Issue link: http://psai.uberflip.com/i/1325965
ASSOCIATIONINSIGHT Portable Sanitation Association International News BIWEEKLY EDITION JANUARY 6, 2021 Page 11 Chemical Labeling Dos and Don'ts…continued from page 10 Make Sure Your Secondary Label Meets the Requirements To ensure the "hazards present" are correctly displayed on a secondary label, OSHA says: • Your in-house label should include a product identifier, as well as words, pictures, symbols, or a combination of those things, which provide general information on the hazards of the chemicals. The label, in conjunction, with other information immediately available to employees under the hazard communication program—such as the Safety Data Sheet (SDS) — will provide employees with specific information regarding the physical and health hazards of the hazardous chemical. • If symbols are used on the label, they must not contradict the pictograms, or use of the wrong symbol for a given hazard (e.g., using the symbol for oxidizers to signify carcinogens). Typically the manufacturer would have used HCS- compliant pictograms in their original packaging (see the chart below for the full array of approved images). So your label could look something like the examples at right. Note: Several PSAI members who sell decals can provide you with similar products (see our Supplier Directory), or you can get them from various online vendors. Complete the Secondary Label in a Compliant Manner OSHA says the key to evaluating the effectiveness of any alternative labeling method is to determine whether employees can correlate the visual warning on the labeled container with the applicable chemical and its appropriate hazard warnings. So your alternative labeling system must be readily accessible to all employees in their work area throughout each work shift. It's also important to know that you cannot use safety data sheets in lieu of labels. This means that while it is essential your team carry an SDS for every chemical on the truck, the SDS is not "good enough" for showing that you, as an employer, have taken the right safety measures to ensure your team has the information needed for the safe use of chemicals. The bottle or container must be labeled with the chemical name and the hazards present. Continued on page 15 HCS-Compliant Pictograms