Is it a hazardous chemical?
Chemical manufacturers are required to properly label their hazardous chemical products. Properly label means compliance with OSHA Globally-Harmonized System requirements. These requirements can be found in OSHA General Industry Standard 1910.1200.
How does the manufacturer let you know if it is considered hazardous?
The first thing to look for is the signal word. There are two choices for signal words under OSHA GHS standards. If you see either word Danger or Warning on the label, the chemical manufacturer considers the chemical be hazardous. The choice of a signal word is based on the manufacturers hazard determination and classification of the hazard(s). Appendices A and B of the OSHA Haz Com standard followed by use of Appendix C of the standard walks the manufacturer through the process.
Key Point – this classification is the responsibility of the manufacturer and not the end user of the product.
Another indicator that a product is a hazardous chemical is when a pictogram is on the label. The pictogram is intended to be a universal symbol of a chemical hazard. More on pictograms next week.
Check the label before accepting delivery of a chemical. If a container (drum or gallon) has a torn or otherwise incomplete label, it should not be accepted. You should not assume you know what is in that container. Be sure to train your employees who receive hazardous chemical products.
What if you tap out of a drum into another container that will not be used up and will be stored?
This can be challenging. The OSHA standard requires the following label information on the container:
• Name, Address and Telephone Number of the Manufacturer • Product Identifier • Signal Word • Hazard Statement(s) • Precautionary Statement(s) • Pictogram(s).
It can be difficult to get all this information on a secondary container label.
OSHA states that as an alternative measure a company can establish a system where the product identifier and words, pictures, symbols or a combination thereof, in combination with other information immediately available to employees, provides specific information regarding the hazards of the chemicals. This workplace labeling system may include signs, placards, process sheets, batch tickets, operating procedures, or other such written materials to identify hazardous chemicals. Any of these labeling methods or a combination may be used instead of a label from the manufacturer, importer or distributer as long as the employees have immediate access to all of the information about the hazards of the chemical.
Bottom line- Make sure the contents of all hazardous containers are identifiable to employees and that all pertinent hazard information is immediately available to employees.
Rich Galutia CSP specializes in the areas of employee safety (OSHA), trucking compliance (FMCSA) and animal feed safety (FDA).