Hazard communication, or HazCom, was the second-most-cited OSHA violation in 2022. While the Occupational Safety and Health Administration (OSHA) has created detailed hazard communication requirements, container labeling requirements under HazCom are among the most significant.
HazCom label requirements differ in specificity. However, they must meet certain criteria to comply. Failure to do so could result in citations and even legal action. HazCom labels are part of a detailed approach to boosting worker health and safety. Employers and safety managers must know what is included in a HazCom label and be able to provide clear and easy-to-understand HazCom chemical labels on all chemicals their employees work with.
What Is OSHA’s HazCom Standard?
OSHA’s hazard communication standard (HCS), also known as the HazCom standard, requires employers and safety managers to provide employees with information about the identities and dangers of chemicals to ensure chemical safety in the workplace. In short, OSHA requires chemical manufacturers to evaluate the hazards of the chemicals they produce and prepare labels and safety data sheets (SDSs) to provide their customers with this information.
Similarly, employers must provide all workers exposed to hazardous chemicals with labels and SDSs. They must also provide these workers with appropriate training in handling these chemicals. There are four main elements to the HCS, including the following:
- Hazard classification: Describe the nature of the chemical or health hazards associated with the chemical, such as explosives and acute toxicity.
- Labeling: Easy-to-understand information must be presented on all hazardous communication labels, including pictograms, signal words, and several other elements.
- Safety data sheets: Each hazardous chemical in the workplace must have an SDS. Employees must have immediate access to the information on the SDS, and they must be regularly updated to include new chemicals and information.
- Information and training: OSHA requires employers to train their workers on HazCom chemical labels and SDSs, so they can recognize and understand the potential dangers of working with each chemical.
How Are Chemical Hazards Classified?
In 2012, OSHA aligned the hazard communication standard with the globally harmonized system (GHS) to provide a common approach to classifying and labeling chemicals nationally and internationally and reduce misunderstanding and trade barriers for American organizations.
Hazard classification provides the basis for the information provided in HazCom labels, SDSs, and worker training. The classification process has several steps, including the following:
- Identification: Identifying the chemical and the relevant data regarding the chemical’s potential hazards.
- Review: Reviewing the relevant data to determine the hazards associated with the chemical.
- Classification: Determining whether the chemical is hazardous and the degree of the hazard.
The HCS classifies any chemical representing health or physical hazards. Examples of each hazard may include:
Health Hazards:
- Toxicity
- Skin Corrosion/Irritation
- Carcinogenicity
- Aspiration Hazards
Physical Hazards:
- Explosives
- Flammable Gases, Aerosols, Liquids, or Solids
- Organic Peroxides
- Pyrophoric Chemicals
Why Are HazCom Label Requirements Important?
The goal of the HCS is to promote worker safety. It is based on the premise that workers have the right to know and understand the hazards associated with chemicals in the workplace. With comprehensive information at their disposal, employees can effectively store, handle, and transport hazardous chemicals and react appropriately in the event of accidental exposure.
The HazCom standard applies to various businesses, from dry cleaners to manufacturers. OSHA places great emphasis on this component of worker safety. If OSHA finds you in willful or repeated violation of OSHA standards, you can receive fines of over $150 000. Abiding by the HCS is in the best interests of your business.
HazCom labeling is critical for employees and directly impacts their responsibilities in the workplace. Employers must know what HazCom requires on chemical labels, train their workers to read and understand them, and apply new labels with the appropriate information to secondary containers. Untrained employees pose a significant risk of serious injury and even fatality to themselves and other workers.
What Are HazCom Labeling Requirements?
OSHA requires that several groups of information are included on labels before the HazCom labeling procedure is complete. The purpose of HazCom labels is to make information easy to understand. In conjunction with SDSs and training, workers have all the tools to facilitate safe handling and emergency protocols when working with potentially harmful chemicals.
All HazCom labels must include the following elements:
Product Identifier
The product identifier allows workers to identify the hazardous chemical. There are several different methods for identification, including the name of the chemical, code number, or batch number. The choice of appropriate identifier rests with the manufacturer, importer, or distributor. Still, they must ensure the same identifier is on the label and in section one of the accompanying SDS.
In most cases, you can find the product identifier in the top left corner of the label.
Chemical Manufacturer Details
Product labels from the manufacturer must include their contact details, the importer’s contact details, or the responsible party’s contact information. These include their name, address, and telephone number. Often, these details are placed in the top left corner, underneath the product identifier.
Signal Words
Signal words help workers discern the severity of the chemical hazard. Two signal words align with the HCS — “danger” and “warning”:
- Danger: When the word “danger” appears on a label, it indicates a more severe hazard.
- Warning: This word suggests a hazard of a less severe nature.
Regardless of the number of hazards a chemical may represent, only one signal word is on the label. The signal word often appears underneath the pictograms discussed below.
Hazard Statements
Hazard statements provide workers with a description of the hazards of a chemical, including the degree of the hazard if appropriate. An example of a hazard statement could be “highly flammable liquid” or “may cause liver and kidney damage when absorbed through the skin.”
A chemical with multiple hazards must include all the associated hazard statements on the label. Manufacturers can combine hazard statements to make them easier to read. They are specific to the hazard communication categories. They should be standardized so workers see the same message for the hazard every time, regardless of who produces the chemical or what the chemical is.
Hazard statements often appear beneath the signal word on the label.
Precautionary Statements
Precautionary statements describe the measures workers take to mitigate or prevent the effects of accidental exposure. There are four types of precautionary statements, including the following:
- Prevention statements: These explain how to minimize exposure to hazardous chemicals.
- Response statements: These outline the emergency response protocols users should take in case of accidental spillage or exposure, including first-aid responses.
- Storage statements: These explain how workers should store the chemical to prevent unnecessary or repeated exposure.
- Disposal statements: These describe how to dispose of the chemical per international, national, and regional regulations.
Examples of precautionary statements could include the following:
- Wear protective gloves.
- Keep away from heat, sparks, and open flame. No smoking.
- Do not breathe vapors.
- If exposed, call the poison center.
- Use a dry chemical or carbon dioxide fire extinguisher in case of fire.
Precautionary statements also detail the type of personal protective equipment (PPE) workers should use when handling a hazardous chemical.
OSHA does allow some flexibility for incorporating precautionary statements on a label. They can be combined to save space, but the most stringent must be on the label. The manufacturer may impose an order of precedence — putting the most critical statements first.
You can find this information underneath the chemical manufacturer details on the left of the label.
Supplementary Information
The manufacturer, distributor, or person responsible may provide additional instructions or information they consider helpful to workers in this section. They can also list any other hazards that may not be classified on the label. This information could include PPE pictograms, expiration dates, fill dates, or instructions for using the chemical.
You will often find this information in the bottom right-hand corner of the label.
Pictograms
Pictograms are graphic representations of the hazards of a specific chemical. OSHA’s adopted pictograms, aligned with the GHS, are used worldwide to improve worker health and safety. The GHS uses nine pictograms, but OSHA enforces eight. The ninth symbol — environment — is not a requirement, but manufacturers or workers can use it as supplementary information.
Each pictogram must have a symbol on a white background and be framed with a red border. The chemical hazard classification determines the pictogram on each label. The eight pictograms enforced by OSHA include the following:
- Health hazard: Represents carcinogens, mutagenicity, reproductive toxicity, respiratory sensitizers, target organ toxicity, and aspiration toxicity.
- Flame: Represents flammable, pyrophoric, self-heating, emitting flammable gas, self-reactive, and organic peroxides.
- Exclamation mark: Represents skin and eye toxicants, skin sensitizers, acute toxicity, narcotic effects, respiratory tract irritants, and hazards to the ozone layer (non-mandatory).
- Gas cylinder: Represents gases under pressure.
- Corrosion: Represents skin corrosion, burns, eye damage, and corrosiveness to metals.
- Exploding bomb: Represents explosives, self-reactive, and organic peroxides.
- Flame over circle: Represents oxidizers.
- Skull and crossbones: Represents acute toxicity, whether fatal or toxic.
The OSHA pictograms do not replace the chemical transport labels required by the Department of Transportation (DOT). DOT labels are required for shipping containers but not smaller containers inside the shipping containers. Smaller containers do need OSHA labels.
Replacement Labels and Secondary Container Labeling Requirements
Containers direct from a manufacturer or distributor are already labeled under the HCS. Still, any chemicals moved into a secondary container, such as a spray bottle, must also be labeled. The duty of transferring and labeling secondary containers lies with the organization’s employer and safety managers.
Labels must always be legible and include a product identifier and general information regarding the hazards of a chemical. Suppose the information on the container is no longer readable. In that case, OSHA requires a new and legible label to be placed on the container. You can generate a replacement label as long as it is aligned with the HCS, or you can obtain one from a vendor.
What Responsibilities Do Employers Have for HazCom Chemical Labels?
Although hazardous chemicals arrive with labels from chemical manufacturers, employers have various responsibilities regarding maintaining the labels on containers if they become illegible for any reason. They must also ensure workers know of any newly-identified hazards that do not appear on the current label.
As part of the HCS, all organizations must have a written hazard communication program specific to their business. This program is a written outline of the organization’s plans to deal with chemical hazards in the workplace and communicate these to employees, promoting health and safety.
Workplace Labels
Under the HCS, employers and safety managers can create their workplace labels. They can provide all the required information on the chemical manufacturer label or a combination of pictograms, symbols, and the product identifier.
The information on workplace labels must — in conjunction with other information immediately available to employees — provide detailed information regarding the hazards of the chemicals.
OSHA Hazcom Training Requirements
While HazCom requires organizations to have adequate labeling on all chemical containers and SDSs to communicate the potential dangers in depth, it also requires them to train employees on safety when working with hazardous chemicals. Employees should complete their HazCom training before their first assignment and complete further training each time a new chemical is introduced in their work area.
Training must align with the tasks workers complete in the course of their work and must include information about the hazardous chemicals they work with. In line with the HCS, training must include the following:
- Methods to detect hazardous chemicals in the workplace,
- How to read SDSs and where to find them,
- Emergency procedures in case of accidental exposure to chemical hazards,
- Where to find and how to use PPE,
- How to get information from labels and pictograms, and
- The details of the hazard communication program, including an explanation of the labels received on shipped containers and the internal workplace labeling system.
Refresher training is not required under the HCS. As an employer or safety manager, you know workers will likely only remember some aspects of their training. Refresher training courses are highly beneficial to ensure compliance with the HCS and prevent unnecessary incidents.
OSHA does not specify a specific format for HazCom training. However, organizations should focus on the topic’s most effective and comprehensive training format. Safety managers should complete HazCom training to guide the workforce to continued compliance.
What Does Typical HazCom Training Include?
It’s important to remember the primary objective of the HCS — to equip workers with information that elevates their health and safety in the workplace. HazCom labels aim to provide professionals with detailed information on handling, storing, and transporting hazardous chemicals.
One of the more extensive aspects of HazCom training is educating workers about the pictograms on labels, as these provide immediate and recognizable details about the chemicals they are working with. Another is learning the various safety precautions associated with each chemical and being able to recreate these protocols in a practical environment.
For safety managers, HazCom training could include the following topics:
- SDS formatting procedures,
- Developing a hazard communication program for your workplace,
- Identifying, classifying, and labeling hazardous chemicals, and
- Training employees to comply with the HCS protocols when handling dangerous chemicals.
Give Your Employees the Knowledge to Protect Themselves With NASP
The National Association of Safety Professionals (NASP) provides the training and structure to implement comprehensive hazard communication. We can help you meet or exceed OSHA regulations with our in-classroom and online training courses built for and by safety professionals.
Our Hazard Communication Specialist course can equip you with the skills and information necessary to ensure HazCom compliance within your organization. You can train your workforce to handle hazardous chemicals in the workplace, regardless of your training requirements. If you would like to learn more about the Practical Approach to Workplace Safety, please reach out to us today, and someone will be in touch to answer your questions.
