Response: Yes. HCS 2012 requires the product identifier to be included on both the label and SDS. 29 CFR 1910.1200(f)(1) and (g)(2)(i). Appendix C, C.1, Allocation of Label Elements (Mandatory) of HCS 2012 requires the label to include the product identifier used on the safety data sheet. Appendix D to HCS 2012 requires the product identifier that is used on the label to be listed in Section 1 of the SDS. Product identifier is defined as the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS. 29 CFR 1910.1200(c).

Response: HCS 2012 requires the use of a product identifier, not a product code. If the product code(s) are being used as product identifier(s) on a label and SDS, then they must match. If product codes are being added to the label and SDS as supplemental information and the downstream user is still able to correctly cross-reference the labels and SDSs based on the product identifier, then product code(s) wouldn't necessarily have to match, as long as it does not lead to unnecessarily wide variation or undermine the required label and SDS information. Paragraph C.3.1 of Appendix C to the HCS 2012 states that the responsible party may provide additional information on a label when it provides further detail and does not contradict or cast doubt on the validity of the standardized hazard information. Similarly, the required elements listed in Appendix D for SDSs are the minimum information required and additional information that satisfies C.3.1 may be included in the SDS.

Response: Yes; see response to question 2.