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FULL VIDEO SCRIPT: Welcome back for the second week of Summit Safety Group’s emphasis program on Hazard Communication. If you didn’t catch last week, I’d encourage you to go back and watch the full video. We focused on some critical elements that need to be a part of your WRITTEN HAZCOM program. This week we are gonna dive deep into a very commonly cited item; the labeling of various chemicals found in the shop or in the field. And we’re not just gonna cover secondary containers. We’re covering all labeling requirements, so let’s jump in.
Labels are the first part (found in paragraph (f) of the three-part approach to communicating information downstream to your teammates. So, a label must be on the immediate container of every hazardous chemical. The label acts as an immediate type of warning since it’s present in the work area, and directly on the actual container of a hazardous chemical. This is important because it acts as a snapshot of the hazards and protective information related to the chemical, and a summary of the more detailed information available on the SDS. When you purchase a hazardous chemical from a supplier, you will receive a container that is labeled with the information required under the Hazard Communication Standard or “HCS.” Now, the label requirements in the HCS changed significantly with the publication of HazCom 2012. Under the prior standard, chemical manufacturers and importers were required to convey the hazards and identity of the products, but were not given specifications on how this was to be done. As a result, labels varied in terms of how the information was conveyed, the terminology used, and the design of the label. This made it more difficult for employers and workers to access and comprehend the information presented than if chemical manufacturers and importers follow the same approach. The label requirements for the newer, revised standard are more specific, which has lead to increased uniformity. This benefits employers and workers by providing the information in standardized language and graphics, making it easier to understand, and helping to ensure that labels on containers of the same chemical from different suppliers have the same information. HazCom 2012 provides chemical manufacturers and importers the information to be conveyed once they have determined the hazard of a chemical. The labels you receive on a shipped container must have the Product identifier, Signal word, Hazard statement(s), Pictogram(s), Precautionary statement(s), and the Name, address, and phone number of the responsible party. It’s important that you understand these terms so let me break them down for you. First off, the product identifier is any chemical, common, or trade name that the chemical manufacturer or importer chooses to use on the label. The term must also appear on the SDS. The signal word, hazard statement(s), pictogram(s), and precautionary statement(s) are the label elements that comprise the primary information about hazards and protective measures on the label. Second, a signal word is a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used in the standard are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for the less severe hazards. Signal words were not previously used in the HCS, although they do often appear on consumer labels. It’s important to be aware of—and train workers on—the way signal words convey a difference in the severity of the hazard. While the product is hazardous wherever a signal word is indicated, the signal word chosen can give a preliminary idea of the relative significance of the effect. Third. A hazard statement is a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. An example of this is the statement: “Fatal if swallowed.” This hazard statement on a hazardous chemical is describing the hazard in text, and in a simple, direct manner. Just so you know, there is a hazard statement for each hazard category of a hazard class, and it will vary depending on the degree of hazard. The example I just presented is a hazard statement for acute oral toxicity. The hazard statement conveys that the chemical is severely toxic, and ingestion of the chemical results in death. But for less toxic chemicals, the hazard statement may be “toxic if swallowed” or “harmful if swallowed.” As with the signal words, this information conveys the relative severity of the hazard, which impacts how it is handled and controlled. Fourth: A pictogram is a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are designated under this standard for application to a hazard category. Under HazCom 2012, pictograms are black symbols, on a white background, with a red diamond border. For example, this is the pictogram for oxidizers. Pictograms are an important addition to the hazard communication tools in the standard. A pictogram draws the attention of any worker reading the label, and you and your workers should be aware that the appearance of a pictogram in a red diamond frame means that a hazard of concern is present in the product. Some of the pictograms in the standard have symbols that resemble the hazardous effect, while others are merely meant to attract attention. Pictograms may be used for several different hazardous effects as well as seen here in this picture. Pictograms have long been used internationally because they convey information without text. This allows users who are either can’t read or those that speak a different language, to understand that the chemical is hazardous. One of the systems that has long used pictograms is the international transport system. This system has been adopted by the U.S. Department of Transportation (or DOT), and is familiar to those who handle shipping containers in the United States. The symbols have been harmonized as much as possible for the hazards covered both in transport and in the workplace. While both pictograms are diamond-shaped, the transport system’s pictograms have backgrounds of various colors. Where the shipping container is also the container used in the workplace, workers must be made aware of the DOT pictograms , as they may appear on the label in addition to, or instead of, the HazCom 2012 pictograms used to represent the same hazard. Here is a diagram that includes examples of DOT pictograms. Note that the environment pictogram located in the center of the bottom row is not required under the OSHA standard since OSHA does not regulate environmental hazards. However, you may see this pictogram used on labels and SDSs to convey environmental hazards, and that will provide useful information for you to use in managing your chemicals. Fifth: A precautionary statement is a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling. An example of this type of statement could be: “Do not eat, drink, or smoke when using this product.” Precautionary statements are key to helping you decide what you need to do to protect workers and your workplace. There are four types of statements: Prevention, Response, Storage, and Disposal. These have been assigned to hazard classes and categories. Therefore, a compliant HazCom 2012 label on a shipped container will have at least this information pictured here. Supplemental information is permitted as long as it does not conflict with the required information. Now, you are required by paragraph (f)(6) of the standard to ensure that containers of hazardous chemicals in your workplace are labeled. For those containers that are received already labeled from the supplier, and are used in the workplace, simply maintaining the label received from the supplier is the best and easiest option. However, the standard is flexible, and employers may relabel these containers, or label other containers used in the workplace with various options as long as workers have immediate access to the specific information about the physical and health hazards of every specific chemical. This is where we see several OSHA citations each year and it’s an easy fix. But under paragraph (f)(7), employers may use signs, placards, process sheets, batch tickets, operating procedures, or other written material instead of affixing labels to individual stationary process containers, AS LONG AS, the alternative method identifies which containers it applies to and conveys at least general information regarding the hazards of the chemicals. Paragraph (f)(8) of the standard also addresses portable containers where hazardous chemicals are transferred from a labeled container, and are for the immediate use of the employee who performs the transfer. These portable containers do not have to be labeled. Some employers use third-party workplace label systems, such as those that have numerical ratings to indicate the hazards (such as the National Fire Protection Association (or NFPA) or Hazardous Materials Identification System or (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. 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 you are preparing these types of 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. If your workplace is inspected by OSHA, compliance officers will be looking for at least the following aspects of your labeling approach. So this part is very important:
#1. The designation of a responsible person that can ensure compliant labeling of shipped and in-plant containers;
#2. A 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. Now there are all things are consultants are consistently trying to help you all with so please do your best to pay attention to any breakdowns we note on our audits and help us help you get these gaps filled and put systems in place to ensure every single chemical is accounted for labeled properly.
Alright, that wraps up this week. Next week we will be diving into the proper way to maintain your SDS sheets. It’s a commonly cited violation and we wanna make sure we’re pointing you in the right direction. For Summit Safety Group and Safety Consulting NOW, I’m Jake Woolfenden and I’ll see you next week. Please check out training.safetyconsultingnow.com to subscribe to our full video training library. I’ll see you in the next one.