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

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

Rebecca Saxena

Corporate Product Stewardship Specialist

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

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

The course was very well structured and covered the material in a clear, concise manner.

Ian Martinez

Hazmat Shipping Professional

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

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

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

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

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.