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Chemical Labels: Frequently Asked Questions


There are various chemical labeling systems. Some of the popular classification systems are:

GHS Labels: GHS labels communicate chemical hazards to workers or recipients through signal words, pictograms, hazard statements, and precautionary statements. These are required by the Occupational Safety and Health Administration’s (OSHA's) Hazard Communication Standard.

DOT Labels: Department of Transportation Hazard Class Labels are part of an international system that alerts emergency responders to the presence of dangerous materials in transit.

NFPA Labels: These labels contain hazard ratings on an NFPA diamond which help firefighters and emergency responders identify chemical hazards concerned with burning, spilling, or exploding.

HMIS Labels: This labeling system uses the color bar format and a rating system developed by the National Paint and Coatings Association. The four bars are blue for health, red for flammability, orange (replacing yellow) for physical hazard, and white for personal protection. The number ratings range from 0 – 4.


As per OSHA 1910.1200(f)(1), there are 6 main sections of a GHS Label:

1. Product Identifier: This must include the name of the chemical, UN number, CAS number, etc.

2. Signal Word: Words such as ‘Danger’ or ‘Warning’ indicate the relative level of hazard’s severity.

3. Pictograms: Any of the 9 diamond-shaped pictograms to convey specific hazard information.

4. Hazard Statement: A phrase assigned to the hazard class that describes the nature of the hazards.

5. Precautionary Statement: Describes/recommends measures to minimize or prevent adverse effects from exposure to the chemical. (e.g., keep the container tightly closed)

6. Supplier Identification: Must include the manufacturer or supplier's name, address, and contact information.


29 CFR 1910.1200, OSHA’s Hazard Communication Standard requires GHS labels on each container of hazardous chemicals leaving the workplace.

49 CFR 172.400 requires Department of Transportation (DOT) Labels on packages or containers used in transporting hazardous materials.

While the DOT labels are required outside shipping containers carrying chemicals, chemicals in smaller containers inside the larger shipping container require GHS labels and not DOT labels. In some international trade situations, both DOT and GHS labels are required on the exterior of shipped containers.

OSHA forbids a package from having a GHS pictogram when the package is already required to have a DOT label for the same hazard [ Letter Of Intent (LOI) issued by OSHA on December 20, 2012]. This is because having two different pictograms addressing the same hazard may lead to confusion for chemical handlers.


Common OSHA citations regarding the Hazard Communication Standard (29 CFR 1910.1200) are:

* Not developing and maintaining a written program

* Not having safety data sheets (SDS) for all chemicals

* Failure to maintain the workplace copies of the required Safety Data Sheets

* Lack of employee training

* Failure to mark/label each container of hazardous chemicals in the workplace

* Deficiencies related to secondary container labels


Labs can avoid OSHA citations related to chemical labeling in the following ways:

* Incoming containers must have GHS labels with the identity of the chemical(s), appropriate pictograms, a signal word, and hazard and precautionary statements. Labels on incoming containers of hazardous chemicals must not be removed or damaged.
* Using GHS labels for secondary containers made in-house must also include the identity of the hazardous chemical(s) and pictograms. Alternative means of labeling, such as wall posters or reference charts that communicate necessary hazard information, can also be used.
* Preparing and maintaining a current chemical inventory and filing all current SDSs for all inventoried chemicals, making them accessible to employees. Electronic SDSs may be allowed in some cities instead of paper copies.
* Providing proper training to the workers handling chemicals. This includes conveying the physical and health hazards of chemicals in the work area, and the telling about the measures employees can take to protect themselves from these hazards; the location of the written plan, inventory, and SDS; and an explanation of the SDS and labeling systems.
* Laboratories that ship hazardous chemicals are regarded as chemical manufacturers or distributors and are required to label any hazardous chemical container leaving the laboratory. A safety data sheet is provided to distributors and other employers.


While most chemicals are required to be labeled by the Occupational Health and Safety Administration, some chemicals (OSHA 1910.1200(b)(6)) are exempt from the HCS because separate government agencies regulate them. These include:

* Wood and wood products (except wood dust)
* Regulated hazardous waste
* Tobacco products
* Food
* Drugs
* Cosmetics
* Alcoholic beverages
* Agricultural or vegetable seed treated with pesticides
* Certain pesticides specified & regulated by the EPA
* Certain nuisance particulates


The HMIS (Hazardous Materials Identification System) was created by the National Paint & Coatings Association (NPCA), now known as the American Coatings Association (ACA), to help employers comply with OSHA's Hazard Communication (HCS), 29 CFR 1910.1200, which now requires Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

The HMIS is not mandatory, but HMIS labels can be used as supplemental information. In fact, the ACA has given exclusive rights for this optional system to a handful of vendors. Many organizations discourage using HMIS labels against the GHS labeling system, which is mandatory, open, and freely available.

OSHA also confirms that SDS authors may include HMIS rating systems on labels and in the SDS so long as the ratings in the HMIS label do not contradict or cast doubt on the validity of label information required by OSHA or hinder the employees' ability to identify a chemical correctly.


A hazardous chemical may be packaged in multi-layer packaging in which the inner packaging requires GHS Labels. Outer packages may also need a GHS-compliant chemical label in case of single packaging such as drums.

As such, there are no guidelines on the placement of the labels. As a good practice, GHS labels must be applied at a conspicuous position on a bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical.
GHS labels are required on the original container labels. The downstream users of these chemicals are also required to put GHS labels when transferring chemicals to secondary containers like spray bottles, jugs, or jars.

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