Lion's office will be closed on Friday, July 4, in observance of Independence Day. For help with online training, please contact support@lion.com.
Search

PHMSA and OSHA Issue GHS Guidance for Bulk Chemical Shippers

Posted on 9/19/2016 by Roger Marks

US DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) and OSHA recently issued a joint guidance document to help industry comply with overlapping hazard communication, or “HazCom,” rules for chemicals in the workplace and in transportation.

The guidance may be useful to those who offer or transport hazmat shipments by rail or highway tanks, rail cars, and other bulk containers. It is intended to clear up confusion about conflicting statements in DOT’s 49 CFR Hazardous Materials Regulations and the text of GHS with regard to hazard labels on bulk shipments.

See the full joint guidance memo here.

Conflicts Between DOT and OSHA Hazardous Chemicals Labeling

DOT’s Hazardous Materials Regulations (HMR), found at 49 CFR 100–185, include a statement that appears to explicitly prohibit the use of GHS and DOT hazmat labels on the same package or container:

“No person may offer for transportation and no carrier may transport a package bearing any marking or label which by its color, design, or shape could be confused with or conflict with a label prescribed by this part.” [49 CFR 172.401(b)]

But if we look to the next paragraph in the HMR, 49 CFR 172.401(c), we see that this prohibition does not apply to packages labeled in conformance with GHS standards. Building on this, the memo states: “As such, the display of a marking or label not required by DOT’s HRM, but conforming to OSHA’s HCS 2012 and consistent with GHS is not a violation of the HMR.”

GHS and DOT hazardous chemical labels

Background on GHS for Hazmat Shippers

Both US DOT and OSHA set requirements for labeling hazardous chemicals. DOT’s rules apply to the transportation of hazardous chemicals. OSHA’s Hazard Communication Standard, found at 29 CFR 1910.1200, is intended to inform employees of the chemical hazards they face in the workplace. OSHA adopted elements of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) its Hazard Communication Standard in 2012.

Read more about GHS hazard communication and hazmat shipping requirements here.

Keep Shipments in Compliance with 49 CFR and GHS

Want to learn more about how GHS labeling rules affect your chemical shipments? On November 17, join a full-time Lion instructor for the GHS for Hazmat Shippers Webinar. The webinar will help you make sense of the complex, overlapping OSHA and DOT labeling rules for hazardous chemicals. Make sure you know how these rules work together and which labels belong on which shipments, and why. Effective training is crucial to protect your staff and avoid hazmat fines as high as $77,114 per day, per violation.

New Course! Shipping Hazmat by Rail

If you offer or transport hazmat rail shipments, Lion’s new Hazmat Ground Shipper—Additional Rail Requirements online course will help you build on your hazmat highway knowledge to keep your rail shipments in compliance. Learn the special considerations and requirements that apply to this unique mode of hazmat transport—loading, unloading, and transloading; segregation, separation, and position-in-train requirements, tank car inspection responsibilities, and special rules for Class 3, 2, 2.1 and 6.1 materials. Sign up now!  

Tags: DOT, GHS, HazCom, hazmat shipping, new rules

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 can't say enough how pleased I was with this course! Everything finally makes sense.

Kim Graham

Lab Manager

Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms.

David Hertvik

Vice President

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

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

Johnny Barton

Logistics Coordinator

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

Ian Martinez

Hazmat Shipping Professional

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 instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

The instructor created a great learning environment.

Avinash Thummadi

CAD & Environmental Manager

Download Our Latest Whitepaper

Your hazmat paperwork is the first thing a DOT inspector will ask for during an inspection. From hazmat training records to special permits, make sure your hazmat documents are in order.

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.