Search
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

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

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

Rebecca Saxena

Corporate Product Stewardship Specialist

Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.

Dorothy Rurak

Environmental Specialist

Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.

John Troy

Environmental Specialist

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

The instructor was energetic and made learning fun compared to dry instructors from other training providers.

Andy D’Amato

International Trade Compliance Manager

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

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

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

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.

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.