Monona Rossol, M=2ES=2E, M=2EF=2EA=2E, Industrial Hygienist

President:  Arts, Crafts & Theater Safety, Inc=2E

Safety Officer: Local USA829, IATSE

181 Thompson St=2E, #23

New York, NY 10012     212-777-0062

actsnyc**At_Symbol_Here**cs=2Ecom   www=2Eartscraftstheatersafety=2Eorg

Greetings All, 

Although the HazCom/GHS standard does not apply to students, I think there

is some room for 'thinking outside the box' so that we can meet the intent

of the standard and, thus, provide effective, safe communication to

students=2E 

First: 

        From (c) Definitions:  "Label elements" means the specified

pictogram, hazard statement, signal word and precautionary statement for

each hazard class and category=2E" 

Second:  

        From (f)(6) Workplace Labeling: "Except as provided in paragraphs

(f)(7) and (f)(8) of this section, the employer shall ensure that each

container of hazardous chemicals in the workplace is labeled, tagged or

marked with either: =2E=2E=2E

(ii) 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=2E" 

Third: 

        From (f)(7):  "(f)(7) The 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,=2E=2E=2E" 

So, a combination of identifying small containers with at least the name

of the material plus a number or color coded designation that is tied to a

poster/legend/handout that then provides the required labeling elements

for that material (and any other materials requiring the same elements)

may be the most practical and effective=2E  Although the standard refers to

using batch tickets, etc=2E for stationary containers, and not very small

containers, I think for our identified need this type of approach is worth

considering=2E  

We shouldn't miss the opportunity of integrating the hazardous

identification/communication piece into the lab session curriculum such

that students have to actively access and understand the information, as

confirmed by the lab write up or quizzes, etc=2E  

Also, smart phone access of QR squares, label scans, etc=2E,=2E that can bring

chemical hazard information to the user/student might be considered as

well=2E  

Best, 

Kevin 

Kevin Creed

Manager, ChemTracker Program

Stanford University

EH&S

480 Oak Road

Stanford, CA 94305-8007

office:  650-723-4767

cell:  408-529-0724 

-----Original Message-----

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED=2ECORNELL=2EEDU] On Behalf

Of Osterby, Meg

Sent: Sunday, November 17, 2013 8:18 AM

To: DCHAS-L**At_Symbol_Here**MED=2ECORNELL=2EEDU

Subject: Re: [DCHAS-L] GHS and secondary container labeling in acedemia

I also need a solution to this issue=2E  We are a small technical college

and have less than 100 total lab students spread between 3-5 courses each

semester=2E  We use 60 mL droppers for most lab solutions, since larger

amounts are far more than we would use in years=2E  Even so, our dropper

bottles are used multiple semesters=2E  We store them in wooden sleeves on

shelves in the stockroom=2E  In the past, we've labeled them with the

chemical name or formula and concentration only, since they are so small

there isn't room for much more=2E  How do we deal with the new labeling

requirements when there isn't physically room on the bottle for such a

detailed label?  Would putting the labels on the wooden sleeves be

sufficient?  (They don't go into the lab with the solutions, however, so

the students using the solutions would never see them=2E)  I don't see a

solution to this dilemma, since the bottle sizes are so small=2E

Meg Osterby

Lead Chemistry Instructor

Western Technical College

400 7th St=2E N=2E

LaCrosse, WI 54601

osterbym**At_Symbol_Here**westerntc=2Eedu

608-789-4714

"It's  better to be careful 100 times, than to be killed once=2E"  

                                                    Mark Twain

-----Original Message-----

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED=2ECORNELL=2EEDU] On Behalf

Of Marlyn Newhouse

Sent: Sunday, November 17, 2013 8:37 AM

To: DCHAS-L**At_Symbol_Here**MED=2ECORNELL=2EEDU

Subject: Re: [DCHAS-L] GHS and secondary container labeling in acedemia

Dear Ones,

We stopped using the smaller bottles and are using 100 mL bottles=2E  We

attach a test tube with a small pipette for the "dropper"=2E  The label and

test tube are secured with clear packing tape=2E

Blessings

 Marlyn Newhouse, D=2EA=2E

 Associate Professor of Chemistry

 1050 Union University Drive

 Jackson TN 38305

 731-661-5295

 mnewhous**At_Symbol_Here**uu=2Eedu

> 

________________________________________

From: DCHAS-L Discussion List [dchas-l**At_Symbol_Here**MED=2ECORNELL=2EEDU] On Behalf Of

Melissa Charlton-Smith [charltonsmith**At_Symbol_Here**WVWC=2EEDU]

Sent: Sunday, November 17, 2013 7:42 AM

To: DCHAS-L**At_Symbol_Here**MED=2ECORNELL=2EEDU

Subject: [DCHAS-L] GHS and secondary container labeling in acedemia

Out of curiosity, for those of you in academia, how are you handling GHS

secondary container labeling in teaching lab situations where the average

freshman student isn't exactly known for their attention to detail?  We

often have a multitude of small dropping bottles with 30 to 50 ml which

becomes a labeling nightmare because of lack of space for labels due to

the small size of the container=2E

Mel

Mel Charlton-Smith

School of Sciences Chemical Hygiene Officer-NRCC Lab Coordinator, Lecturer

BS-CHO program Department of Chemistry WV Wesleyan College Buckhannon, WV

26201

charltonsmith**At_Symbol_Here**wvwc=2Eedu<mailto:charltonsmith**At_Symbol_Here**wvwc=2Eedu>

304-473-8355