Search

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

Find a Post

Recent Posts

Compliance Topics

Compliance Archives

Lion - Quotes

Lion was very responsive to my initial questions and the website was user friendly.

Michael Britt

Supply Chain Director

The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.

Marc Bugg

Hazardous Waste Professional

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow.

Steven Erlandson

Environmental Coordinator

I love that the instructor emphasized the thought process behind the regs.

Rebecca Saxena

Corporate Product Stewardship Specialist

Amazing instructor; real-life examples. Lion training gets better every year!

Frank Papandrea

Environmental Manager

These are the best classes I attend each year. I always take something away and implement improvements at my sites.

Kim Racine

EH&S Manager

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!

Lori Hardy

Process & Resource Administrator

This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things.

Quatama Jackson

Waste Management Professional

Download Our Latest Whitepaper

Ace hazmat inspections. Protect personnel. Defend against civil and criminal penalties. How? See the self-audit "best practices" for hazardous materials shippers.

Download
Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.