Are NFPA and/or HMIS Ratings still allowed on OSHA SDS and Labels?
Written By: Atanu Das on Tuesday, April 11, 2017
On the OSHA FAQ site, the agency addressed the following question:
Will OSHA continue to allow Hazardous Material Information System (HMIS) and/or National Fire Protection Association (NFPA) rating systems to be used on a) workplace labels, b) Safety Data Sheets (SDSs), and c) labels on shipped containers?
a) For workplace labels:
OSHA has retained the same flexible approach to in-plant labeling in the revised standard as it did in the 1994 Hazard Communication Standard (HCS). Employers may create their own labeling system that works for their workplace and employee population. Or, employers can continue to use their current labeling system as long as all of the required information is immediately available to employees when they are in their work areas.
For the workplace label, the container must be labeled, tagged, or marked with either the:
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Product identifier, signal word, pictogram(s), hazard statement(s), and precautionary statement(s) of the hazardous chemical; OR |
Product identifier and words, pictures, symbols, or a combination of these that provide at least general information about the hazards of the chemicals, and which, in conjunction with the other information immediately available, provides employees with the specific information about the physical and health hazards of the hazardous chemical. |
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The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by 29 CFR 1910.1200 (f)(6), outlined above, to be on a label. The employer must ensure the written materials are readily accessible to the employees in their work area throughout each work shift.
Other systems, such as the NFPA 704 hazard rating system and the HMIS are permitted for workplace containers. However, these labels must provide at least general information regarding the hazards of the chemicals. Hazard warnings or pictograms that conflict with those required by HCS for the chemical may not appear on the workplace label. When such rating systems are used, employees must be trained on how to use and understand the alternative labeling systems so that employees are aware of the effects of the hazardous chemicals to which they are potentially exposed.
In other words:
Employers may choose to label workplace containers either with the same label required for shipped containers of the chemical, or may instead use alternative labels, as long as those labels provide employees with general information about the hazards of the chemical, and the employer provides training so that employees exposed to the chemical understand the specific hazards it presents.
b) For SDSs:
The HMIS and NFPA information is not required on SDSs; however, such information may be included if it does not contradict or cast doubt on the Hazard Communication classification.
c) For labels on shipped containers:
The HCS has specific requirements for label elements (see 29 CFR 1910.1200(f)(1)). However, chemical manufacturers and importers are free to provide additional information regarding the hazardous chemical and precautions for safe handling and use. This is referred to as supplemental information. OSHA will allow the NFPA and HMIS rating systems to be used on the labels if it does not contradict or cast doubt on the information required by the HCS. OSHA has published several guidance products on labeling, including an OSHA Brief, located at: http://www.osha.gov/Publications/OSHA3636.pdf**.