Search

New GHS Labels vs. DOT Labels

Posted on 7/31/2012 by James Griffin

Q. I have a 55-gallon drum of a flammable chemical that I plan to ship to a customer. I know I am required to have a GHS label on the outside, as well as DOT markings and labels. I was told that the flame pictogram on the GHS label cannot be on the drum since there is already a Flammable Liquid label as required by the DOT. Is this true?
 
A. You are correct. This is a case of overlapping regulations.
 
The Occupational Safety and Health Administration (OSHA) recently added the Globally Harmonized System (GHS) to its Hazard Communication Standard. As such, all hazardous chemicals that will be transported must be labeled with new GHS labels. There will be a small transition period (until June 1, 2015), but most employers are already phasing in the new system.
 
GHS labels are required to have four pieces of information on them: a signal word, hazard statements, precautionary statements, and a pictogram. The full text of these requirements can be found at 29 CFR 1910.1200, Appendix C.
 
While some of the pictograms are exclusive to GHS, many of them have the same appearance as DOT pictograms. For instance, here is the mentioned flame pictogram that goes on your GHS labels.
GHS HazCom Label for Flammable liquid

 

Under the Department of Transportation’s (DOT) hazardous materials regulations, all shipments of hazmat must have certain hazmat markings and labels placed on packages. They include, but are not limited to, marking the Proper Shipping Name, identification number, name and address, and affixing hazard labels. [49 CFR 172, Subparts D and E] For instance, here is the Flammable Liquid label.
Hazmat Shipping Label for Class 3 Flammable Liquid

Avoid Labeling Confusion
As part of the rollout of the GHS rule, OSHA explicitly forbids a package from having a GHS pictogram when the package is already required to have a DOT hazmat label.
 
“Where a pictogram required by the Department of Transportation under Title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in C.4 for the same hazard shall not appear.” [29 CFR 1910.1200, Appendix C.2.3.3]
 
OSHA addresses its comments as to why it is prohibiting the GHS pictogram in this specific scenario in the Federal Register that announced the final GHS rule.
 
“The reason it is mandatory is that having two different pictograms addressing the same hazard may lead to confusion for people handling the chemical.” [77 FR 17728, March 26, 2012]
 
Prepare your facility for a seamless transition to the new labeling standards with Lion’s online OSHA training. Material handlers will learn to recognize new labels, pictograms, and Safety Data Sheets (SDS) in the Hazard Communication Online Course. All employees must be trained by December 1, 2013.
 

Tags: GHS, HazCom, hazmat shipping, marks and labels, osha

Find a Post

Compliance Archives

Lion - Quotes

I can't say enough how pleased I was with this course! Everything finally makes sense.

Kim Graham

Lab Manager

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!

Stephanie Weathers

SHE Specialist

Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.

Dorothy Rurak

Environmental Specialist

The instructor was very very informative, helpful, understandable and pleasant. This course answered many questions I had, being new to this industry.

Frances Mona

Shipping Manager

This is the best RCRA training I've experienced! I will be visiting Lion training again.

Cynthia L. Logsdon

Principal Environmental Engineer

The instructor created a great learning environment.

Avinash Thummadi

CAD & Environmental Manager

Lion was very responsive to my initial questions and the website was user friendly.

Michael Britt

Supply Chain Director

Download Our Latest Whitepaper

Four key considerations to help you maximize the convenience and quality of your experience with online training.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.