What Are the Requirements for Chemical Labels?
When you’re dealing with hazardous chemicals, don’t leave anything to chance. Complying with chemical labeling regulations doesn’t just keep your business on the right side of the law; it ensures that anyone who comes in contact with hazardous materials has information on how to handle them and what to do in case of an emergency.
Of course, you should always consult with your Environmental, Health, and Safety (EHS) team to ensure compliance, but understanding label requirements from the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HCS) and California’s Proposition 65 is essential for proper chemical labeling.
HCS & GHS Labels: Chemical Labeling Regulations for Hazard Information
OSHA’s Hazard Communication Standard (HCS) follows the United Nations’ Globally Harmonized System of Chemical Labeling (GHS). To be HCS-compliant, the following four label elements must be present.
- A harmonized signal word. “Danger” is used for severe hazards, and “warning” for less severe hazards. Only the strongest applicable word is used on labels. For example, if the chemical is a severe oxidation hazard and carries a minor risk of igniting, the label should say “Danger.”
- GHS pictograms, each surrounded by a diamond-shaped red border.
- A hazard statement that includes the hazard class, category, and, in most cases, degree of hazard.
- A precautionary statement that describes recommended practices to minimize or prevent adverse effects when handling or storing the chemical.
Safety Data Sheet (SDS) Requirements
In addition to hazard pictograms, OSHA requires all chemicals to have a Safety Data Sheet (SDS) available on-site for each material that may present a chemical hazard (must be accessible for all work shifts). These are critical documents that provide detailed information about hazardous chemicals, including their properties, safe handling, and emergency response measures. SDSs must follow the Globally Harmonized System of Classification and Labeling of Chemicals format to ensure consistency. Each SDS includes key sections such as identification, hazard classification, first-air measures, handling and storage guidelines for secondary containers, and toxicity data, among other specific information.
To stay compliant, SDS information must align with chemical container labels, including GHS pictograms, hazard statements, and precautionary instructions. This alignment ensures a successful Hazard Communication Program.
GHS Pictograms
GHS pictograms are designed to be understood worldwide, independent of language.
Health Hazard
Looks like: A silhouette of a person with a 6-point burning motif
Used for: Toxins, mutagens and carcinogens
Flame
Looks like: A flame with a line beneath it
Used for: Flammables, pyrophorics, self-heating chemicals, self-reactives, organic peroxides, flammable liquids, and anything that emits flammable gases
Exclamation
Looks like: An exclamation point
Used for: Skin sensitizers, skin irritants, eye irritants, acute toxicity, respiratory irritants, and chemicals that can cause narcotic effects
This pictogram is also used for chemicals that are hazardous to the ozone layer, but this labeling isn’t mandatory.
Gas Cylinder
Looks like: A pressurized gas cylinder tilted on its side
Used for: Gases held under pressure
Corrosion
Looks like: A hand and black bar being burned by vials of chemicals
Used for: Skin corrosion, skin burns, eye damage, and metal corrosion
Exploding Bomb
Looks like: An exploding sphere
Used for: Explosives, self-reactives, and organic peroxides
Oxidizer
Looks like: A flame above a circle
Used for: Oxidizers
Skull and Crossbones
Looks like: A skull and crossbones
Used for: Acute toxicity, whether toxic or fatal
Environmental*
Looks like: A tree and fish
Used for: Aquatic toxicity
*This symbol is not mandatory.
HCS Label Layouts
A detailed HCS label is typically divided into two columns:
Left Column
– Standard Industrial Classification (SIC) code or CAS number and chemical name or product identifier
– Supplier or chemical manufacturer information, including the name, address, and emergency telephone number of the company
– Precautionary statements, including handling recommendations, first aid, and fire instructions
Right Column
– GHS pictograms
– Signal word
– Hazard statements
– Supplemental information, including the expiration date, manufacturing date, recommended personal protective gear, and directions for use
Two-column labels are mostly seen on large containers, like 50-gallon drums. If less information is needed, or the label needs to fit a small package, you can use chemical labels laid out in a single column:
– Standard Industrial Classification (SIC) code or CAS number and product name
– GHS pictograms
– Signal word
– Hazard statements
– Precautionary statements, including handling recommendations, first aid, and fire instructions.
– Supplier identification, including the name, address, and emergency phone number of the company
For small items, it may be difficult to fit all the required information directly on the label. In this case, the label may only include basic information, including the GHS pictogram, hazard statement, and signal word. However, complete label information must be included with the product, whether it’s on the box it’s shipped in or a paper that is packaged with the container. These items must have their information detailed in the SDS.
Labels for California Proposition 65 Compliance
Along with the chemical labeling requirements from national and international agencies, products sold in California must comply with labeling established by the Safe Drinking Water and Toxic Enforcement Act of 1986, known colloquially as “Proposition 65.”
The state maintains a list of chemicals known to cause cancer, birth defects, or reproductive harm. Updated each year, this list has grown to include over 800 chemicals. Businesses have 12 months to comply with labeling requirements once a chemical is added to this list. In 2018, the law was amended to make labeling clearer on consumer goods:
– The warning must be at least the same size as other consumer information, and the writing must be in a 6-point or larger font.
– It must include the GHS exclamation pictogram
– Chemical labels must include versions of the warning for each language used on the packaging and any instructions. For example, if you package the item with English, Spanish, and French instructions, the warning must also be in English, Spanish, and French.
Labeling Machine Options for Chemical Containers
Both HCS and Proposition 65 information can be part of a larger label or a separate label.
If you want to apply chemical warnings on labels separate from the main product label, consider CTM’s front-back wrap labeling system. This labeling machine can apply more than one label, letting you switch the product and warning labels independently.
For small vials and round containers, consider a semi-automatic tabletop wrap labeler. By switching out the star wheel, you can use this machine to label a range of small, round containers.
For these smaller label applications, the remaining hazard communication information can be applied to the boxed containers. CTM Labeling Systems offers a variety of automated labeling systems and print and apply labeling applicators to accommodate any need, increase efficiency, and improve work processes.
Let Us Help You with Safety Label Compliance
Looking for a way to add OSHA and Proposition 65-compliant labels to your products without slowing down production? Contact CTM Labeling Systems. We can direct you to a local distributor who can set you up with a chemical labeling system that will fit your facility’s needs.
