Proper
labeling of hazardous chemical and waste is extremely
important to reduce exposure, prevent accidents and extra
disposal costs:.
OSHA’s Hazard Communications Program (HazCom) (link) covers
the labeling of hazardous chemicals in use. Once the chemical
becomes a hazardous waste, a different set of labeling rules apply under EPA’s RCRA
program (provide link). To add to the challenge of labeling
all hazardous materials, to prepare hazardous waste for shipment, another set of rules apply under the Department
of Transportation (DOT) (provide link).
HazCom requires that all containers of
hazardous chemicals must be labeled, tagged, or marked with
the identity of the material
and appropriate hazard warnings. Chemical manufacturers,
importers, and distributors must ensure that every container
of hazardous chemicals they ship is appropriately labeled with
such information and with the name and address of the producer
or other responsible party.
The primary information to be obtained
from an OSHA-required label is the identity for the material
and appropriate hazard
warnings. The identity is any term which appears on the
label, the MSDS, and the list of chemicals, and thus links these
three sources of information. The identity used by the
supplier may be a common or trade name ("Black Magic Floor
Cleaner"), or a chemical name (1, 1, 1 - trichloroethane). The
hazard warning is a brief statement of the hazardous effects
of the chemical ("flammable," "causes lung damage"). Labels
frequently contain other information, such as precautionary measures
("do not use near open flame") but this information
is provided voluntarily and is not required by the rule.
Labels must be legible and prominently
displayed. There
are no specific requirements for size or color or any specified
test.
Proper labeling is extremely important to prevent accidents
and extra disposal costs
- Ensure proper labeling of all incoming materials as they
are received (Include product name, weight, concentration,
lot number, date, hazard class and any other information useful
in tracking material location, quality, age or use.)
- Always label hazardous waste at its point of generation where
it can still be easily identified (Testing later to determine
the contents is expensive.)
- Label all areas in the plant, including
stationary tanks, pipelines, etc. containing hazardous
materials or wastes
- If a chemical was in a labeled container and is subsequently
transferred to another container, the employer must label the
new container.
- Shelving where the chemical is stored
may be labeled with additional labeling if when the chemical
is removed from the
labeled shelf, it will be used in its entirety. If not, it
will require an additional label.
Specifically, HazCom requires the following types of information
to ensure that labeling is properly implemented in your facility:
- Designation of person(s) responsible for labeling system
implemented throughout the facility;
- Designation of person(s) responsible for ensuring labeling
of all containers in each department/area;
- Designation of person(s) responsible for ensuring re-labeling
of hazardous waste or to prepare waste for shipping
- Description of labeling system(s) used and comprehensive
training program;
- Description of written alternatives to labeling of containers
(if used); and,
- Procedures to review and update label information when necessary.
