The hazard communication system (HCS) regulations are covered in 29CFR1910.1200. Subsection (f) provides requirements for labels and other forms of warning. The first requirement applies to shipped containers, which is another way of saying it applies to every chemical that enters your facility in a container (spray can, lidded can, bottle, etc.). Each individual container must have a label, tag, or marking that says what’s inside the container [1920.1200(f)(1)]. That label, tag, or marking must provide the following information:
- Product identifier
- Signal word
- Hazard statement(s)
- Pictogram(s)
- Precautionary statement(s)
- Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.
This information must comply with Appendix C of 1910.1200, which is titled “Allocation of Label Elements (Mandatory).” In addition to other requirements, it contains 30 examples of what OSHA wants to see for “signal words, hazard statements, pictograms, and precautionary statements” depending upon how the particular chemical is classified per Appendix A-1. This is a lot to sort through, but if you purchase your chemicals from a reputable source this work is done for you. Something you’ll notice on these examples is all of the information is located together on the label, tag, or mark. That’s required by 1910.1200(f)(3).
If any of this is missing, either add the missing information to the container, remove it from your facility [1910.1200(f)(6)], or use an approved alternative to labeling per 1910.1200(f)(7). For example, you can put the information in your maintenance procedures.
There is an exception to the “every container” rule. It applies to solid materials such as metal beams that, due to their downstream use, aren’t exempted as articles. For electrical work, there generally is not anything that falls under this exception. Your concern is probably with solvents, adhesives, lubricants, and coatings (including paints).
The labeling requirement does not apply to “job use” containers, for example a small can into which an employee pours an adhesive for use on a specific job [1910.1200(f)(8)]. But make sure employees understand how properly dispose of such containers when done using them.
