4.3 GHS Labels, Signal Words & 9 GHS Pictograms

4.3 GHS Labels, Signal Words & 9 GHS Pictograms

The 6 Mandatory Shipped Container Label Elements

Under 29 CFR 1910.1200(f)(1), chemical manufacturers, importers, and distributors must ensure that every container of hazardous chemicals leaving the facility is labeled, tagged, or marked with six mandatory GHS label elements:

1. Product Identifier: The unique chemical name, code number, or batch number matching the product identifier listed on the Safety Data Sheet (SDS) and the written chemical inventory list.
2. Signal Word: A standardized single word used to indicate the relative degree of hazard severity:
   • "Danger": Reserved for severe hazard categories (e.g., Flammable Liquid Category 1, Acute Toxicity Category 1, Carcinogenicity Category 1A).
   • "Warning": Reserved for less severe hazard categories (e.g., Flammable Liquid Category 3, Eye Irritation Category 2A).
   • Mandatory Priority Rule: If a chemical presents multiple hazards where one hazard warrants "Danger" and another warrants "Warning", only "Danger" appears on the container label.
3. Hazard Statement(s): Standardized, assigned phrases describing the nature and degree of the hazard (e.g., "Fatal if swallowed", "Highly flammable liquid and vapor", "May cause cancer by inhalation").
4. Precautionary Statement(s): Standardized phrases describing recommended measures to minimize or prevent adverse effects resulting from exposure, improper handling, or storage. These are grouped into four sub-categories: Prevention (e.g., "Keep away from heat/sparks/open flames"), Response (e.g., "IF SWALLOWED: Immediately call a POISON CENTER"), Storage (e.g., "Store locked up in a well-ventilated place"), and Disposal (e.g., "Dispose of contents in accordance with local regulations").
5. Pictogram(s): Graphic symbols depicting specific hazard classifications. GHS pictograms must feature a black hazard symbol set against a white background, enclosed within a red square set at a point (diamond) border.
   • Prohibition: OSHA strictly prohibits shipped container labels from displaying blank red diamonds without a black symbol.
6. Supplier Identification: The name, full street address, and U.S. telephone number of the chemical manufacturer, importer, or responsible party.

Detailed Breakdown of the 9 GHS Pictograms

OSHA recognizes 9 standard GHS pictograms. Under 29 CFR 1910.1200, 8 pictograms are mandatory under federal OSHA enforcement. The Environment pictogram is non-mandatory because aquatic toxicity falls under EPA statutory authority.

Workplace / Secondary Container Labeling (29 CFR 1910.1200(f)(6))

When chemicals are transferred from original manufacturer-shipped containers into workplace secondary containers (such as spray bottles, dip tanks, day tanks, or squeeze bottles), employers are responsible for container labeling. Under 29 CFR 1910.1200(f)(6), employers may choose one of two compliant options:

1. Full GHS Label Replication: Affix a secondary label containing all 6 mandatory GHS shipped container elements.
2. Alternative Workplace Labeling System: Utilize an alternative system (such as NFPA 704 diamond placards, HMIS color bars, or customized company labels) PROVIDED that:
   • The product identifier matches the SDS and chemical inventory list.
   • The label provides words, pictures, symbols, or a combination thereof that supply at least general physical and health hazard warnings.
   • Employees are fully trained on the specific hazard warnings and symbols used in the alternative system.

Immediate-Use Secondary Container Exemption (29 CFR 1910.1200(f)(8))

Under 29 CFR 1910.1200(f)(8), employers are NOT required to label portable secondary containers into which hazardous chemicals are transferred from labeled containers, provided all three of the following statutory conditions are met:

1. The portable container is intended ONLY for the immediate use of the employee who performs the transfer;
2. The chemical is used exclusively within that employee's work shift; AND
3. The container remains under the exclusive control of the transferring employee at all times.

EXAM ALERT: If the employee leaves the work area, leaves the portable container unattended, hands the container to a co-worker, or fails to consume all chemical contents before the shift ends, the immediate-use exemption is forfeited, and a compliant secondary container label must be attached immediately.