after new hazard information becomes available so that the labels can reflect the new information

Phase-in Period for Hazcom 2012 Labeling

  • All hazardous chemicals that are shipped after 1st June 2015 must have Hazcom labels with all the specified elements (signal words, pictograms, hazard statements and precautionary statements)
  • Manufacturers, distributors, and importers are allowed to start using Hazcom labels of the revised HCS before the effective date of June 1, 2015, if they choose to do so. And until June 1, 2015, manufacturers, distributors and importers may choose to comply with either the Hazcom 1994 labeling system or the revised standard; while distributors may choose to comply with Hazcom 1994 until December 1, 2015
  • All containers of hazardous chemicals must be labeled according to the revised HCS standard by June 1, 2016; and every container shipped after 1st June 2015 must have the new Hazcom label. OSHA has given distributors an additional 6 months, until December 1, 2015, to label all shipped containers properly
  • Employers must comply with the new labeling requirements by June 1, 2016, and have up to this date to offer additional training to employees and to update their written Hazcom plans.