By Phil Molé, MPH
A chemical label packs a lot of important information into a small space.
Under OSHA’s Hazard Communication (HazCom) Standard, shipped container labels help workers quickly identify a chemical and understand its hazards. But chemicals don’t always stay in the containers they arrive in. Many times, you need to put them in secondary containers, also known as workplace containers, and OSHA requires you to label those, too.
You may transfer chemicals into smaller bottles or dispense them into process containers. You might move those containers between work areas. And over time, the information chemical manufacturers provide about their products can change, and that means the workplace container labels should change, too.
That means an effective workplace container labeling system takes more than putting a label on a container. You need a system that communicates the right hazard information, stays current, and makes that information easy for employees to find and understand.
Here are six best practices to help you build a stronger workplace container labeling system.
1. Understand What Your Workplace Labeling System Needs to Communicate.
First, it’s important to distinguish between shipped container labels and workplace labels.
Chemical manufacturers, importers, and distributors are responsible for labeling the hazardous chemicals they ship. These shipped container labels follow standardized HazCom requirements and include information, such as the product identifier, signal word, hazard statements, pictograms, precautionary statements, and supplier information.
Employers have more flexibility when labeling workplace containers.
You can use a label containing the same information as the shipped container label or you can use an alternative workplace labeling system that meets OSHA’s requirements.
If you use an alternative system, you have two main conditions to meet according to HazCom. First, the workplace label itself must, at a minimum, include the product identifier. Other information immediately available to employees under your HazCom program must provide them with specific information regarding the chemical’s physical and health hazards.
Second, the entire workplace labeling system, consisting of supplemental information, needs to convey all shipped container label info, including product identification, supplier identification, hazard pictograms, signal word, precautionary statements, and hazard statements, to employees within their work shifts.
In other words, don’t think about a workplace label in isolation. Think about the whole hazard communication system surrounding it.
The label, supplemental information, Safety Data Sheets (SDSs), written HazCom program, and employee training should work together to make sure employees can identify a chemical and understand its hazards.
As extra motivation, think about the fact that in the event of an OSHA inspection, the inspector will want to see evidence that your workplace labeling system is effective and that employees understand it. The bottom line: Keep it as simple as possible, and make sure your people know how it works.
2. When Possible, Make the Shipped Container Label Your Gold Standard.
OSHA gives employers flexibility with workplace labeling, but that doesn’t mean you always need to take advantage of it. When practical, replicating the shipped container label on a workplace container is a strong best practice.
Why? Consistency.
Employees who encounter a chemical in its original container see one set of information. If they encounter that same chemical in a workplace container, replicating the shipped label gives them the same hazard information in a familiar format.
It can also reduce some of the complexity involved in developing, maintaining, and training employees on a separate workplace labeling system.
There may be situations where replicating the full shipped container label isn’t practical. That’s where OSHA’s flexibility around workplace labeling becomes useful. Alternative labeling systems may be the only viable option if, for example, the container is too small to affix a label that contains full shipped container label information.
But when you can replicate the shipped label, doing so can provide a simple gold standard: Give employees the same hazard information wherever they encounter the chemical.
3. If Using an Alternative Labeling System, Document and Train Employees on It.
Flexibility comes with responsibility. If you choose an alternative approach to workplace labeling instead of replicating shipped container labels, employees need to understand how that system works.
Your written HazCom program should describe your workplace labeling system, including how you will meet your labeling responsibilities.
Your HazCom training should also prepare employees to understand the labeling system they will encounter on the job. If your system relies on supplemental information to provide specific hazard details, employees need to know how and where to access that information.
Think about the experience from the worker’s perspective.
If someone picks up a workplace container, can they identify what’s inside? Can they understand the general hazards? Do they know where to find more detailed hazard information? And have they been trained to interpret the labeling system correctly?
If the answer to any of those questions is no, the system may not be communicating as effectively as it should.
A labeling system only works when the people relying on it know how to use it.
4. Keep Workplace Labels Aligned with Changing Shipped Container Information.
Chemical hazard information isn’t static. That’s particularly important right now because of OSHA’s 2024 updates to the Hazard Communication Standard.
As chemical manufacturers, importers, and distributors update their hazard classifications, SDSs, and shipped container labels to align with the revised standard, they will have to reclassify chemicals in certain hazard categories, such as desensitized explosives, aerosols, flammable gases, and chemicals under pressure.
This means they’ll need to reauthor SDSs and shipped container labels with updated HazCom info. As that process continues, employers will receive updated information about chemicals already present in their workplaces.
That can create a ripple effect for workplace labeling.
Suppose you’ve created workplace labels based on information from a supplier’s shipped container label. You later receive an updated label or SDS containing revised hazard information.
Are the workplace labels you’ve already created still accurate? Maybe not. The chemical may still be the same physically, but the specific accompanying info, like pictograms, hazard statements, and precautionary statements, may no longer reflect the information OSHA has determined should be present for the safety of end users. As one example, if you store desensitized explosives (a hazard class new to HazCom via the 2024 final rule) in workplace containers, you’re going to want to make sure those container labels:
- Identify them as desensitized explosives rather than just explosives
- Contain important details about checking that wetting/stabilizing agents are present to ensure the chemical remains stable and doesn’t become an actual explosive
That’s why your labeling process needs to account for change. Prioritize establishing a process to:
- Identify when manufacturers or suppliers provide updated chemical information
- Review updated shipped labels and SDSs against the information currently used in your workplace labeling system
- Determine whether existing workplace labels or supplemental information need to be updated
- Update affected information throughout your workplace when necessary
- Avoid maintaining conflicting versions of hazard information across different locations
This can become especially challenging for organizations managing large chemical inventories or multiple facilities. The goal is to keep the information employees see in the workplace aligned with the most current hazard information you’ve received.
5. Don’t Forget About the Original Shipped Container.
Workplace containers aren’t the only containers that require attention.
When a hazardous chemical arrives at your facility, its shipped container should already have the required label. Employers must not remove or deface existing labels on incoming containers of hazardous chemicals unless the container is immediately marked with the required information.
But keeping the label on the container isn’t enough if nobody can read it.
Labels can become torn, stained, faded, damaged, or otherwise illegible during storage and use. That’s why label condition should be something you monitor, not something you assume.
Consider incorporating container labels into routine inspections of chemical storage and use areas.
Ask: Is the original label still present? Is it intact? Is the information legible?
If the answer is no, address the issue so employees continue to have access to the hazard information they need.
6. Make Sure Employees Can Actually See the Label.
Here’s an easy labeling problem to overlook. A 55-gallon drum of a chemical has the right label and the label is completely legible. There’s just one issue: the container is stored so that the label is on the far side, flush with the wall.
There’s no safe way for an employee to see that label because he or she would need to heave that whole barrel around so that the label is visible. The purpose of a label is to convey needed hazard information to users, but the storage of this drum defeats that purpose because the information isn’t accessible.
When reviewing chemical storage areas, don’t stop at checking whether containers are labeled. Check how they’re stored, and make sure the label is both legible and visible.
Labels should be positioned, so employees can readily see and read them. Avoid arrangements where other containers, shelving, walls, or storage configurations routinely obscure important hazard information.
It’s a small operational detail with a big implication: Don’t just ask whether the container has a label. Ask whether employees can see and read it.
Give Your Team the Tools to Keep Labeling Manageable
There’s a common thread running through all these best practices: maintaining an effective labeling system takes ongoing work.
You need current chemical information. You need a consistent approach to workplace labels. You need to know when supplier information changes. And when someone needs a new or replacement label, you need a practical way to create it.
The harder those tasks are, the harder it becomes to maintain consistency, especially when you’re managing hundreds or thousands of chemicals across multiple locations.
That’s why the systems supporting your HazCom program matter.
Look for tools that make it easy to access current chemical information, reproduce shipped container labels when appropriate, and print workplace labels containing selected HazCom information when your labeling system calls for it.
The goal is to make doing the right thing easy.
Better Workplace Labeling Manages the Moving Pieces
An effective workplace labeling program isn’t just about what’s printed on the label. It’s about making sure employees can identify the chemicals they work with, understand their hazards, and access the information they need to work safely.
That requires looking at the entire system: shipped container labels, workplace labels, supplemental hazard information, SDSs, your written HazCom program, employee training, and the processes you use to keep all that information current.
And as manufacturers update their labels and SDSs to align with HazCom 2024, having a reliable way to manage those moving pieces becomes even more important.
Level Up Your Labeling System with VelocityEHS
VelocityEHS Chemical Management helps you manage chemical and SDS information, while giving your team the support they need to reproduce shipped container labels and create workplace labels with selected HazCom information.
Set up a meeting so you can see our software in action for yourself.
