When OSHA revised its Hazard Communication Standard to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) in 2012, the worlds of hazardous materials shipping and workplace safety collided. Starting June 1, 2015, shippers must comply with the new classification, labeling, and documentation standards of OSHA's revised HazCom Standard. Many suppliers already use the new GHS labels, and overlapping DOT and OSHA hazard communication labeling standards have caused confusion for shippers at best and shipping delays at worst, especially for air shipments. GHS and DOT Labels on the Same Package
In some cases, the workplace container that holds a hazardous chemical will also be the package in which the material is shipped (e.g., a 5-gallon 1A1 drum containing a flammable liquid paint thinner). Because this material is subject to both OSHA workplace hazard communication requirements and US DOT's Hazardous Materials Regulations (HMR), both GHS HazCom and DOT hazmat labels and pictograms may be present. GHS Labels on Non-hazmat Shipments
There are situations in which a package that requires OSHA GHS labels does not require hazmat shipping labels. In these situations, the GHS labels may cause confusion, raise questions from freight forwarders or carriers, and even delay the shipment.
For example, GHS includes a health hazard class for "Serious Eye Damage/Eye Irritation" [GHS, Chapter 3.3]. Materials in Category 1 of this GHS hazard class require labels with the "corrosion" pictogram. However, unless the material also meets the 49 CFR or IATA DGR definition of a corrosive material (i.e., it can destroy skin tissue or metal), then no hazmat shipping label is required. IATA's 56th Edition Dangerous Goods Regulations (IATA DGR) addresses this issue with a new note in the regulation for hidden dangerous goods in Section 2.
"Diamond-shaped GHS pictograms on packages may indicate the presence of dangerous goods. While some pictograms identify substances that only pose a hazard for supply and use, other GHS pictograms contain symbols that are largely equivalent to the symbols contained in the hazard labels used in transport, and which may therefore be classified as dangerous goods." [Note to IATA DGR 2.2.2]
If you are shipping a material that is not regulated by the IATA DGR (or other hazmat regulation), but does require GHS labeling, taking the following measures can minimize potential delays:
- Contact your carriers in advance. Provide information that they may need to ensure your classification is correct and complete.
- Include a statement on your shipping paperwork that indicates the material is not regulated under the hazmat shipping requirements.
- Include a marking on the package indicating that the material is not subject to the hazmat shipping requirements.
By discussing your products with your carriers prior to shipment, you can minimize delays during transportation. Prepare for the June 1 Deadline
Gain clarity about the relationship between GHS requirements and 49 CFR hazmat labeling standards and be prepared before the June 1 deadline. Join the next session of the live, instructor-led GHS Compliance for Hazmat Shippers Webinar
on March 17 from 1 to 3 PM ET. The webinar will help you get ready to conquer the challenges hazmat shippers face now that OSHA's new GHS rules are imminent. Don't let hazard labeling delay your shipments, confuse your supply-chain partners, or subject you to DOT or OSHA civil penalties-sign up now.