OSHA Publishes Brief on Labels and Pictograms under the 2012 GHS HCS

OSHA has published OSHA BRIEF DSG BR-3636 2/2012 on the Hazard Communication Standard: Labels and Pictograms. The brief clarifies aspects of labeling under the 2012 Hazard Communication Standard (HCS) which adopts the principles of the United Nations (UN) Globally Harmonized System of classification and labeling of chemicals (GHS).

The brief offers good examples of how a GHS label for chemical products in the USA should be designed, and clarifies some aspects of labeling, especially in the workplace and for samples.

Most importantly, the brief promises that enforcement of provisions in Appendix C.2.3.3 prohibiting the use of GHS pictograms that correspond to the DOT transport pictogram on a single container. The corresponding pictograms for transport and GHS have the same "symbol" -- the image at the center of the square-on-point frame -- and appy based on the same hazard classification. An excerpt from the OSHA brief:


If a label has a DOT transport pictogram, Appendix C.2.3.3 states that the corresponding HCS pictogram shall not appear. However, DOT does not view the HCS pictogram as a conflict and for some international trade both pictograms may need to be present on the label. Therefore, OSHA intends to revise C.2.3.3. In the meantime, the agency will allow both DOT and HCS pictograms for the same hazard on a label.