OSHA’s required pictograms must be in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame sufficiently wide enough to be clearly visible. A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label. OSHA has designated eight pictograms under this standard for application to a hazard category.
OSHA requires eight of the nine possible GHS pictograms to be used in communicating hazards. The ninth pictogram, Environmental, is under the jurisdiction of the Environmental Protection Agency in the United States.
The revised HCS changes the existing Hazard Communication Standard from a performance-based standard to one that has more structured requirements for the labeling of chemicals. The revised standard requires that information about chemical hazards be conveyed on labels using quick visual notations to alert the user, providing immediate recognition of the hazards. Labels must also provide instructions on how to handle the chemical so that chemical users are informed about how to protect themselves.
Labels: Employer Responsibilities
Employers are responsible for maintaining the labels on the containers, which include, but are not limited to, tanks, totes and drums. This means that labels must be maintained on chemicals in a manner that continues to be legible and so that the pertinent information (such as the hazards and directions for use) does not get defaced (e.g., fade or get washed off) or removed in any way.
The employer is not responsible for updating labels on shipped containers, even if the shipped containers are labeled under HazCom 1994. The employer must re-label items if the labels are removed or defaced. However, if the employer is aware of newly-identified hazards that are not disclosed on the label, the employer must ensure that the workers are aware of the hazards as discussed below under workplace labels.
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