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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)|
ILPI Notes: This interpretation is based on and references the HCS 1994 which is now obsolete. While some parts have been deleted or changed, the conclusions of this interpretation appear consistent with the current regulation which now follows the GHS labeling practices discussed below.
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 [in context: HCS 1994 | current regulation: HCS 2012 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) [in context: HCS 1994 | current regulation: HCS 2012]. 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 1910.1200(c)]. Manufacturers, importers, and distributors must ensure that containers of hazardous chemicals leaving their facilities have labels which contain these elements. [Note: HCS 2012 has additional specific requirements including pictograms, hazard statements and precautionary statements]
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.
OSHA is proposing to amend the HCS [in context: HCS 1994 | current regulation: HCS 2012] to incorporate the GHS. If these changes are ultimately adopted [they were], then EU GHS labels should generally meet the requirements of the HCS.
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 [in context: HCS 1994 | current regulation: HCS 2012] .
Richard E. Fairfax, Director
Directorate of Enforcement Programs
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27218&p_text_version=FALSE