What are the container labeling requirements under HazCom?

Labels for containers to be shipped

OSHA 29 CFR 1910.1200(f) requires the chemical manufacturer, importer, or distributor to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged, or marked with:

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

For solid materials, the required label may be transmitted to the customer at the time of initial shipment, and need not be included with subsequent shipments to the same employer unless the information on the label changes.

Workplace labeling

OSHA 1910.1200(f)(6) states that except as provided in 1910.1200(f)(7) and (f)(8), the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either:

• The information specified under 1910.1200(f)(1)(i) through (v); or,
• Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.

The second option includes the use of alternative labeling systems, such as the National Fire Protection Association (NFPA) 704 Hazard Rating or the Hazardous Material Information System (HMIS).

Stationary process containers

OSHA 1910.1200(f)(7) states that an employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the required label information. The employer shall ensure the written materials are readily accessible to the employees in their work area throughout each work shift.

Portable containers

Under 1910.1200(f)(8), the employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the “immediate use” of the employee who performs the transfer. Immediate use means that the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred. That means if the hazardous chemicals are transferred into unmarked containers, these containers must be labeled with the required information if any of the hazardous chemical is passed along to another employee or the chemical will be used for more than one shift.