When the Hazard Communication Standard was updated in 2012, the burden of providing chemical hazard labeling was shifted from employers to the manufacturers and distributors of hazardous chemical products. Previously, employers had to supplement manufacturer labels to indicate hazard warnings for health, fire, reactivity and special hazards, along with a notation of the name of the product and an indication of the target organs. After December 1, 2015, manufacturers will have to ship products with a compliant label that includes pictograms, hazard statements, etc.
For the rare circumstances in which the manufacturer label is not on a container, the employer will have to provide workplace labeling. A common example of this situation is when an employer orders a large bottle of a product (such as isopropyl alcohol), and then pours it into smaller containers/pumps/dispensers for use throughout the workplace.
The standard defines workplace labeling as:
Product identifier and 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.
For more information on how to accomplish workplace labeling when it is required, refer to the article in the December 2015 issue of the American Practice Advisor.