Search

How GHS Labels Will Affect Chemical Shipments

Posted on 2/17/2015 by Scott Dunsmore

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.
DOT Hazmat and OSHA GHS Hazcom Labels

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.


Tags: DOT, GHS, HazCom, hazmat shipping, IATA

Find a Post

Compliance Archives

Lion - Quotes

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past.

Neil Ozonur

Safety Officer

Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right.

Gregory Thompson

Environmental, Health & Safety Regional Manager

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!

Brian Martinez

Warehouse Operator

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

Michael Britt

Supply Chain Director

The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information.

Stephanie Venn

Inventory Control Specialist

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

Rebecca Saxena

Corporate Product Stewardship Specialist

We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.

Timothy Mertes

Hazmat Shipping Professional

I can't say enough how pleased I was with this course! Everything finally makes sense.

Kim Graham

Lab Manager

Download Our Latest Whitepaper

Explore ten hazardous waste management errors that caused generators in California the most trouble last year.

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.