HMIS Labeling system

ez Explanations

HMIS® stands for Hazardous Materials Identification System®, an in-house labeling system copyrighted by the American Coatings Association (ACA). The program uses a numerical hazard rating system and labels with colored bars to indicate chemical hazards in the workplace.

HMIS® was originally developed for use by the paint manufacturing industry, but has since spread to numerous other service and manufacturing industries such as health care, chemical manufacturing, public utilities, transportation, education, and construction.

HMIS® labels always appear as a rectangle-shaped block of colored bars with hazard ratings of zero through four. Early versions of the HMIS® labels used a blue “health” bar on top, a red “flammability” below that, followed by a yellow “reactivity” bar and a white “PPE” area. There may be additional space on the label for other information, such as the product name, supplemental warnings, manufacturer information, or additional HMIS® information.

HMIS® III, the most current version of the system, replaces the yellow “reactivity” or “instability” block with an orange “physical hazard” block, which is more in line with OSHA defined hazards.

ACA first constructed HMIS® by using Health, Flammability, and Reactivity fields similar to those being used by NFPA. The NFPA’s system was developed for emergency responders. ACA adopted the widely recognized ratings criteria used by NFPA for flammability and reactivity, but the health ratings criteria developed by ACA were based on OSHA health ratings.

Scope

Under the HazCom standard at 1910.1200(f)(6), OSHA allows the use of workplace labeling systems like HMIS but only in-house. Any containers which leave the workplace must be labeled following the requirements at 1910.1200(f)(1).

Regulatory citations

None

Key definitions

Hazardous Materials Identification System® (HMIS): An in-house labeling system copyrighted by the American Coatings Association (ACA).
HMIS Hazard Ratings: The HMIS system uses four color-coded bars to represent types of hazards:
- Blue = Health
- Red = Flammability
- Orange = Reactivity/physical hazard
- White = Personal protection
Under the HMIS rating system, hazards are rated on a scale of 0 to 4, with 0 indicating no hazard or a minimal hazard and 4 indicating the most severe hazard. (These hazard ratings are the opposite of those found in OSHA's HazCom Standard.) The white personal protection section is not numerical but uses letters A through K to indicate the type of PPE required.

Summary of requirements

Under OSHA's Hazard Communication Standard, employers may use HMIS labeling in-house; see 1910.1200(f)(6). In CPL 02-02-079, OSHA says, “…the HMIS or NFPA system may be used as part of an employer’s workplace labeling system, if used in accordance with the NFPA and HMIS guidelines and as long as it does not cast doubt or contradict the validity of the label information. Employers must ensure that their training program instructs employees on how to use and understand the alternative labeling systems so that employees are aware of the effects of the hazardous chemicals to which they are potentially exposed.”

“Workplace labels must include the product identifier and general information regarding all of the hazards of the chemical(s) even when using the NFPA or HMIS system. In some cases, all hazards are not addressed by a particular rating system (e.g., chronic health hazards), and therefore, hazards not addressed must be communicated by words, pictures, symbols, or a combination thereof in addition to the NFPA or HMIS rating system.”

Train employees on your in-house labeling system.

['Hazard Communication', 'Signs and Markings']

['Hazard Classifications', 'Hazard Communication', 'Safety Data Sheets', 'HazCom Information and Training', 'Hazcom Labeling', 'Signs and Markings']

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