Lion's office will be closed January 1. Online training support is available every day from 8:30 AM to 5 PM ET via support@lion.com.
Search

New GHS Labels vs. DOT Labels

Posted on 7/31/2012 by James Griffin

Q. I have a 55-gallon drum of a flammable chemical that I plan to ship to a customer. I know I am required to have a GHS label on the outside, as well as DOT markings and labels. I was told that the flame pictogram on the GHS label cannot be on the drum since there is already a Flammable Liquid label as required by the DOT. Is this true?
 
A. You are correct. This is a case of overlapping regulations.
 
The Occupational Safety and Health Administration (OSHA) recently added the Globally Harmonized System (GHS) to its Hazard Communication Standard. As such, all hazardous chemicals that will be transported must be labeled with new GHS labels. There will be a small transition period (until June 1, 2015), but most employers are already phasing in the new system.
 
GHS labels are required to have four pieces of information on them: a signal word, hazard statements, precautionary statements, and a pictogram. The full text of these requirements can be found at 29 CFR 1910.1200, Appendix C.
 
While some of the pictograms are exclusive to GHS, many of them have the same appearance as DOT pictograms. For instance, here is the mentioned flame pictogram that goes on your GHS labels.
GHS HazCom Label for Flammable liquid

 

Under the Department of Transportation’s (DOT) hazardous materials regulations, all shipments of hazmat must have certain hazmat markings and labels placed on packages. They include, but are not limited to, marking the Proper Shipping Name, identification number, name and address, and affixing hazard labels. [49 CFR 172, Subparts D and E] For instance, here is the Flammable Liquid label.
Hazmat Shipping Label for Class 3 Flammable Liquid

Avoid Labeling Confusion
As part of the rollout of the GHS rule, OSHA explicitly forbids a package from having a GHS pictogram when the package is already required to have a DOT hazmat label.
 
“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.” [29 CFR 1910.1200, Appendix C.2.3.3]
 
OSHA addresses its comments as to why it is prohibiting the GHS pictogram in this specific scenario in the Federal Register that announced the final GHS rule.
 
“The reason it is mandatory is that having two different pictograms addressing the same hazard may lead to confusion for people handling the chemical.” [77 FR 17728, March 26, 2012]
 
Prepare your facility for a seamless transition to the new labeling standards with Lion’s online OSHA training. Material handlers will learn to recognize new labels, pictograms, and Safety Data Sheets (SDS) in the Hazard Communication Online Course. All employees must be trained by December 1, 2013.
 

Tags: GHS, HazCom, hazmat shipping, marks and labels, osha

Find a Post

Compliance Archives

Lion - Quotes

This is the best RCRA training I've experienced! I will be visiting Lion training again.

Cynthia L. Logsdon

Principal Environmental Engineer

Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.

Kimberly Arnao

Senior Director of EH&S

Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.

Francisco Gallardo

HES Technician

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

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

Rebecca Saxena

Corporate Product Stewardship Specialist

Lion's information is very thorough and accurate. Presenter was very good.

Melissa Little

Regulatory Manager

The online course was well thought out and organized, with good interaction between the student and the course.

Larry Ybarra

Material Release Agent

The instructor does a great job at presenting material in an approachable way. I have been able to save my company about $30,000 in the last year with what I have learned from Lion!

Curtis Ahonen

EHS&S Manager

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

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

Download Our Latest Whitepaper

What to do before, during, and after a RCRA hazardous waste inspection to defend your site from rising State and Federal penalties.

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.