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Getting It Right: GHS Labels on Combination Packages

Posted on 12/31/2015 by Roger Marks

Now that OSHA’s adoption of the Globally Harmonized System for Classifying and Labeling Chemicals (GHS) is in full effect, facilities that ship hazardous chemicals in combination packages may be confused about the finer points of how new OSHA GHS hazard labels affect chemical shipments.

Take a popular form of combination packaging—bottles in a box. If a shipper packs six 1-liter bottles in a fiberboard box, should the shipper label the bottles inside the box, the outside of the box, or both?

Where to put GHS label on hazardous chemical in combination packaging

Per OSHA’s Hazard Communication Standard (HCS), manufacturers and distributors of hazardous chemicals must ensure that “each container of hazardous chemicals leaving the workplace is labeled, tagged, or marked.” [29 CFR 1910.1200(f)(1)]

The GHS labeling rules are meant to inform and protect employees in the workplace. To this end, it’s useful to think of a chemical “container” as the actual workplace container that end users (employees) will handle on the job. When you think of it this way, it’s clear that each bottle should be labeled separately. The individual who unpacks the shipment may not be the end user. If GHS labels appear only on the outer package—the box—the end user will not have access to this critical hazard information when handling the actual chemical container.

Six Required Elements of GHS HazCom Labels

There are six elements that must be included on a GHS hazard label. All GHS labels must include:
  • A product identifier (as used on the SDS);
  • The name, address, and telephone number of the chemical manufacturer, importer, or other responsible party;
  • A signal word;
  • Pictograms;
  • Hazard statements; and
  • Precautionary statements. [29 CFR 1910.1200(f)(1)]
This information must be on each container of hazardous chemicals, regardless of how those containers are packed and shipped. Though it’s not required, shippers may label the outer package (box, drum, pail) with GHS information as well.

GHS Labels for Very Small Containers

Very small containers raise their own unique challenges. With so much information required on the label, shippers may run out of real estate to display the information on very small vials or other containers. For guidance on labeling small chemical containers to satisfy OSHA’s HazCom Standard, read Small Containers a GHS Challenge for Chemical Industry.
GHS labels for very small chemical containers
OSHA does not provide any exemptions from labeling due to the size of the container under the HazCom Standard. For containers too small to display the entire GHS label in a print-on or stick-on format, OSHA recommends pull-outs, fold-backs, or tags. If none of those options are feasible, OSHA authorizes the use of abbreviated labels on the containers as long as a full label is attached to the outer packaging.

When the GHS Label Really Won’t Fit

When manufacturers and/or shippers can show that it is not feasible to use pull-out labels, fold-back labels, or tags, OSHA has granted the following practical accommodation. Note that OSHA does not consider an increase in cost an acceptable reason to use this accommodation.

The shipped small container (i.e., the actual container holding the hazardous chemical), at a minimum, must contain the following:
  • Product identifier
  • Appropriate pictogram(s)
  • Signal word
  • Manufacturer’s name and phone number
  • A statement indicating the full label information for the chemical is provided on the outside package.
The outside packaging, at a minimum, must comply with the following:
  • The outside packaging must contain all applicable label elementso   The outside packaging is the object (e.g., bag, box) that the immediate product container is placed into
  • The outside package must be clearly marked to ensure the complete label elements are visible, and it must clearly inform users that the small container must be stored in the outer container bearing the complete label
  • The complete label must be maintained on the outer package (e.g., not torn, defaced, destroyed)
  • The manufacturer must ensure that any alternative labeling used does not conflict with any other standards
More OSHA Guidance on GHS Labeling:

OSHA GHS Letter of Interpretation to the National Institute of Standards and Technology (NIST) (June 4, 2013)
OSHA GHS Letter of Interpretation to the Henkel Corporation (September 11, 2013)
OSHA GHS Letter of Interpretation to the US Pharmacopeial Convention (September 20, 2013)

Cut Through the GHS Confusion
Don’t risk a citation during your next OSHA inspection because of confusion about these new GHS labeling rules.  Whether you ship hazardous chemicals or manage your facility’s safety program, a firm grasp of these new hazard communication rules is crucial to ongoing compliance.  For interactive GHS training you can complete on your own schedule, see the Managing Hazard Communication Online Course.  

For chemical shippers, Lion instructors will present the live, two-hour webinar GHS Compliance for Hazmat Shippers next on February 4 and throughout 2016. 

Tags: GHS, hazmat shipping, osha

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