Miller Engineering is often asked to evaluate chemical product literature against mandatory regulations and consensus standards. The most applicable mandatory standard for industrial chemicals is often OSHA’s Hazard Communication Standard 29CFR1910.1200. OSHA is currently updating the Hazard Communication Standard for consistency with international standards.
We are staying on top of these changes, and continue to evaluate product literature to the most applicable standards and regulations for the time period. Further, we can help your company write product literature such as Material Safety Data Sheets (MSDS), Product Labels, & other technical documents.
Allow us to prepare or review your chemical product labels and Safety Data Sheets!!
OSHA HazCom Standard
The premiere standard for communicating hazards associated with chemicals found in the workplace is the Occupational Health and Safety Administration (OSHA) Hazard Communication Standard (HazCom) found in 29 CFR 1910.1200, which includes the following sections:
(b) scope and application;
(d) hazard determination;
(e) written hazard communication program;
(f) labels and other forms of warning;
(g) material safety data sheets;
(h) employee information.
Prior to the HazCom’s promulgation in the mid-1980’s, there was no national requirement that employees be provided information about the hazards associated with the chemicals they were handling, or instructions for remedial action to avoid or minimize the risk associated with those hazards.
ANSI Hazard Communication Standards
The American National Standards Institute has published the following standards, which are the primary consensus standards related to chemical hazard communication in the U.S.:
- American National Standard for Hazardous Industrial Chemicals – Precautionary Labeling (ANSI Z129.1)
- American National Standard for Hazardous Industrial Chemicals – Material Safety Data Sheets – Preparation (ANSI Z400.1)
ANSI Z129.1 provides recommendations for chemical label format, color, size, symbols,& wording. These aspects of a label are important in creating an effective warning that workers will heed.
ANSI Z400.1 provides guidelines for preparation of MSDS in a method that more closely resembles the Globally Harmonized System for Classification and Labeling of Chemicals (GHS; see reverse) than the current OSHA HazCom standard does.
Similar to the our evaluations to OSHA standards, Miller Engineering has established processes for comparing chemical product label and MSDS language with the ANSI guidelines.
Globally Harmonized System (GHS) for Classification & Labeling of Chemicals
The United Nations adopted the Globally Harmonized System for Classification & Labeling of Chemicals (GHS) in 2003. The purpose of the GHS was to provide hazardous chemical classification systems definitions and outline components to be included on hazardous chemical product labels providing the opportunity for consistency between countries and even within a given country.
A good example of inconsistency within a given country is the definition of a flammable liquid. The following agencies differ in their classification of flammable liquids: OSHA, National Fire Protection Association (NFPA), the Department of Transportation (DOT), the Consumer Product Safety Commission (CPSC), and ANSI in Z129.1. These flammable liquid definitions differ from those in other countries as well, such as Canada’s WHMIS and the EU’s definition. Harmonizing these definitions will provide interagency & intercountry consistency to the definition of flammable liquids by those entities that choose to adopt the GHS guidelines.
Countries and agencies are not required to adopt the GHS guidelines. It is up to each country, and each agency within that country, to determine if and when it will implement the GHS guidelines.
In the United States, OSHA is now working to incorporate the GHS guidelines into the HazCom. While it may take up to 10 years to implement, Miller Engineering will stay current on the progress and incorporate the changes into our analyses, evaluating literature to the regulations contemporary to the time period of exposure.
Other Agency Labeling Requirements
Depending on the type of packaging, method of exposure, and chemical properties of a hazardous chemical, additional product labeling may be required other than that specified by OSHA.
Agencies such as the Department of Transportation, the Environmental Protection Agency, and the Consumer Product Safety Commission all regulate aspects of product labeling.
Further there are consensus organizations such as the National Fire Protection Agency (NFPA) and the National Paint & Coatings Association (NPCA) provide guidelines for information to include on product labels.
Chemical Exposures – Miller Publications
- Miller, J.M. (2007). “Hazard Communication Compliance”, in Safety Engineering Handbook, American Society of Safety Engineers.
- Lehto, M.R., House, T.E. and Papastavrou, J.D. (2000). “Interpretation of Fuzzy Qualifiers by Chemical Workers,” International Journal of Cognitive Ergonomics, Vol. 4, No. 1, pp. 73-88.
- Lehto, M.R. (1998).“The Influence of Chemical Warning Label Content and Format on Information Retrieval Speed and Accuracy,”Journal of Safety Research, Vol. 29, No. 1, pp.1-14.
- Lehto, M.R. and House, T.E. (1997). “Evaluation of the Comprehension of Hazard Communication Phrases by Chemical Workers,” International Ergonomics Association 13th Triennial Congress, Tampere, Finland.
- Miller, J.M., Chaffin, D., Dinman, B., Smith, R. and Zontine, D. (1975). Psychomotor and Neuromuscular Changes in Workers Exposed to Inorganic Mercury. Journal of the American Industrial Hygiene Association, October.
- Miller, J.M. and Chaffin, D. (1973). Behavioral and Neurological Evaluation of Workers Exposed to Inorganic Mercury. (NIOSH Contract #5T01-0N00161-02).
- Miller, J.M., Chaffin, D., Dinman, B., Smith, R. and Zontine, D. (1973). An Evaluation of the Effects of Chronic Mercury Exposures on EMG and Psychomotor Functions (Final Report, NIOSH Contract #5T01-0N00161-02).