Issue link: http://psai.uberflip.com/i/1112122
W EEKLY EDITION MAY 1, 2019 C hemical Labeling Dos and Don't s When You Use Your Own Labels, Make Sure They Are OSHA - Compliant By Karleen Kos, PSAI Executive Director OS HA also says, "Employers may use additional instructional symbols that are not included in OSHA's HCS pictograms on the [secondary] labels. An example of an instructional pictogram is a person with goggles, denoting that goggles must be worn while handli ng the given chemical. Including both types of pictograms on [secondary] labels is acceptable. The same is true if the employer wants to list environmental pictograms or PPE pictograms from the Hazardous Materials Identification System (HMIS) to identify p rotective measures for those handling the chemical." Co m plia nt la bel s a re only p art of w ha t is re quir ed of em plo ye rs. Completing the labeling elements on these secondary label examples and affixing the labels to all products carried on the truck would usu ally meet the requirements for HCS compliance for secondary labels. But there is more you must do. First, remember: • Every chemical on your truck must have either the original manufacturer's label or a secondary label that meets the above criteria. • The S DS must be immediately available to employees. Usually this means the SDS for every chemical carried would be on the truck either in hard copy or on a tablet. Next, be sure you are communicating about hazards to your employees in an OSHA - compliant manner. Employers using alternative labeling systems must ensure that their employees are aware of all information required to be conveyed under the Hazard Communication Standard (HCS). If you are ever inspected, OSHA will make a site - specific determination of the effectiveness of your complete safety and labeling program. Any employer who relies on a secondary type of alternative labeling system, instead of using manufacturer labels containing complete health effects information will - in any OSHA enforcement a ction alleging the inadequacy of the labeling system - bear the burden of establishing that it has achieved a level of employee awareness which equals or exceeds that which would have been achieved if the employer had used labels containing complete health effects information. So: • Make sure you are training your employees on the chemicals you use in your operation, their hazards, and how to use them safely. • If you use secondary labels, make sure you cover this in your training program and document it • Keep good training records P AGE 11 CONTINUED ON PAGE 1 2