HazCom Labeling Alternative Method
Hello,
I am curious about 1910.1200(f)(7) and the use of an alternative method to identify chemicals in secondary containers that employees are using at their workstations. I've scoured the Safety Knights archives and there seems to be differing opinions on what an acceptable alternative method might be.
In this thread,
https://www.safetyknights.com/post/612e25517173c7001837a8a8/in_house_system_for_labeling_chemicals
, @Drew Hinton says that having a color-coded bottle system with a master sheet containing the chemical information at each workstation would not be compliant. In looking at other threads, some members seem to be using that exact identification system at their workplace or something similar.
I understand that the wording of 1900.1200(f)(6) indicates that the container should be labeled with certain elements, but in what situation would the statement in 1910.1200(f)(7) "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" apply and what would an acceptable alternative be?
Same old story, my employer is currently using a color-coded system like the one in the above posted thread. I am trying to get them to label the individual bottles, but the label always gets destroyed from the chemicals themselves. Just trying to better understand any possible alternative method.
Thanks
Comments (2)
1910.1200(f)(7) does not apply to portable secondary containers (e.g., bottles) - it only applies to STATIONARY process containers (e.g., aboveground storage tanks (ASTs), blenders, etc.). The correct part of the standard that applies to portable secondary containers is 1910.1200(f)(6) only - not (f)(7).
With that being said, whatever labeling system you use would need to convey the "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." This means you can create your own internal/company labeling, use the HMIS system (which is pretty outdated), or another similar system. I would not recommend using the NFPA 704 marking system since that doesn't convey the same message as OSHA's HazCom labeling requirements (NFPA 704 only conveys the hazards when it's involved in a fire or other similar emergency - not for normal, occupational use).
Regarding 1910.1200(f)(7), I've seen it done a few different ways. More commonly, on aboveground storage tanks, for example, I've seen companies create custom signs/labels to put on the tank (typically near the hatch/cover/openings. At a previous chemical manufacturer I worked at, at our blender (2-story chemical mixing blender), we'd put signage on it, but would also put batch tickets and our SOPs (that had chemical info in it) at the top of the blender where they dumped the materials in.
We use color coded bottles with labels that are meant to handle oily environments. And consistently bring up that containers must be functional, have a label, and that label has to be legible. And we have a nonconforming shelf to put ones that aren't compliant. It has worked pretty well.