Can an employer use NFPA and HMIS labeling systems for in-house chemicals?

OSHA says that employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical, or with label alternatives that meet the requirements for the standard.

Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent with the HazCom standard (e.g., no conflicting hazard warnings or pictograms).

OSHA also says that all hazards that are not addressed by a particular rating system, such as chronic health hazards, must be communicated by words, pictures, symbols, or a combination thereof in addition to the ratings numbers used. If any of the required label information is missing, it is not compliant with the standard.

In short, employers may continue to use their current in-house labeling systems, but those labels may not be used on containers leaving the workplace.

Moreover, since these alternative labels would, at a minimum, only provide the product identifier and “general” information regarding the hazards of the chemicals, the employer must also make “specific” information regarding the physical and health hazards of the chemical immediately available to employees through other means. And, employers must train employees on both the GHS-style labels and any in-house labeling system.