OSHA is now practicing theology with its latest interpretation concerning labeling requirements regarding the revised Hazard Communication standard (HCS 2012), 29 CFR 1910.1200.
5 milliliter vials, 50 milliliter bottles- Doesn’t make a difference to the theologians at OSHA- You MUST GET ALL THE REQUIRED INFORMATION ON THE LABEL ATTACHED TO THE VIAL!
In a letter of interpretation to the NIST– A division of the United States Department of Commerce- the High Priests at OSHA have made GHS labelling a matter of faith.
You can do it. You must do it. SOMEHOW.
Here’s what needs to be legible on the label on the 5 milliliter vial:
“Paragraph 1910.1200(f)(1) requires the chemical manufacturer, importer, or distributor to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following information: (1) a product identifier; (2) signal word; (3) hazard statement(s); (4) pictogram(s); (5) precautionary statement(s); and (6) the name, address, and telephone number of the responsible party.”
Here’s OSHA’s Offical Lable Layout. On my screen it measures 150% taller than the vial, and it is basically illegible, and the manufacturer name and address fields have been abridged to two words :
No mention of recognizing the hazards of placing a big long fold out label on a tiny vial of a hazardous substance. No consideration for the fact that perhaps a paper label might in fact react with the contents of the small contqiner in case of contact.
Nope, For the theologians at OSHA it is just DO AS WE SAY TO because that is how it is printed in the SCRIPTURE of Paragraph 1910.1200(f)(1).
It’s a matter of faith. Not critical thinking.
Blind, authoritarian faith.
This regulation is literally impossible for my company to follow. In fact, the addition of a tag could actually make it more hazardous when working with the product (increasing spilling). I am all for alerting hazards, but can someone tell me WHY we can not just label the container holding 2 mL individual bottles?!?
Obey the Bureaucrats. That is the only “logic” I can find. My sympathies.
US’s requirement is insane. GHS labelling for small containers are a lot easier to comply.