2.1 The six elements of a shipped label
A shipped container label is the only piece of hazard information that travels physically attached to the product. It has to work for a receiving clerk who will never open the safety data sheet, and for a worker who picks up the can six months later. Paragraph (f) fixes exactly what it carries, in what language, and how quickly it has to change when the science does.
1 The six elements
Paragraph (f)(1) requires the chemical manufacturer, importer or distributor to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked. Where a label is required, six things shall be provided:
In the words of the standard, (f)(1)(i) through (vi): product identifier; signal word; hazard statement(s); pictogram(s); precautionary statement(s); and name, U.S. address, and U.S. telephone number of the chemical manufacturer, importer, or other responsible party. The word U.S. appears twice and is deliberate — an imported product cannot satisfy this with a foreign address and phone number alone.
The same paragraph carves two things out of the label: hazards not otherwise classified, and hazards identified and classified under (d)(1)(ii) — the reaction products associated with known or reasonably anticipated uses — do not have to be addressed on the container. They stay on the safety data sheet. Reading only the label loses them, which is why Part 3 exists.
2 Layout rules: together, prominent, in English
Two short paragraphs govern the physical arrangement, and both get cited.
Paragraph (f)(2): the information provided under (f)(1)(i) through (v) must be in accordance with Appendix C, for each hazard class and associated hazard category, prominently displayed, and in English. Other languages may also be included if appropriate — added, not substituted.
Paragraph (f)(3): the information provided under (f)(1)(ii) through (iv) — signal word, hazard statements and pictograms — shall be located together on the label, tag or mark. That is the rule that makes a GHS label recognizable at arm's length. Three of the six elements form a block, so a person can read severity, effect and symbol in one glance without hunting around a drum.
3 Solid materials and bulk shipments
Two categories of product do not lend themselves to a sticker, and the standard handles both.
Solid materials — (f)(4). For solid metal such as a steel beam or a metal casting, solid wood, or plastic items not exempted as articles due to their downstream use, or shipments of whole grain, the required label may be transmitted to the customer at the time of the initial shipment, and need not be included with subsequent shipments to the same employer unless the label information changes. It may travel with the shipment itself or with the safety data sheet provided at or before the first shipment. Paragraph (f)(4)(iii) then limits the concession: this exception is only for the solid material itself, and does not apply to hazardous chemicals used in conjunction with, or known to be present with, the material — the standard's own examples are cutting fluids and pesticides in grains.
Bulk shipments — (f)(5)(ii). A bulk shipment is defined in paragraph (c) as any hazardous chemical transported where the mode of transportation comprises the immediate container: a tanker truck, a rail car, an intermodal container. The label for such a shipment must be on the immediate container, transmitted with the shipping papers or bills of lading, or — with the agreement of the receiving entity — transmitted electronically so that it is immediately available to workers in printed form at the receiving end. Note the two conditions on the electronic route: agreement, and immediate availability in printed form.
4 DOT placards and HazCom labels living together
Paragraph (f)(5)(i) requires shipped-container labeling to be done in a manner which does not conflict with the Hazardous Materials Transportation Act and the Department of Transportation regulations in 49 CFR subtitle B. The two systems overlap on the outside of a drum, and the standard resolves the collision at (f)(5)(iii): where a pictogram required by DOT under title 49 appears on a shipped container, the corresponding HazCom pictogram for the same hazard shall not appear.
The practical result is a container that carries a DOT flame diamond and no HazCom flame pictogram, and the crew has to know that the absence of the red-bordered diamond is not the absence of the hazard. It is one of the more confusing things a receiving clerk sees, and it is exactly the sort of thing (h)(3)(iv) means when it asks training to explain the labels received on shipped containers.
| System | Purpose | Where it applies | Rule when they meet |
|---|---|---|---|
| DOT, 49 CFR subtitle B | Protecting people during transport | Outside of the container in commerce | Takes the space |
| HazCom, 1910.1200(f) | Protecting people using the chemical | Container leaving the workplace, and in the workplace | Its pictogram for the same hazard is omitted — (f)(5)(iii) |
5 When a label has to change: six months
Paragraph (f)(11) is the update clock, and it is a different number from the one on safety data sheets. Manufacturers, importers, distributors or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels within six months of becoming aware, and ensure that labels on containers shipped after that time carry the new information.
For product already released for shipment and waiting in a warehouse, there is a choice: relabel, or do not relabel and instead provide the updated label for each individual container with each shipment. And if the chemical is not currently produced or imported, the information is added to the label before the chemical is introduced into the workplace again.
Hold that six-month figure next to the sheet figure you will meet in Part 3: safety data sheets get updated within three months under (g)(5). The sheet moves first, the label follows. That is not an inconsistency; it reflects the fact that reprinting labels and reworking stock takes longer than reissuing a document.
6 What a good receiving check looks like
Everything in this chapter collapses into a thirty-second routine at the dock, and it is worth writing into the program under (e)(1) as the method for meeting the (f) criteria.
- 1Is there a label at all, and is it legible and in English?
- 2Are the six elements there — identifier, signal word, hazard statements, pictograms, precautionary statements, U.S. supplier name, address and phone?
- 3Are the signal word, hazard statements and pictograms together in one block?
- 4Did a safety data sheet arrive with it, or has one arrived before? If not, request it — (g)(6)(iii) makes obtaining one the receiver's move.
- 5Does the product identifier on the label match the one on the sheet, and is that identifier on the chemical list?
A product that fails step 5 is the one that will be unfindable in six months, when someone is standing over a spill trying to work out what they are looking at.
- Six elements on a shipped label, including a U.S. address and U.S. telephone number for the responsible party.
- Signal word, hazard statements and pictograms must be located together; everything must be prominent and in English.
- Hazards not otherwise classified are kept off the label on purpose and stay on the safety data sheet.
- Solid materials may be labeled once at initial shipment; bulk shipments may be labeled on paperwork or electronically by agreement.
- Where a DOT pictogram appears for a hazard, the HazCom pictogram for that same hazard is omitted.
- Labels are revised within six months of significant new information; safety data sheets within three.
Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.