Portable Sanitation Association International

ASSOCIATIONINSIGHT Portable Sanitation Association International News BIWEEKLY EDITION JANUARY 6, 2021 Page 15 To properly prepare and affix labels: • Choose labels designed to stick to the type of container you are using and will not be faded or degraded by contact with the chemical. • Transfer the product identifier to the label using indelible ink. It can be the name of the product (e.g. "Windex") or the chemical name (e.g., "formaldehyde"). The same product identifier must be both on the label and in section 1 of the SDS. • Record the "signal word" from the parent container. Signal words are used to indicate the relative level of severity of the hazard and alert the reader to a potential hazard on the label. There are only two words used as signal words: "Danger" and "Warning." "Danger" is used for the more severe hazards and "Warning" is used for the less severe hazards. There will only be one signal word on the label no matter how many hazards a chemical may have. A few products may not have a signal word. In that case, write N/A on your secondary label to show you haven't overlooked it. • Select the appropriate pictogram for the chemical in the container. To do this, check the box for the correct image, or draw a heavy black circle around it. To further assure safety, you can also blacken all the irrelevant pictograms. • Note any specific hazard or precautionary statements on the original label and write them on the secondary label. On secondary labels, space is often an important factor. Precautionary statements may be combined on the label to save on space and improve readability. For example, "Keep away from heat, spark, and open flames;" "Store in a well-ventilated place;" and "Keep cool" may be combined to read: "Keep away from heat, sparks, and open flames and store in a cool, well-ventilated place." OSHA 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 handling 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 protective measures for those handling the chemical." Compliant labels are only part of what is required of employers. Completing the labeling elements on these secondary label examples and affixing the labels to all products carried on the truck would usually 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 SDS 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. Chemical Labeling Dos and Don'ts…continued from page 11 Continued on page 16

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