To label workplace containers..or not to label...is there really any question?
OSHA's GHS Rule plainly states that employers may use signs, placard, process sheets, batch tickets or even operating procedures in lieu of affixing labels to individual containers as long as whichever method is chosen meets the required conveyance of information and written materials are available to employees in their specific work area during each work shift. This is not far off from the original HCS. However when we refer back to the workplace labeling section, the new rules states that the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged and or marked. Symbols and statements all need to be present in accordance with the new system.
This brings to mind a previous topic regarding NFPA or HMIS systems and the compatibility of said systems. It would be worth considering the option of combining them IF the numbering systems were congruent. Since, at the time of this writing they are not, we are looped back to the original question.
Next week's topic...
Can labeling systems be combined with GHS?
This information is offered for evaluation and discussion
only. For more information contact your local OSHA representative or
go to http://www.osha.gov/dsg/hazcom/index.html
