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

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!

Chelsea Minguela

Hazmat Shipping Professional

Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!

Marti Severs

Enterprise Safety Manager

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance 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 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

Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.

Ellen Pelton

Chemical Laboratory Manager

The instructor made the class very enjoyable and catered to the needs of our group.

Sarah Baker

Planner

The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

Download Our Latest Whitepaper

The definitive 10-step guide for new hazardous materials shipping managers. Quickly reference the major considerations and details that impact hazmat shipping compliance.

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.