In order to help you determine whether or not your GHS labels are compliant, we compiled common questions and answers pertaining to labeling in the workplace.

When do I need to have my labels converted?
Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemicals within six months of becoming aware of the new information

What if I’m introducing a new chemical, when do I have to supply GHS compliant labels?
The aforementioned individuals who introduce new chemicals are responsible for ensuring that labels on the containers of the newly identified hazardous chemicals are labeled appropriately when shipped.

What is the deadline for GHS label conversion?
For manufacturers, labels must be converted by June 1st, 2015. For distributors, labels must be converted by December 1st, 2015. There are certain caveats, such as proving a good faith effort. Therefore, it’s important to understand and evaluate your options as soon as possible!

What GHS elements do I need to include on my labels?
Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. Section C.2.3 .1 requires that the pictograms are “sufficiently wide to be clearly visible.”

What is the meaning of the term “shipped container” within the context of OSHA’s appendix C.2.3.3?
Any container leaving the workplace should be considered a “shipped container.” Furthermore, each container of hazardous chemicals leaving the workplace must be labeled, tagged, or marked with the required information.

Does OSHA require both the inside container and the outside box to be labeled when a chemical is classified as corrosive and/or flammable?
An employer is required to label a hazardous chemical’s immediate container, but the standards do not require labels on the outside shipping containers. According to a letter written by OSHA on November 9th 1990, labels are not required for outside shipping containers. However, when a hazardous chemical leaves the workplace, its immediate container must be labeled.

How many different GHS pictograms are there?
There are nine pictograms within the HazCom legislation, but only 8 of the labels are required to be included on the SDS, as the environmental pictogram does not reflect hazards within OSHA’s jurisdiction. Please reference the following photo depicting all of the GHS pictograms:

Source; OSHA

Source; OSHA

Do GHS labels need to be printed in color, or is black and white sufficient?
OSHA has been very clear that the red boarders of the pictograms are depicted in color. Every change made by HazCom was intended to help maximize the visibility of the potential hazard.

Am I required to have separate labels for consumers and manufacturers?
According to OSHA regulation, there are not different label requirements for end users and workplace manufacturers. One label should be sufficient.

For more information on specific OSHA regulations, please refer to: https://www.osha.gov/index.html

Please direct any additional questions to amanda.y@usequantum.com !