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Labeling

Proper labeling of hazardous chemical and waste  is extremely important to reduce exposure,  prevent accidents and extra disposal costs:

OSHA’s Hazard Communications Program (HazCom) (link) covers the labeling of hazardous chemicals in use.  Once the chemical becomes a hazardous waste, a different set of labeling rules apply under  EPA’s RCRA program (provide link).  To add to the challenge of labeling all hazardous materials, to prepare hazardous waste for shipment, another set of rules apply under the Department of Transportation (DOT) (provide link).

HazCom requires that all containers of hazardous chemicals must be labeled, tagged, or marked with the identity of the material and appropriate hazard warnings.  Chemical manufacturers, importers, and distributors must ensure that every container of hazardous chemicals they ship is appropriately labeled with such information and with the name and address of the producer or other responsible party.

Additional information on labeling:

• Third party labeling systems are available to communicate specific hazards such as toxicity, flammability, reactivity and other hazards. HMIS and NFPA Labeling Systems

Emergency Planning and Community Right-To-Know Act

The primary information to be obtained from an OSHA-required label is the identity for the material and appropriate hazard warnings.  The identity is any term which appears on the label, the MSDS, and the list of chemicals, and thus links these three sources of information.  The identity used by the supplier may be a common or trade name ("Black Magic Floor Cleaner"), or a chemical name (1, 1, 1 - trichloroethane).  The hazard warning is a brief statement of the hazardous effects of the chemical ("flammable," "causes lung damage").  Labels frequently contain other information, such as precautionary measures ("do not use near open flame") but this information is provided voluntarily and is not required by the rule. 

Labels must be legible and prominently displayed.  There are no specific requirements for size or color or any specified test.

Proper labeling is extremely important to prevent accidents and extra disposal costs

  • Ensure proper labeling of all incoming materials as they are received (Include product name, weight, concentration, lot number, date, hazard class and any other information useful in tracking material location, quality, age or use.)
  • Always label hazardous waste at its point of generation where it can still be easily identified (Testing later to determine the contents is expensive.)
  • Label all areas in the plant, including stationary tanks, pipelines, etc.  containing hazardous materials or wastes
  • If  a chemical was in a labeled container and is subsequently transferred to another container, the employer must label the new container.   
  • Shelving where the chemical is stored may be labeled with additional labeling if when the chemical is removed from the labeled shelf, it will be used in its entirety.  If not, it will require an additional label.

Specifically, HazCom requires the following types of information to ensure that labeling is properly implemented in your facility:

  • Designation of person(s) responsible for labeling system implemented throughout the facility;
  • Designation of person(s) responsible for ensuring labeling of all containers in each department/area;
  • Designation of person(s) responsible for ensuring re-labeling of hazardous waste or to prepare waste for shipping
  • Description of labeling system(s) used and comprehensive training program;
  • Description of written alternatives to labeling of containers (if used); and,
  • Procedures to review and update label information when necessary.

©2015 Healthcare Environmental Resource Center
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