Ask the Experts
April 2011
Q: Hazard communication is #3 on OSHA's list of the top ten violations in 2010. What can be done to improve labeling of hazardous substances?
A: Since manufacturers are required to properly label the substances they ship, the biggest HazCom labeling area involves transferring chemicals from the manufacturer's containers to smaller containers. Lack of labeling or improper labeling of these secondary containers results in many of the OSHA HazCom citations.
How can labeling of secondary containers be improved?
Start with training. Anyone who might need to transfer substances from one container to another should be trained on the importance of proper labeling, how to obtain or make the needed labels and on how to read an MSDS.
Next make labeling easy. Print commonly used labels in advance so that they are readily available. Assign someone to check the label inventory on a periodic basis and replenish the label inventory well before it runs low. The cost of a few extra labels is far outweighed by the potential results of a missing label.
Have an easy-to-use DuraLabel label printer readily available, along with RTK labeling supplies, so that labels not in the inventory can be quickly made. In some circumstances, to ensure the information on the label is accurate, making new labels may be limited to trained staff. If so, ensure there is a backup so that someone is available whenever labels are needed.
Have group leaders or supervisors monitor labeling as a part of their daily routine. As they walk around a facility one of the things they should be looking for are unlabeled containers.
Ensuring all secondary containers are properly labeled is half the battle, also train every employee so they are familiar with RTK labels and can easily understand the information on the label.
OSHA labeling requirements are given in 29 CFR part 1910.1200, subpart Z – the Toxic and Hazardous Substances, Hazard Communication standard. It is available on the OSHA web site at: http://www.osha.gov/
