Does OSHA Prohibit NFPA / HMIS Labeling Systems?

NFPA & HMIS Warnings Systems and Their Place in OSHA's Haz-Com Standard

September 8, 2015 -  It seems like once every week or two I get a call or email from someone asking me if I’d help clarify for them OSHA’s requirements on labeling of in-house containers and secondary containers per the revised Hazard Communication standard. Apparently many people think that OSHA now requires all in-house containers be labeled with the pictograms and other information adopted from the Global Harmonized System of Classification and Labeling of Chemicals (GHS), and that OSHA no longer allows the use (some even say they “outlaw” the use) of other hazard labeling systems such as those created by the National Fire Protection Association (NFPA) and the Hazardous Materials Identification System (HMIS).

In actuality, it is only those containers shipped by manufacturers, importers, and distributors that are required by OSHA’s updated Hazard Communication standard to be labeled with all the GHS-related information (specifically, a product identifier, signal word, hazard statement(s), pictogram(s), precautionary statements, and the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party). But when it comes to labeling of in-house containers, such as fixed tanks and secondary containers, the employer actually has two options:

Option 1 - Employers can label in-house containers with labels (or placards) displaying the product identifier, signal work, hazard statement(s), pictogram(s), and precautionary statements, which is essentially the exact same information as manufacturers’ original container labels;

or,

Option 2 - Employers can label in-house containers with the product identifier (same as GHS) and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical [see 1910.1200(f)(6)(i) and (ii)].

This,in essence, means the employer can continue to use alternate hazard identification systems such as NFPA and HMIS as part of their in-house labeling system, as long as their labels convey the same hazard message(s) as the GHS system.  However, I typically still recommend that employers transition over to the newer GHS label elements for all in-house containers. Why?  It all comes down to employee training.

The updated OSHA Haz-Com standard now requires employers to train all of their employees on all elements of the new GHS labeling system, which makes sense because all labels on containers shipped from manufacturers and others are required to display the GHS information. So if all of your in-house containers are also labelled with the same GHS information, then your employee training on labels is covered. But, if an employer chooses to use an alternate labeling system as part of their in-house container labeling system, then the employer must also provide additional training on that alternate system (or systems) in use for in-house containers.  Why would you want to do that?

So the answer is no, OSHA has not “outlawed” the use of alternate labeling systems like NFPA or HMIS for labeling your in-house containers, so long as the labeling systems still meet the requirements for alternate labels that are spelled out in the OSHA container labeling standard referenced above. But long-term, it seems to me that converting to the GHS system for all in-house containers would make your life easier in terms of employee training and for increasing employee understanding, which was the whole reason OSHA adopted the GHS system.

Do you or your clients still utilize alternate labeling systems for in-house containers? Or have all in-house labels been converted to GHS-based labels? Were there any problems associated with converting to the new GHS-based system for labeling in-house containers? Or sticking with the old labeling system that utilized an alternate system?

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ABOUT THE AUTHOR:

Curtis Chambers is a Certified Safety Professional (CSP) and holds a Master of Science degree in Occupational Safety and Health. He has held numerous leadership positions managing and evaluating health and safety programs and providing training on workplace safety and health topics at various public organizations and private corporations. Mr. Chambers is currently the President of OSHA Training Services Inc. Visit their website at www.oshatraining.com. 

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