GHS and DOT Labels and Placards

GHS was developed by the United Nations, as a way to bring into agreement the chemical

regulations and standards of different countries. In short, it is an international attempt to get everyone on the same page. The hope is that every country will incorporate the tenets of the GHS into their

own chemical management systems with the goal of making the international sale and transportation

of hazardous chemicals easier, as well as, making workplace conditions safer for all employees

exposed to chemical hazards.

It is now part of your trainingThe DOT requires markings and labels, or in some cases placards, for packages holding “hazardous materials” before and during transportation. OSHA/OH&S/OH&S requires hazard labels for containers holding “hazardous chemicals” in the workplace. While both agencies have harmonized their regulations with international standards, there are some cases in which the two systems don’t match. Often, a given material may meet the definition of both a DOT hazardous material and an OSHA/OH&S/OH&S hazardous chemical. In the instances where the standards intersect, a shipped chemical may need both DOT and OSHA/OH&S/OH&S hazard communication. This often leads to confusion about how these communications should be displayed on the shipment.

Inside to it can say outsideOSHA/OH&S “Containers” Inside a DOT “Package” • Now that we have defined what DOT deems a package and what OSHA/OH&S

deems a container, we can discuss situations where the DOT and OSHA/OH&S hazard communication requirements may overlap.

• As a first example, let us examine a hazardous material/chemical contained in glass bottles that are then packed in a fiberboard box. Where would the DOT and OSHA/OH&S communications go?

• For DOT, the markings and labels would go onto the fiberboard box, because that is the final form that would be safe for shipment and would meet all DOT requirements. The glass bottles are too weak to be shipped without a protective barrier, so they are not DOT packages and would not get the DOT communication.

• Under OSHA/OH&S, the GHS labels would go onto the glass bottles rather than the box, because that is the container that an employee would work with. The employee needs the information immediately in case of an accident, and the bottle may be the most readily available container.

Over lap but still seperateFor DOT, the package is the steel drum, since that is considered a safe form in which it can be shipped. Thus, markings and labels would go onto the drum.

• Under OSHA/OH&S, the container is also the steel drum since that is the form in which an employee would foreseeably come in contact with the chemical. Thus, in this instance, the GHS labels would also go onto the drum.

• While DOT and OSHA/OH&S hazard communication requirements do overlap, recognizing the intent of each standard will help employees differentiate between the two sets of rules and better protect themselves from hazardous chemicals.

This just adds to the above training