Chances are your maintenance facility has some substances that are potentially hazardous if used incorrectly or are exposed to workers for too long. Hydraulic fluid is an example. Depending on the type of projects your company does, you may also have liquid or solid chemical mixtures that are used on a jobsite, such as herbicides, insecticides, removal compounds, aerosols, etc. And you wouldn't be the only shop to transfer a hazardous product from a large container into a more manageable secondary container.
It isn't enough to mark a container "brake fluid" or draw a skull & crossbones with a black Sharpie. As of June 1, 2016, all containers must be labeled using the approved OSHA format. If your company is inspected by OSHA and containers are not marked or incorrectly marked, your company will be noncompliant by OSHA standards.
When OSHA updated its HCS, employers and product manufacturers had to make significant changes to their safety programs, information and training. OSHA also aligned itself with Globally Harmonized System of Classification and Labeling of Chemicals (GHS) to ensure description continuity for chemicals and products coming from other countries.
Manufacturers are now required to supply updated safety data sheets (SDS) to replace the previous MSDS materials, and label all shipping containers with hazard classification information. Employers were required to develop a hazard communication program and train workers on safe handling and accident prevention before allowing them to use the substances on a job. The June 1, 2016 deadline ends the transition period OSHA allowed for employers to meet the new HCS requirements and marks the final step employers need to take to be in compliance with OSHA rules.
Your To-Do List
ALL secondary or alternate containers holding hazardous materials including liquids, viscous fluids, gases, and solids must be labeled.
Each label must have the following information:
- Product Identifier - the common or trade name of the chemical(s). This identifier must match the term used in the SDS description
- Signal Word - indicates the level of potential hazard the contents contain. 'Danger' is used for severe hazards and 'Warning' for less severe hazards. It is important to train workers about the difference these signal words imply.
- Hazard Statement - a simple, direct statement that describes what will happen if the container's contents are misused. Example: Fatal if Swallowed
- Pictogram - One of eight approved graphics that shows, using color, borders and pictures, what the content's dangers are. Some pictograms have symbols that resemble the hazardous effect and others are used to attract attention to the label.
- Precautionary Statement - describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to the container's contents. Example: Do not eat, drink, or smoke when using this product.
- Supplier Identification - Manufacturer and/or distributor name, address, phone, and emergency phone number.
- Supplemental Information - this area is for directions for use, expiration dates, fill dates, lot numbers, etc.
Above is an example of an OSHA approved label.
To make labeling simpler, several companies provide templates, software, labels, and printer recommendations. Avery offers GHS label supplies and software so you can print your own. Seton offers secondary container labels that are preprinted and let you fill in the information by hand.
The more you and your workers know, the safer you will all be.