Guide
Chemical Labeling Requirements: Shipped Containers vs Workplace Labels
Under OSHA HazCom, chemical manufacturers, importers and distributors must put a label on each shipped container of a hazardous chemical with six elements: product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s) and the supplier's name, address and phone number. Employers use these labels in the workplace, or may use their own system with the product identifier plus general hazard information.
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Shipped container labels (supplier labels)
A supplier label must contain:
- Product identifier, the same one used on the SDS.
- Signal word: "Danger" or "Warning".
- Hazard statement(s), the standard phrases for each hazard class and category.
- Pictogram(s): black symbol on a white background in a red diamond border. See the GHS pictograms.
- Precautionary statement(s), the recommended measures.
- Name, address and telephone number of the manufacturer, importer or other responsible party.
The standard wording of each statement can be looked up in the hazard statement and precautionary statement references. Labels must be legible, in English (other languages may be added), and prominently displayed on the container.
Workplace labels
For containers in the workplace, the employer must ensure that each container is labeled, tagged or marked with the product identifier and words, pictures, symbols or a combination of these that together provide at least general information about the hazards of the chemical. The employer may keep the supplier label or use an alternative system, such as NFPA 704 or HMIS ratings, provided the information is consistent with HazCom and employees can understand it. Workplace labels need to be updated when new hazard information is made available. The NFPA 704 page explains the diamond rating.
Shipped vs workplace labels at a glance
| Shipped container label | Workplace label | |
|---|---|---|
| Who writes it | Manufacturer, importer or distributor | Employer (or reuse supplier label) |
| Required content | Six defined elements | Product identifier plus general hazard information |
| Pictograms | GHS pictograms required where applicable | Optional, but allowed |
| Format | Prescribed | Flexible, if consistent with HazCom |
Exemptions and special cases
- Portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer, do not need a label. See secondary container labels.
- Pipes and process equipment may be handled through alternative labeling such as signs, placards or process sheets, provided employees can get the information.
- Transport labels are separate. Packages shipped on public roads also carry DOT labels and marks; see DOT hazard classes and the DOT regulations.
- Consumer products follow consumer labeling laws. See SDS for consumer products.
- Small containers (2024 update). Where a full label is not feasible, containers of 100 ml or less may carry an abbreviated label (product identifier, pictograms, signal word, supplier name and phone number, and a statement that full label information is on the outer package), and containers of 3 ml or less need only the product identifier if a label would interfere with normal use. The outer package must carry the full label.
- Released for shipment (2024 update). Containers that have been packaged and labeled for distribution and are awaiting shipment need not be relabeled after new hazard information, provided the updated label is supplied with each container when it is shipped.
Keeping labels in good order
- Do not remove or deface labels on incoming containers unless the container is immediately re-labeled.
- Replace damaged or unreadable labels.
- Check that the product identifier on the label matches the sheet in your library.
- Train employees on the label elements; see HazCom training.
Labels in other regimes
The layout and content of GHS labels differ slightly between regions. Canada requires bilingual labels (see WHMIS), the EU requires CLP labels with additional supplier details and sometimes a UFI code (see EU CLP), and so on. See the GHS overview for the common structure.
Worked scenario: checking a delivery
A drum of solvent arrives. At the receiving dock, the clerk checks the label for the six elements: product identifier, signal word, pictograms, hazard statements, precautionary statements and supplier details. The name on the label matches the name on the delivery note and on the sheet in the library. One pictogram printed on the label is not mentioned in Section 2 of the sheet. The clerk raises it with the supplier before the drum goes to the store, because a mismatch suggests that either the label or the sheet is out of date.
This ten-second check at receiving catches many problems before they reach the shelf.
Damaged and missing labels
- If a label is torn or faded, re-label using the information from the sheet and the supplier's label as far as it is legible.
- If a container arrives with no label, do not use it. Contact the supplier.
- Do not paint over or cover manufacturer labels with your own unless you copy the required information.
- Check labels on a routine inspection schedule, as chemical storage areas are tough on paper.
Frequently asked questions
What six elements must be on a HazCom shipped container label?
Product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and the name, address and phone number of the manufacturer, importer or other responsible party.
Can I use NFPA or HMIS labels in the workplace?
Yes, as a workplace labeling system, if the information is consistent with HazCom and employees are trained to understand it. They do not replace supplier labels on shipped containers.
Do I have to relabel every container in my workplace with GHS labels?
No. You can keep the supplier's label or use an alternative workplace system that provides the product identifier and general hazard information.
What does the red diamond on a label mean?
The red border identifies a GHS hazard pictogram. The symbol inside shows the type of hazard, such as flame, corrosion or health hazard.