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OSHA Lifts Prohibition on HCS & DOT Labels on Same Package

Posted on 3/19/2013 by Roger Marks

A HazCom rule change has been announced that will affect labeling of all hazardous materials packages.  The new rule makes an important adjustment to new requirements OSHA adopted last year, known as the Globally Harmonized System (GHS) of classifying and labeling chemicals.
 
The rule in question pertains to DOT and HCS labels on the same package. The regulation (29 CFR 1910.1200, C.2.3.3) currently reads:
 
“Where a pictogram required by the Department of Transportation under Title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in C.4 for the same hazard shall not appear.”
 
OSHA now plans to revise this rule to allow both a DOT and HCS pictogram for the same hazard to appear on a package, and will not enforce the current prohibition in the meantime. Because the U.S. DOT does not view Hazard Communication pictograms as conflicting with DOT labeling requirements; and because for some international shipments both pictograms may be needed, OSHA has decided to lift the prohibition at 1910.1200 C.2.3.3.
 
The planned change was announced in an OSHA Brief released last week. You can view the full brief here.
 
 

Tags: GHS, HazCom, marks and labels, new rules, osha

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