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|Title: 10/06/2009 - Using the Globally Harmonized System (GHS) to Comply with OSHA's Hazard Communication Standard.|
|Record Type: Interpretation||Standard Number: 1910.1200, 1910.1200(f)|
Mr. Benjamin Garth Studebaker, CSP
Videojet Technologies, Inc.
1500 Mittel Boulevard
Wood Dale, IL 60191-1073
Dear Mr. Studebaker:
Thank you for your April 20, 2009, letter to the Occupational Safety and Health Administration. You had specific questions regarding the use of the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased scenario and questions are below, followed by our responses.
Scenario: Your company manufactures various ink products for industrial inkjet printers and some of these ink products are considered hazardous within the context of:
The HCS requires that labels contain the identity of the chemical; appropriate hazard warnings; and the name and addresses for the chemical manufacturer, importer, or other responsible party [29 CFR 1910.1200(f)(1)]. The identity of a chemical is the chemical name or common name that is also used on the material safety data sheet (MSDS), and a hazard warning means words, pictures, symbols, or a combination thereof which conveys the specific physical and health hazards, including the target organ effects [29 CFR 1010.1200(c)]. Manufacturers, importers, and distributors must ensure that containers of hazardous chemicals leaving their facilities have labels which contain these elements.
Classification schemes in the EU and other countries may be different from those in OSHA's HCS. These classification schemes may affect the information provided on both the safety data sheet and the label. However, as long as the EU GHS label contains the information required by the HCS, OSHA will consider the EU GHS label sufficient.
This safety wall poster from Safety Emporium uses humor to reinforce the importance of proper container labels.
Question 2: Would you take enforcement action under your current regulations against manufacturers, importers or distributors that market products that have been appropriately labeled according to EU GHS requirements?
Manufacturers, importers and distributors of hazardous chemicals are required to determine the hazards of the chemical(s) they produce or import and provide that information downstream to employers and employees through MSDSs and labels that comply with 29 CFR 1910.1200.
Richard E. Fairfax, Director
Directorate of Enforcement Programs