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A HazCom rule change has been announced that will affect labeling of all hazardous materials packages, according to a blog by Lion Technology Inc.
The entry, OSHA Lifts Prohibition on HCS & DOT Labels on Same Package, by Roger Marks, states that the new rule makes an important adjustment to new requirements OSHA adopted last year, known as the Globally Harmonized System (GHS) of classifying and labeling chemicals.
The rule in question pertains to DOT and HCS labels on the same package. The regulation (29 CFR 1910.1200, C.2.3.3) currently reads:
Where a pictogram required by the Department of Transportation under Title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in C.4 for the same hazard shall not appear.
"OSHA now plans to revise this rule to allow both a DOT and HCS pictogram for the same hazard to appear on a package, and will not enforce the current prohibition in the meantime," says Marks. "Because the U.S. DOT does not view Hazard Communication pictograms as conflicting with DOT labeling requirements; and because for some international shipments both pictograms may be needed, OSHA has decided to lift the prohibition at 1910.1200 C.2.3.3."
For its part, OSHA explains that "The diverse and sometimes conflicting national and international requirements can create confusion among those who seek to use hazard information effectively. For example, labels and safety data sheets may include symbols and hazard statements that are unfamiliar to readers or not well understood. Containers may be labeled with such a large volume of information that important statements are not easily recognized. Given the differences in hazard classification criteria, labels may also be incorrect when used in other countries. If countries around the world adopt the GHS, these problems will be minimized, and chemicals crossing borders will have consistent information, thus improving communication globally."
The planned change was announced in an OSHA Brief released last week. All employees must be trained on OSHA’s new GHS hazard communication standards by Dec. 1, 2013.
For the latest on the new HazCom requirements, and how the GHS rules will affect a facility’s hazard communication program, Lion’s Preparing for OSHA’s New GHS Rule Webinar, promises to be a great resource. Presented throughout 2013, the two hour webinar covers OSHA’s HazCom 2012 standard, how it affects facilities, and how to prepare. Registration includes access to the webinar, downloadable workbooks, and Certificate of Attendance.