OSHA Label: Standards and Suggestions

The Occupational Safety and Health Administration (OSHA) came into effect in the United States to secure the health and safety of industrial chemical workers when using hazardous chemicals within the work environment. The Hazard Communication Standard 1910.1200 provides the necessary regulations for employers and employees within the industrial chemical industry to ensure this safety.

The OSHA label requirements for regulated chemicals are stated under the Hazard Communication Standard (HCS) 1910.1200. Section (f)(1) of the HCS states it is the chemical manufacturer, importer, or distributor’s responsibility to ensure the OSHA label of a hazardous chemical leaving the workplace contains:

i)Identity of the hazardous chemical(s)

ii)Appropriate hazard warnings

iii)Name and address of the chemical manufacturer, importer, or responsible party

Section (f)(5) states it is the employer’s responsibility to ensure the OSHA label of a hazardous chemical in the workplace contains:

i)Identity of the hazardous chemicals(s) contained therein

ii)Appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical

Section (f)(5) does not need to apply if sections (f)(6) or (f)(7) are followed:

(f)(6) 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 paragraph

(f)(5) to be on a label. The written materials shall be readily accessible to the employees in their work area throughout each work shift.

(f)(7) The employer is not required to label portable containers into which hazardous chemicals are transferred from labelled containers, and which are intended only for the immediate use of the employee who performs the transfer.

CCCR Canadian Consumer Label Review

Canadian Consumer Label Review (CCCR) is a service offered by organizations that have the expertise with the Consumer Chemicals and Containers Regulations, 2001 (issued under the Hazardous Products Act). To ensure the products are correctly classified and eliminate the probability of product recalls due to improper classification, packaging and/or labeling.

Consulting services provide companies with expert interpretations, guidance and compliance with the CCCR guidelines. It is important to have someone with expert knowledge to classify the product because the person who determines the product classification is responsible for the CCCR. Therefore, if the CCCR is not outsourced to a company of experts and the importer, distributor or manufacture of a consumer product decides to complete the CCCR in-house they will be obligated to assess and correctly classify, package and label the product (as per Parts 1 to 5 of the CCCR-2001). It is not the retailer’s responsibility to ensure the product is packaged correctly. The person responsible for classifying the product is also responsible for providing the necessary information to a government inspector should there be a packaging concern or a product audit.

Typically, companies who pursuit CCCR label reviews save time, money and increase efficiency. Many current product labels do not meet standard regulations because the designers are unsure how to interpret the regulations or are not aware of the consumer chemicals and containers regulations. This oversight can be costly and embarrassing for companies who have are mandated by health Canada to recall their product due to unsuitable labeling.