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

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

I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!

George Chatman

Hazardous Material Pharmacy Technician

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

Well designed and thorough program. Excellent summary of requirements with references. Inclusion of regulations in hard copy form, as well as full electronic with state pertinent regulations included is a great bonus!

Oscar Fisher

EHS Manager

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 very knowledgeable and provided pertinent information above and beyond the questions that were asked.

Johnny Barton

Logistics Coordinator

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

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

Larry Ybarra

Material Release Agent

I will never go anywhere, but to Lion Technology.

Dawn Swofford

EHS Technician

I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!

Sara Sills

Environmental Specialist

Download Our Latest Whitepaper

Knowing why TSDFs reject loads of hazardous waste—and the exact steps to follow if it happens—can reduce your anxiety and uncertainty about rejection.

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.