2.3 Signal words, hazard statements, precautionary statements

1 Two signal words, and only two

Appendix C uses exactly two signal words: Danger and Warning. Danger is the more severe. Paragraph C.2.1.1 settles what happens when a product's classifications would call for both: if the signal word “Danger” is included, the signal word “Warning” shall not appear.

So a label carries one signal word, and it reflects the most severe classification the product has. A can marked Danger may also be mildly irritating; the Warning that irritation would have generated is suppressed.

Caution is not a GHS signal word. It belongs to older American labeling conventions and to consumer product law, and workers who learned on those systems read it as a third, milder level. Under 1910.1200 there is no third level. That is a training point worth making explicitly, because a label that says Caution is either not a HazCom label or is defective.

2 Hazard statements: what it does

A hazard statement describes the nature of the hazard, and its wording is assigned by the classification — not written by the supplier. Paragraph C.2.2.1: the text of all applicable hazard statements shall appear on the label, except as otherwise specified.

Two conventions matter when you read one. First, italics: C.2.2.1 states that information in italics shall be included as part of the hazard statement as provided, and gives the example “causes damage to organs (state all organs affected) through prolonged or repeated exposure (state route of exposure if no other routes of exposure cause the hazard)”. That parenthetical is an instruction to the supplier to fill in specifics — a finished label should name the organ, not print the instruction.

Second, combining: the same paragraph allows hazard statements to be combined where appropriate to reduce information on the label and improve readability, as long as all of the hazards are conveyed as required. So a shorter statement list is not necessarily a shorter hazard list.

Paragraph C.2.2.2 adds the only permitted omission: if the manufacturer, importer or responsible party can demonstrate that all or part of a hazard statement is inappropriate to a specific substance or mixture, the corresponding statement may be omitted. The burden sits with them, not with you.

3 Precautionary statements: what you do about it

Paragraph C.2.4.1 sets out four types of precautionary statement, and knowing the four turns a wall of text into four answerable questions.

C.2.4.1 also explains the typography: the core part of the precautionary statement is presented in bold print in the appendix, and that is the text which shall appear on the label; where additional information is required, it is indicated in plain text.

4 Four punctuation conventions that change the meaning

Appendix C uses four typographic devices, and each one means something specific. They appear in the appendix text and sometimes survive onto a poorly finished label, where they confuse people.

1. 1
   A slash (/) means choose. C.2.4.2: when a backslash or diagonal mark appears, a choice has to be made between the separated phrases. “Wear protective gloves/protective clothing/eye protection/face protection” could correctly read, on a finished label, “wear eye protection”.
2. 2
   Three full stops (. . .) mean the list is not complete. C.2.4.3: in “Use explosion-proof electrical/ventilating/lighting/. . ./equipment”, the ellipsis indicates other equipment may need to be specified, and the responsible party chooses.
3. 3
   Italics are a condition, not label text. C.2.4.4: italic text indicates specific conditions applying to the use or allocation of the statement — for example, explosion-proof equipment is required for flammable solids only if dust clouds can occur. It is explanatory and is not intended to appear on the label.
4. 4
   Square brackets mean sometimes. C.2.4.5: text in square brackets is not appropriate in every case and is used only in certain circumstances, with the conditions for use stated in the appendix — the worked example being “[In case of inadequate ventilation] wear respiratory protection.”

5 The product identifier and the supplier block

Two elements sit outside the signal word block and are easy to overlook.

Paragraph C.1: the label for each hazardous chemical shall include the product identifier used on the safety data sheet. That single sentence is why your chemical list can work at all — label, sheet and list all pivot on the same string of text. C.1.1 adds that labels on shipped containers shall also include the name, address and telephone number of the chemical manufacturer, importer or responsible party.

In practice the product identifier is where audits break down. A supplier's marketing name on the front of the can is not necessarily the identifier in section 1 of the sheet. When they differ, the sheet's identifier is the one that belongs on your list — and writing the marketing name on the list is how a sheet becomes unfindable at the moment somebody needs it.

6 Reading a whole label in ten seconds

Put the pieces together and there is a reliable order of reading, which is worth teaching as a habit.

Signal word tells you how bad. Pictograms tell you what kind, at a glance and across languages. Hazard statements tell you exactly what it does, including the things the pictogram cannot distinguish. Precautionary statements tell you what to do — and the four types answer prevention, response, storage and disposal in that order. Product identifier is the key to the sheet and the list. Supplier block is who to phone at 2 a.m.

Everything else — exposure limits, incompatible materials, glove breakthrough times, what the fire department needs to know — is on the safety data sheet, which is where Part 3 goes next.