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Hazard Communication for Ink Manufacturers

The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

2021 OSHA Proposed Hazard Communication Rule

OSHA is proposing significant changes to the Hazard Communication Standard – 29CFR 1910.1200.

The Final Rule incorporating the Globally Harmonized System for Classification and Labeling of Chemicals (GHS) into the OSHA Hazard Communication Standard (29 CFR 1910.1200) was published in the Federal Register on March 26, 2012. OSHA adopted Revision 3 (2009) in the  Final Rule.

The integration of the Globally Harmonized System into the OSHA Hazard Communication Standard (29CFR1910.1200) substantially revised the physical and health hazard classification procedures – Appendices A and B of the Standard. It is important to note that the majority of the regulatory basis for the standard has not changed. OSHA still requires “potential for exposure” under the Scope and Application (29CFR1910.1200(b)) of the Hazard Communication Standard. Specifically, this section of the rule indicates that: “This section applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.” There are numerous OSHA compliance interpretations and guidance based on this section:

The OSHA Hazard Communication requirements covering trade secrets and confidential business information remain largely unchanged from pre-GHS HazCom. Chemical name, substance identification number, and exact weight percentage belong to trade secrets if the claim that the information withheld is a trade secret can be supported. Prior approval from OSHA is not required.

All hazards must be disclosed. If confidential business info is claimed and withheld from SDSs, it must be indicated as trade secrets in SDSs.
However, under GHS different competent authorities (geographic regions) are empowered to make their own provisions to protect confidential business info in SDSs or on labels as long as such provisions do not compromise the health and safety of workers and consumers. This page provides a summary.

The HCS applies to any hazardous chemical* present in the workplace in a manner that employees may be exposed under normal conditions of use and foreseeable emergencies.(page 8 of 2015 Compliance Instruction)

2015 Compliance Instruction for enforcement of the Hazard Communication Standard

Use of DOT Placards for HazCom Pictogram Compliance
Of particular interest in this new compliance, instruction is the clarification/confirmation that the US DOT Placards that contain hazard symbols meet the HazCom pictogram requirements (page 48 of the compliance instruction).

*Hazardous chemical means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified

  • Printer: EPSON Model GP-C831
    Label Material: Flextuff IJ-430 Synthetic Paper, BS5609 compliant. Contact Person (For Both): Ron Hicks, Tel: 1-800-843-4242, ext. 117
  • Zebra 105sl (small label printer); Zebra ZT420 (large label printer)Both are typical black thermal printers. So we will have the GHS red diamonds pre-printed on our labels and black out those that we don’t need. ZEBRA ZT420 Thermal Printer (single color)
  • We are using our existing black and white laser printers as we are going with the preprinted diamonds and blocking out unused ones as recommended by Denise Deeds. When we were looking at printing the diamonds on-demand we were looking at a Cannon color printer. We worked with Cannon to reduce the speed to handle label stock. Speed and heat were issues we ran into. Note this is all relative to our sheet-fed (8.5X11) label stock. We never found a good color solution for roll-fed stock.