2.4 Workplace labeling: the labels you apply

1 The rule, and the two ways to satisfy it

Paragraph (f)(6): except as provided in (f)(7) and (f)(8), the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either:

1. 1
   (f)(6)(i) — the information specified under (f)(1)(i) through (v) for labels on shipped containers: product identifier, signal word, hazard statements, pictograms and precautionary statements. In other words, a copy of the supplier label.
2. 2
   (f)(6)(ii) — the product identifier and words, pictures, symbols, or a 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.

The second option is the workhorse, and its final clause is the one people miss. A short in-house tag is legal because the rest of the program is reachable — the list, the sheets, the training. Take away the reachable sheet and the tag no longer satisfies (f)(6)(ii), because it can no longer combine with anything.

Both options require the product identifier. There is no version of a workplace label that omits it, because it is the link back to the sheet.

2 The two exceptions

Stationary process containers — (f)(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, on two conditions: the alternative method identifies the containers to which it applies, and it conveys the information required by (f)(6) to be on a label. The employer shall ensure the written materials are readily accessible to employees in their work area throughout each work shift.

Immediate use — (f)(8). The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. Both halves are conditions. Transfer from a labeled container, and immediate use by the person who did the transferring.

The moment the bottle is set down for the next shift, handed to a colleague, or left on the bench overnight, the exception has ended and (f)(6) applies. Nothing about the container changed; the use did.

3 Do not deface the label that arrived

Paragraph (f)(9): the employer shall not remove or deface existing labels on incoming containers of hazardous chemicals, unless the container is immediately marked with the required information.

This gets cited more often than it should, and usually for good intentions: a drum comes in with a torn or dirty label, and someone tidies it up by peeling it off and writing the product name on the side with a marker. What has just been lost is the signal word, the hazard statements, the pictograms, the precautionary statements and the supplier's phone number. The product name alone is not the required information.

Paragraph (f)(10) sets the quality bar for what you do put on: the employer shall ensure that workplace labels or other forms of warning are legible, in English, and prominently displayed on the container, or readily available in the work area throughout each work shift. The same paragraph permits the information to be presented in other languages as well — in addition to English, not instead of it.

4 Where NFPA 704 and HMIS fit

Many American workplaces run a numeric rating system alongside GHS: the NFPA 704 diamond on a building or tank, or an HMIS bar on a container. Neither is an OSHA labeling system, and neither is prohibited.

The way to think about it is (f)(6)(ii). A numeric system can form part of a workplace labeling scheme where it is combined with a product identifier and with the rest of the program, and where employees have been trained on what the numbers mean — which is exactly what (h)(3)(iv) requires when it asks training to explain the workplace labeling system used by their employer. What a numeric system cannot do is satisfy (f)(1) on a container leaving your workplace, because a shipped container needs the six GHS elements.

There is also a genuine trap in mixing them: the numbers run in opposite directions. In NFPA 704 and HMIS, 4 is the most severe and 0 the least. In GHS, Category 1 is the most severe. A worker who learned the diamond and then meets “Flammable liquid, Category 1” on a safety data sheet will read it as mild unless somebody tells them otherwise. This belongs in your training, explicitly.

5 Designing a workplace labeling system that survives

Three practical decisions make the difference between a system that holds and one that decays into masking tape.

Decide the format once and put it in the written program. Paragraph (e)(1) asks you to describe how the (f) criteria will be met. “Secondary containers carry a printed tag with the product identifier and the supplier's pictograms” is a format. Write down where the blank tags live and who prints them.

Put the supply where the decanting happens. Labels do not get applied because the printer is in the office and the drum is in the yard. A roll of pre-printed tags in the paint locker changes behavior more than a policy does.

Make the check part of an existing walk. A weekly foreman's walk that includes “every container has an identifier” catches drift while it is one bottle, not fifty.

6 Multi-employer sites: your tags, someone else's crew

A workplace labeling system only works for people who have been told what it means. On a site with four trades, three of them have never seen your tags.

That is why paragraph (e)(2)(iii) requires the written program of an employer whose chemicals may expose other employers' employees to include the methods the employer will use to inform the other employers of the labeling system used in the workplace — alongside (e)(2)(i) on safety data sheet access and (e)(2)(ii) on precautionary measures.

In practice this is a paragraph in the site orientation and a line in the subcontractor pre-mobilization pack. It costs nothing and it is the difference between a visiting mechanic reading your yellow tag correctly and guessing.