First blog post | OSHA/GHS FAQ’s

We decided to start this blog to enhance our communication with our customers, Twitter followers and to easily answer questions that our customers ask and we know others may be thinking the same thing.

Many of our customers come to us with questions about our products, their uses, and why they may need them. These questions are asked frequently and so our first blog post will be about our most Frequently Asked Questions regarding the newest OSHA Hazard Communication Standard (Hazcom) and OSHA’s adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

So, without further ado:


1) Are HCL’s GHS labels compliant?

Yes, HCL’s GHS labels are fully compliant with OSHA’s adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

2) Why don’t HCL’s GHS labels look exactly like the sample on the GHS website?

The actual label format or layout is not specified in the GHS.  As long as the GHS hazard pictograms, signal word and hazard statements are located together on the label, the label format can vary.  GHS publications show several “sample” format, but adopting their design is not required.

3) Why don’t HCL’s GHS labels need the Manufacturer’s address?

HCL’s GHS labels are “secondary container” labels, they are not meant to replace the manufacturer’s label on the original product (1).

What are the requirements for labels under the revised 2012 OSHA Hazard Communication Standard (HazCom)?

Labels require the following elements: a pictogram, a signal word, physical hazard statement as well as a precautionary statement, response, storage and disposal statements.

4)  Are there color or size requirements for GHS labels?  

The actual layout and label format is not specified in the GHS.
The only color requirements are as follows:
“Pictograms shall be in the shape of a square set at a point and shall include a black hazard symbol on a white background with a red frame sufficiently wide to be clearly visible” (2).

5) In what applications should GHS labels be used?

GHS labels must be used to identify all hazardous materials (chemicals that may pose a physical or health hazard) and their specific hazards.  All secondary containers in the workplace must be marked with OSHA/GHS compliant labels.

6)  Is the NFPA diamond required on a GHS label?

No, the NFPA diamond is not required on GHS labels. GHS allows the option of providing supplemental information related to the hazard of chemicals.  The NFPA diamond may be placed on labels if it does not contradict the information required by the GHS (3).
(1) Appendix C.2 https://www.osha.gov/dsg/hazcom/appendix_c.pdf and https://www.osha.gov/Publications/laboratory/OSHAquickfacts-lab-safety-labeling-chemical-transfer.pdf 
(2)Appendix C.2.3.1 https://www.osha.gov/dsg/hazcom/appendix_c.pdf 
(3) https://www.osha.gov/dsg/hazcom/hazcom-faq.html#collapse10

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