Topic: Labeling: Requirements for Secondary/Workplace Containers under 2012 Revised Standard
Question: Are employers required to include the new revised GHS label elements (e.g. pictograms) on secondary containers?
Answer:No. The requirements for labeling secondary (workplace) containers under the revised 2012 MIOSHA Part 42, 92 and 430 Hazard Communication Standard (HCS) are as follows.
All of the words that appear in BOLD text and with larger font have been embellished for emphasis.
(6) Workplace labeling. Except as provided in paragraphs (f)(7) and (f)(8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either:
(i) The information specified under paragraphs (f)(1)(i) through (v) of this section for labels on shipped containers[Product identifier; Signal word; Hazard statement(s); Pictogram(s); Precautionary statement(s); and,
Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.]; or,
(ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.
(7) The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(6) of this section to be on a label. The employer shall ensure the written materials are readily accessible to the employees in their work area throughout each work shift.
The excerpt (6)(ii) and (7) above means that the employer can continue to use the secondary container labeling program they have instituted within their facility that meets the requirement (e.g. Hazardous Materials Identification System/HMIS or National Fire Protection Association/NFPA or other label system…with supplemental “product identifier”) without any change as long as that system meets the requirements of the “OR” provisions stated above.
The bottom line is that the employees must know the hazards associated with the chemical and that information must be represented on any label that is required by the MIOSHA Hazard Communication Standard to be placed on the container of hazardous chemicals.
Applicable Construction Safety Standard/Rule: Part 42. Hazard Communication, 1910.1200(e)
Applicable General Industry Safety Standard/Rule: Part 92. Hazard Communication, 1910-1200(e)
Applicable Occupational Health Standard/Rule: Part 430. Hazard Communication, 1910.1200(e)
Additional Resources: For complimentary MIOSHA consultation please contact our office at (517) 284-7720 or submit a Request for Consultative Assistance (RCA).
Date Posted: March 11, 2013 /