Following the release of the revised Hazard Communication Standard (HCS) by the Occupational Safety and Health Administration (OSHA) in May 2024, understanding the requirements for hazardous chemical labels in the U.S. has become critical. Below, we outline key elements and updates to note for these labels.
1. Label Elements for U.S. Hazardous Chemicals
1) Product identifier
The product identifier refers to the name or code used on the hazardous chemical label or Safety Data Sheet (SDS) (e.g., chemical name, code, or batch number). It uniquely identifies the chemical to users. This identifier facilitates cross-referencing between labels, SDSs, and the hazardous chemical inventory required in written hazard communication plans. Importantly, the product identifier on the label must match the one on the SDS.
2) Signal word
A signal word indicates the relative severity of hazards and alerts readers to potential risks. Under HCS, the signal words are "Danger" and "Warning":
- "Danger" is used for more severe hazard categories.
- "Warning" is used for less severe categories.
If "Danger" applies, "Warning" should not appear on the label.
3) Hazard statement(s)
The text of all applicable hazard statements shall appear on the label, except as otherwise specified. The information in italics shall be included as part of the hazard statement as provided. For example: ‘‘causes damage to organs (state all organs affected) through prolonged or repeated exposure (state route of exposure if no other routes of exposure cause the hazard)’’. Hazard statements may be combined where appropriate to reduce the information on the label and improve readability, as long as all of the hazards are conveyed as required.
If the chemical manufacturer, importer, or responsible party can demonstrate that all or part of the hazard statement is inappropriate to a specific substance or mixture, the corresponding statement may be omitted from the label.
4) Precautionary statement(s)
Precautionary statement means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling.
5) Pictogram(s)
Pictogram means a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are designated under this standard for application to a hazard category. Although there are 9 GHS pictograms, OSHA only specifies 8, among which environmental pictograms are not mandatory.
Pictograms shall be in the shape of a square set at a point and shall include a black hazard symbol on a white background (Figure 1) with a red frame sufficiently wide to be clearly visible. A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label.
If the skull and crossbones pictogram is included, the exclamation mark pictogram shall not appear where it is used for acute toxicity. If the corrosive pictogram is included, the exclamation mark pictogram shall not appear where it is used for skin or eye irritation. If the health hazard pictogram is included for respiratory sensitization, the exclamation mark pictogram shall not appear where it is used for skin sensitization or for skin or eye irritation.
6) Name, U.S. address, and U.S. telephone number of the chemical manufacturer, importer, or other responsible party
2. Small container labelling
For a container less than or equal to 100 ml capacity, the chemical manufacturer, importer, or distributor must include, at a minimum, the following information on the label of the container:
- Product identifier;
- Pictogram(s);
- Signal word;
- Chemical manufacturer’s name and phone number; and
- A statement that the full label information for the hazardous chemical is provided on the immediate outer package.
For a container less than or equal to 3 ml capacity, where the chemical manufacturer, importer, or distributor can demonstrate that any label interferes with the normal use of the container, no label is required, but the container must bear, at a minimum, the product identifier.
For all small containers covered above, should use the full label information in the immediate outer package. A statement that the small container(s) inside must be stored in the immediate outer package bearing the complete label when not in use.
3. Label Updates
- Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information. For chemicals that have been released for shipment and are awaiting future distribution, chemical manufacturers, importers, distributors, or employers have the option not to relabel those containers; however, if they do not relabel the containers, they must either provide the updated label for each individual container with each shipment or, with the agreement of the receiving entity, transmit the labels by electronic or other technological means.
- If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.
4. Label size
There is no specified minimum size for the labels or pictograms in the US, but the text must be legible, sections separated, and elements must not overlap. Manufacturers or suppliers must put a GHS-compliant label on all primary chemical containers – in other words, the ones used for distribution.
