(10) Labeling
10.1 - OSHA Requirement
With respect to labels and MSDSs, employers shall ensure that labels on incoming containers of hazardous chemicals are not removed or defaced; employers shall maintain any MSDSs that are received with incoming shipments of hazardous chemicals, and ensure that they are readily accessible to laboratory employees.
The following provisions shall apply to chemical substances developed in the laboratory:
a. If the composition of the chemical substance which is produced exclusively for the laboratory's use is known, the employer shall determine if it is a hazardous chemical [as defined in section 2]. If the chemical is determined to be hazardous, the employer shall provide appropriate training as required [see sections 11 and 15].
b. If the chemical produced is a byproduct whose composition is not known, the employer shall assume that the substance is hazardous and shall implement [the applicable portion of the CHP].
c. If the chemical substance is produced for another user outside of the laboratory, the employer shall comply with the OSHA Hazard Communication Standard 29 CFR 1910.1200, including the requirements for preparation of MSDSs and labeling.
10.2 - Additional Information from ACS [35]
OSHA's stated purpose is to have labels serve only as an immediate warning and
a reminder that more detailed information is available elsewhere. Employees
already should be aware that they are working with hazardous chemicals through
in-house training programs. These programs will have informed employees of the
nature of the hazards present in their workplace and of the availability of
MSDSs as their principal source of information. When a chemical has several
potential hazards, all of them need to be listed unless the substance is in
a physical state that does not allow exposure to occur (e.g. physically bound).
Labels may use symbols, pictures, and/or words to present their message.
10.3 - Chemistry Department Implementation of the OSHA Labeling Requirement [36]
a. If the substance is a commercial product in its original container, the manufacturer's label should not be removed or defaced. A label must contain the manufacturer's name, substance's chemical name, and appropriate hazard warnings. Common hazard designations are "carcinogen," "corrosive," "irritant," "sensitizer," and "toxic" - any of these properties warrant a hazard warning on the label.
b. Large containers of stored chemicals, no matter what the source, must be labeled with the same information as above, i.e. name and hazards.
c. If the lab area is accessed only by authorized trained workers, chemicals may be transferred to temporary containers that are labeled simply with an identifying name, formula, or abbreviation. Note that such practice requires unsupervised cleaning staff not be admitted to the lab.
d. For unstable substances that must be tested after a period of storage, such as ethers for peroxide formation, it is important to note on the label the date the container was initially opened. Date-labeling is discussed in Section 7.
e. New chemical substances [37]i. The PI is responsible for ensuring that newly synthesized chemicals are used within his or her own lab (or that of a University colleague) and are properly labeled.
ii. If the substance is to be transferred off-campus, the PI must comply with the University Hazard Communication Right-to-Know Program, including labeling and insofar as possible preparation of the MSDS.
iii. An abbreviation system coded to a notebook or other reference may be used for labels on small containers of newly synthesized chemicals. Large containers should be labeled as described earlier in this section.
iv. If the hazards of a substance produced in the lab are unknown, the substance must be assumed to be hazardous. The PI should develop a preliminary MSDS at the earliest opportunity, and add to it as properties of the substance become known (see Section 9 ).
v. Newly synthesized chemicals may be subject to the requirements of the EPA Toxic Substances Control Act (TSCA) 40 CFR 700 [38]. Chemical substances manufactured solely for non-commercial research and development purposes are exempt from TSCA reporting requirements unless their production is for eventual commercial purposes. TSCA requires that notification of health and safety hazards for chemical substances used for research must be made to all persons handling the chemical, particularly if the chemical is sent to another laboratory on or off campus. Contact the Department of Environmental Health and Safety CHO for specific requirements.
10.4 - Chemistry Department Implementation of the OSHA MSDS Requirement (see Section 9)
References:
[35] ACS OSHA Hazard Communication Standard.
[36] Adapted from the UIUC and the Stanford CHPs.