In April, we advised of the upcoming GHS labeling changes outlined below. As explained in the original Exhibit B, if the outer package carried the corrosive label, the pictogram was not to be included on the label. Feedback from the manufacturing community deemed this to be confusing, so OSHA and the DOT have agreed that ALL labels can display the pictogram. The label examples on the attached are still compliant, but to avoid confusion, all CSI products manufactured as of October 23, will have the pictogram on the product label (as Exhibit A).
Effective December 1st – Do Not ship product unless the label is GHS compliant (Exhibit A-C). Please review your inventories to insure that all of the product with the old labels is shipped prior to this date.
In 2003, the United Nations adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This worldwide system promotes standardized formats for chemical communications. OSHA has revised its Hazard Communication Standard to convert all requirements to be compliant with the GHS. As part of this initiative, in 2012 the MSDS were re-formatted into the current SDS. All employers should be familiar with the new OSHA standard and have their employees trained to understand the new label and SDS formats.
This year, the guidelines regarding the labeling of chemicals will go into effect. The current deadlines for the new labeling will become effective in two stages:
June 1, 2015 – Manufacturers must follow new label requirements.
December 1, 2015 – Distributors must follow new label requirements and must NOT ship products unless they have GHS compliant labels.
CSI has been proactive and all products manufactured after March 20th will be labeled in accordance with the GHS requirements. An example of the previous and new label formats are below for your review:
Exhibit A is the bottle or inner package label for corrosive
Exhibit B is the outer package label for corrosive
Exhibit C is the non-corrosive label.
The pictogram is a new element and will be an easy way to quickly identify the new label format for all non-corrosive products. However, since the DOT already requires a pictogram to be on the hazard label on the outer container of corrosive products, it is not allowed to be duplicated on the product label. The signal word (ex: Danger) does appear on the product label for the corrosive products.
Rotating inventory is always important and this new deadline of December 1st makes it even more critical. Please make sure that all products with the old label format are shipped to customers prior to the December 1st deadline.
More detailed information on GHS can be found at www.osha.gov/dsg/hazcom/ghs.html.