OSHA has had a long-standing policy allowing flexibility in labeling bulk shipments where the immediate container is the mode of transportation (i.e., in a tanker truck, rail car, or intermodal container). In this case, OSHA will permit the label to be on the immediate container, transmitted with shipping papers, bills of lading, or transmitted by other technological or electronic means so that it is readily available to workers in printed form at the receiving end of the shipment. In this final rule, OSHA has codified this long-standing accommodation.
Changes to Label Elements
In this final OSHA rule, in addition to adding the elements for the newly identified hazard investor database classes such as desensitized explosives and chemicals under pressure, OSHA has made several changes to the instructions for how to apply the label elements.
OSHA has indicated that the same pictogram may not appear on the label multiple times. This means that even if a specific pictogram is triggered by multiple hazards, it should only appear on the label once.
Guidance on how the label preparer can combine multiple precautionary statements related to medical response.
Updated precautionary statements to align with GHS Revision 7. These changes were made to improve the applicability of the hazard statements by updating the phrases or the conditions for when the statements should be applied.
The required label elements were updated to specify that the address and telephone number of the responsible party on the label must include a U.S. address and a U.S. telephone number. Finally, OSHA did not adopt the proposed requirement to include the “release date for shipment” on the label.
For more details on what is included in the Hazard Communication Standard, see the OSHA Hazard Communication Standard pdf .
Do you have questions? Send your questions to our SDS team at [email protected] by June 21st to be answered in a follow-up blog post.
Please note: These are the author’s opinions and should not be taken as an interpretation of OSHA and do not constitute legal advice. Readers should consult a qualified attorney for advice on a specific legal issue. The information provided is based on the author’s understanding of the regulation at the time of writing. The primary purpose of this blog is to inform readers about the published Hazard Communication Standard. To stay up-to-date with OSHA’s latest updates on the HCS final rule, follow CHEMTREC on social media: Facebook | X | LinkedIn
