Chemical Labels
Hazardous chemicals are required to be labeled with “appropriate hazard warnings” under Hazard Communication standard (29CFR1910.1200). Hazard warning is defined as “any words, pictures, symbols, or combination thereof appearing on a label or other appropriate form of warning which convey the specific physical and health hazard(s), including target organ effects, of the chemical(s) in the container(s).” This definition has caused many to question if the two most popular methods of secondary container labeling, the HMIS and NFPA labeling systems, meet the requirements.
The HMIS and NFPA systems were designed to provide quick, visual general hazard information. The definition of hazard warning requires specific information, including target organ effects. To provide appropriate hazard warning, some additional information should be on containers than just the standard HMIS or NFPA markings, but often times it is as simple as adding target organ information. If employees understand the color and number scheme of NFPA or HMIS, adding verbiage about target organ effects will meet regulatory requirements (before GHS enactment).
Target organ verbiage can be obtained from MSDS or manufacturer container labels. That verbiage can usually be easily added to an open area on the bottom portion of HMIS or NFPA pre-printed labels. Target organ effects need to be included in employee training to fully close the loop and ensure hazard “communication” is effective.
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