From: "Shoshenskiy, Nicole" <nshoshenskiy**At_Symbol_Here**MSDSONLINE.COM>
Subject: Re: [DCHAS-L] GHS and NFPA query
Date: Fri, 17 Oct 2014 17:57:28 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: C14222A5D2E37D4F88C6E6DF3465DB9D7D88DF35**At_Symbol_Here**

The feedback I was given by OSHA at this fall’s Society for Chemical Hazard Communication conference on this subject is that OSHA will not prohibit you from including more information on the label than is prescribed under GHS, however, they do not recommend placing NFPA or HMIS labels near the GHS label as the numbering system for hazard severity is conflicting.  Under GHS a category 1 is the most dangerous whereas under NFPA or HMIS a rating of 1 is the least dangerous. 


This is from the OSHA guidance available at their website:


Q. How will workplace labeling provisions be changing under the revised Hazard Communication Standard?

A. The current standard provides employers with flexibility regarding the type of system to be used in their workplaces and OSHA has retained that flexibility in the revised Hazard Communication Standard (HCS). Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, 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 Identification System (HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms.


Nicole Shoshenskiy
Authoring Team Lead

350 North Orleans Street, Suite 950

Chicago, IL 60654
Direct: 1.312.881.

Fax: 1.312.881.2001



From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Eileen Mason
Sent: Friday, October 17, 2014 12:24 PM
Subject: Re: [DCHAS-L] GHS and NFPA query


Hazard Communication has always required labeling, but has never required NFPA labeling, or HMIS labeling. Until GHS was implemented, the format of the labeling was left to the employer. 


Regional or local authorities might require NFPA labels, or the HazMat organization might require them,  but OSHA does not.. 


On Fri, Oct 17, 2014 at 10:13 AM, George D. McCallion <medchem**At_Symbol_Here**> wrote:

Dear DCHAS members,

It seems that from the attached OSHA HazComm info,

The NFPA labeling might no longer be required. From a Hazardous Materials Technician level (completing this in Oct.) I would use that placard as fist line if identification. Any ideas as to why it might not be required?


Thank you in advance.






George D. McCallion
124 Magnolia Court
Collegeville, PA 19426


Voice: 610.888.2436
Email: medchem**At_Symbol_Here**



Previous post   |  Top of Page   |   Next post

The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.