BRIEF

Hazard Communication Standard: Labels and Pictograms

OSHA has adopted new hazardous chemical standard also requires the use of a 16-section
labeling requirements as a part of its recent safety data sheet format, which provides
revision of the Hazard Communication detailed information regarding the chemical.
Standard, 29 CFR 1910.1200 (HCS), bringing There is a separate OSHA Brief on SDSs
it into alignment with the United Nations that provides information on the new SDS
Globally Harmonized System of Classification requirements.
and Labelling of Chemicals (GHS). These
changes will help ensure improved quality and All hazardous chemicals shipped after June1,
consistency in the classification and labeling 2015, must be labeled with specified elements
of all chemicals, and will also enhance worker including pictograms, signal words and hazard
comprehension. As a result, workers will and precautionary statements. However,
have better information available on the safe manufacturers, importers, and distributors
handling and use of hazardous chemicals, may start using the new labeling system in the
thereby allowing them to avoid injuries and revised HCS before the June1, 2015 effective
illnesses related to exposures to hazardous date if they so choose. Until the June 1, 2015
chemicals. effective date, manufacturers, importers and
distributors may maintain compliance with
The revised HCS changes the existing Hazard the requirements of HazCom 1994 or the
Communication Standard (HCS/HazCom 19941) revised standard. Distributors may continue
from a performance-based standard to one to ship containers labeled by manufacturers
that has more structured requirements for the or importers (but not by the distributor
labeling of chemicals. The revised standard themselves) in compliance with the HazCom
requires that information about chemical 1994 until December 1, 2015.
hazards be conveyed on labels using quick
visual notations to alert the user, providing This document is designed to inform chemical
immediate recognition of the hazards. Labels receivers, chemical purchasers, and trainers
must also provide instructions on how to about the label requirements. It explains the
handle the chemical so that chemical users are new labeling elements, identifies what goes on
informed about how to protect themselves. a label, and describes what pictograms are and
how to use them.
The label provides information to the workers
on the specific hazardous chemical. While Label Requirements
labels provide important information for Labels, as defined in the HCS, are an
anyone who handles, uses, stores, and appropriate group of written, printed or
transports hazardous chemicals, they are graphic informational elements concerning a
limited by design in the amount of information hazardous chemical that are affixed to, printed
they can provide. Safety Data Sheets (SDSs), on, or attached to the immediate container
which must accompany hazardous chemicals, of a hazardous chemical, or to the outside
are the more complete resource for details packaging.
regarding hazardous chemicals. The revised
The HCS requires chemical manufacturers,
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Prior to the 2012 update, the Hazard Communication importers, or distributors to ensure that each
Standard had last been amended in 1994. HazCom container of hazardous chemicals leaving the
1994 refers to the version of the Hazard Communi- workplace is labeled, tagged or marked with
cation Standard in effect directly prior to the 2012
revision, printed in the 1995 through 2011 versions of
the following information: product identifier;
the Code of Federal Regulations. It is also available on signal word; hazard statement(s); precautionary
OSHAs webpage. 1
 statement(s); and pictogram(s); and name, alert the reader to a potential hazard on
address and telephone number of the chemical the label. There are only two words used
manufacturer, importer, or other responsible as signal words, Danger and Warning.
party. Within a specific hazard class, Danger
is used for the more severe hazards and
Labels for a hazardous chemical must contain: Warning is used for the less severe
hazards. There will only be one signal
Name, Address and Telephone Number word on the label no matter how many
Product Identifier hazards a chemical may have. If one of
the hazards warrants a Danger signal
Signal Word
word and another warrants the signal word
Hazard Statement(s) Warning, then only Danger should
Precautionary Statement(s) appear on the label.
Pictogram(s)
Hazard Statements describe the nature
of the hazard(s) of a chemical, including,
To develop labels under the revised HCS, where appropriate, the degree of hazard.
manufacturers, importers and distributors For example: Causes damage to kidneys
must first identify and classify the chemical through prolonged or repeated exposure
hazard(s). Appendices A, B, and C are all when absorbed through the skin. All of
mandatory. The classification criteria for health the applicable hazard statements must
hazards are in Appendix A and the criteria for appear on the label. Hazard statements may
physical hazards are presented in Appendix be combined where appropriate to reduce
B of the revised Hazard Communication redundancies and improve readability.
Standard. After classifying the hazardous The hazard statements are specific to
chemicals, the manufacturer, importer or the hazard classification categories, and
distributor then consults Appendix C to chemical users should always see the same
determine the appropriate pictograms, statement for the same hazards no matter
signal words, and hazard and precautionary what the chemical is or who produces it.
statement(s), for the chemical label. Once this
information has been identified and gathered, Precautionary Statements describe
then a label may be created. recommended measures that should be
taken to minimize or prevent adverse effects
Label Elements resulting from exposure to the hazardous
The HCS now requires the following elements chemical or improper storage or handling.
on labels of hazardous chemicals: There are four types of precautionary
statements: prevention (to minimize
Name, Address and Telephone Number exposure); response (in case of accidental
of the chemical manufacturer, importer or spillage or exposure emergency response,
other responsible party. and first-aid); storage; and disposal. For
example, a chemical presenting a specific
Product Identifier is how the hazardous target organ toxicity (repeated exposure)
chemical is identified. This can be (but hazard would include the following on the
is not limited to) the chemical name, label: Do not breathe dust/fume/gas/mist/
code number or batch number. The vapors/spray. Get medical advice/attention
manufacturer, importer or distributor can if you feel unwell. Dispose of contents/
decide the appropriate product identifier. container in accordance with local/regional/
The same product identifier must be both national and international regulations.
on the label and in section 1 of the SDS.
A forward slash (/) designates that
Signal Words are used to indicate the the classifier can choose one of the
relative level of severity of the hazard and precautionary statements. In the example

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 above, the label could state, Do not it can demonstrate that the statement is
breathe vapors or spray. Get medical inappropriate.
attention if you feel unwell. Dispose of Supplementary Information. The
contents in accordance with local/regional/ label producer may provide additional
national/international regulations. See instructions or information that it deems
Examples 1 and 2A of this document as an helpful. It may also list any hazards not
example. otherwise classified under this portion of
the label. This section must also identify
In most cases, the precautionary the percentage of ingredient(s) of unknown
statements are independent. However, acute toxicity when it is present in a
OSHA does allow flexibility for applying concentration of 1% (and the classification
precautionary statements to the label, such is not based on testing the mixture as a
as combining statements, using an order of whole). If an employer decides to include
precedence or eliminating an inappropriate additional information regarding the
statement. chemical that is above and beyond what
the standard requires, it may list this
Precautionary statements may be information under what is considered
combined on the label to save on space supplementary information. There is also
and improve readability. For example, no required format for how a workplace
Keep away from heat, spark and open label must look and no particular format
flames, Store in a well-ventilated place, an employer has to use; however, it cannot
and Keep cool may be combined to read: contradict or detract from the required
Keep away from heat, sparks and open information.
flames and store in a cool, well-ventilated
place. Where a chemical is classified for a An example of an item that may be
number of hazards and the precautionary considered supplementary is the personal
statements are similar, the most stringent protective equipment (PPE) pictogram
statements must be included on the label. indicating what workers handling the
In this case, the chemical manufacturer, chemical may need to wear to protect
importer, or distributor may impose themselves. For example, the Hazardous
an order of precedence where phrases Materials Identification System (HMIS)
concerning response require rapid action pictogram of a person wearing goggles
to ensure the health and safety of the may be listed. Other supplementary
exposed person. In the self-reactive hazard information may include directions of use,
category Types C, D, E or F, three of the four expiration date, or fill date, all of which may
precautionary statements for prevention provide additional information specific to
are: the process in which the chemical is used.

Keep away from heat/sparks/open Pictograms are graphic symbols used
flame/hot surfaces. - No Smoking.; to communicate specific information
about the hazards of a chemical. On
Keep/Store away from clothing// hazardous chemicals being shipped or
combustible materials; transported from a manufacturer, importer
or distributor, the required pictograms
Keep only in original container. consist of a red square frame set at a point
with a black hazard symbol on a white
These three precautionary statements background, sufficiently wide to be clearly
could be combined to read: Keep in visible. A square red frame set at a point
original container and away from heat, without a hazard symbol is not a pictogram
open flames, combustible materials and and is not permitted on the label.
hot surfaces. - No Smoking.
The pictograms OSHA has adopted
Finally, a manufacturer or importer may improve worker safety and health, conform
eliminate a precautionary statement if with the GHS, and are used worldwide.

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 While the GHS uses a total of nine DOT requirements set forth in 49 CFR 172,
pictograms, OSHA will only enforce the use SubpartE. If a label has a DOT transport
of eight. The environmental pictogram is pictogram, Appendix C.2.3.3 states that the
not mandatory but may be used to provide corresponding HCS pictogram shall not
additional information. Workers may appear. However, DOT does not view the
see the ninth symbol on a label because HCS pictogram as a conflict and for some
label preparers may choose to add the international trade both pictograms may need
environment pictogram as supplementary to be present on the label. Therefore, OSHA
information. Figure1 shows the symbol intends to revise C.2.3.3. In the meantime,
for each pictogram, the written name the agency will allow both DOT and HCS
for each pictogram, and the hazards pictograms for the same hazard on a label.
associated with each of the pictograms. While the DOT diamond label is required for all
Most of the symbols are already used for hazardous chemicals on the outside shipping
transportation and many chemical users containers, chemicals in smaller containers
may be familiar with them. inside the larger shipped container do not
require the DOT diamond but do require the
Figure 1: Pictograms and Hazards OSHA pictograms. (See Example 2.)

Labels must be legible, in English, and

prominently displayed. Other languages
may be displayed in addition to English.
Chemical manufacturers, importers, and
distributors who become newly aware of any
significant information regarding the hazards
of a chemical must revise the label within six
months.

Employer Responsibilities
Employers are responsible for maintaining
the labels on the containers, including, but not
limited to, tanks, totes, and drums. This means
that labels must be maintained on chemicals in
a manner which continues to be legible and the
pertinent information (such as the hazards and
directions for use) does not get defaced (i.e.,
fade, get washed off) or removed in any way.

The employer is not responsible for updating

labels on shipped containers, even if the
shipped containers are labeled under HazCom
1994. The employer must relabel items if the
labels are removed or defaced. However, if
the employer is aware of newly-identified
hazards that are not disclosed on the label, the
employer must ensure that the workers are
aware of the hazards as discussed below under
It is important to note that the OSHA workplace labels.
pictograms do not replace the diamond-
shaped labels that the U.S. Department of Workplace Labels
Transportation (DOT) requires for the transport OSHA has not changed the general
of chemicals, including chemical drums, requirements for workplace labeling.
chemical totes, tanks or other containers. Employers have the option to create their own
Those labels must be on the external part workplace labels. They can either provide
of a shipped container and must meet the all of the required information that is on the

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label from the chemical manufacturer or, the information as discussed above. An employer
product identifier and words, pictures, symbols using NFPA or HMIS labeling must, through
or a combination thereof, which in combination training, ensure that its employees are fully
with other information immediately available aware of the hazards of the chemicals used.
to employees, provide specific information
regarding the hazards of the chemicals. If an employer transfers hazardous chemicals
from a labeled container to a portable
If an employer has an in-plant or workplace container that is only intended for immediate
system of labeling that meets the requirements use by the employee who performs the
of HazCom 1994, the employer may continue transfer, no labels are required for the portable
to use this system in the workplace as long container.
as this system, in conjunction with other
information immediately available to the Sample Labels
employees, provides the employees with The following examples demonstrate how
the information on all of the health and a manufacturer or importer may display
physical hazards of the hazardous chemical. the appropriate information on the label. As
This workplace labeling system may include mentioned above, once the manufacturer
signs, placards, process sheets, batch tickets, determines the classification of the chemical
operating procedures, or other such written (class and category of each hazard) using
materials to identify hazardous chemicals. Any Appendices A and B, it would determine the
of these labeling methods or a combination required pictograms, signal words, hazard
thereof may be used instead of a label from the statements, and precautionary statements
manufacturer, importer or distributer as long using Appendix C. The final step is to put the
as the employees have immediate access to information on the label.
all of the information about the hazards of the
chemical. Workplace labels must be in English. The examples below show what a sample
Other languages may be added to the label if label might look like under the revised HCS
applicable. requirements. The examples break the
labeling out into steps to show the order of
If the employer chooses to use the pictograms information gathering and how label creation
that appear in Appendix C on the workplace (or occurs. Step 1 is performing classification; step
in-plant) labels, these pictograms may have a 2 is gathering full label information; and step 3
black border, rather than a red border. is creating the label.

Employers may use additional instructional These examples are for informational
symbols that are not included in OSHAs purposes only and are not meant to represent
HCS pictograms on the workplace labels. An the only labels manufacturers, importers and
example of an instructional pictogram is a distributors may create for these hazards.
person with goggles, denoting that goggles
must be worn while handling the given
chemical. Including both types of pictograms
on workplace labels is acceptable. The same is
true if the employer wants to list environmental
pictograms or PPE pictograms from the HMIS
to identify protective measures for those
handling the chemical.

Employers may continue to use rating systems

such as National Fire Protection Association
(NFPA) diamonds or HMIS requirements
for workplace labels as long as they are
consistent with the requirements of the Hazard
Communication Standard and the employees
have immediate access to the specific hazard

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Example 1: This example demonstrates a Precautionary Statements:
simple label. Prevention:
Wash hands and face thoroughly after
The Substance: handling.
HS85 Do not eat, drink or smoke when using this
Batch Number: 85L6543 product.

Step 1: Perform Classification Response:

Class: Acute Oral Toxicity; Category 4 If swallowed: Call a doctor if you feel
unwell.2
Step 2: Gather Labeling Information Rinse mouth
Pictograms:
Storage:
None specified

Disposal:
Signal Word: Dispose of contents/container in
WARNING accordance with local/regional/national/
international regulations.3
Hazard Statements:
Harmful if Swallowed Step 3: Create the Label
Putting together the above information on HS85, a
label might list the following information:

Example 1: HS85 Label

HS85
Batch number: 85L6543

Warning
Harmful if swallowed

Wash hands and face thoroughly after handling. Do not eat, drink or smoke when using this
product. Dispose of contents/container in accordance with local, state and federal regulations.

First aid:
If swallowed: Call a doctor if you feel unwell. Rinse mouth.

GHS Example Company, 123 Global Circle, Anyville, NY 130XX Telephone (888) 888-8888

2
The manufacturer of this chemical determined that
calling a doctor was the most appropriate emergency
medical advice; therefore, it is listed as part of the
first-aid procedures.
3
The downstream users must familiarize themselves
with the proper disposal methods in accordance
with local, regional, state and federal regulations. It
is impractical to expect the label preparer to list all
potential regulations that exist.
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Example 2: This example demonstrates a Response:
more complex label. IF ON SKIN (or hair): Take off immediately
all contaminated clothing. Rinse skin with
Example 2 is for a substance that is a severe water.
physical and health hazard. For shipping IF ON CLOTHING: Rinse immediately
packages of chemicals that will be transported contaminated clothing and skin with plenty
in the United States (i.e., drums, totes, tanks, of water before removing clothes. Wash
etc.), the U.S. DOT requires a DOT label(s) contaminated clothing before reuse.
on the outside container(s) for hazardous IF IN EYES: Rinse cautiously with water for
chemicals. Two versions of this label are several minutes. Remove contact lenses, if
presented below to demonstrate the difference present and easy to do. Continue rinsing.
between an OSHA label with pictograms from IF INHALED: Remove person to fresh air
the HCS and a DOT label required for transport and keep comfortable for breathing.
of a shipping container. IF SWALLOWED: Rinse mouth. Do NOT
induce vomiting.
The Substance: Immediately call poison center.4
OXI252 (disodiumflammy)
CAS number: 111-11-11xx Specific Treatment:
Treat with doctor-prescribed burn cream.5
Step 1: Perform Classification
Class: Oxidizing Solid, Category 1 In case of fire:
Class: Skin Corrosive, Category 1A Use water spray. In case of major fire and large
quantities: Evacuate area. Fight fire remotely
Step 2: Gather Labeling Information due to the risk of explosion.
Pictograms:
Storage:
Store locked up.

Disposal:
Dispose of contents/container in
accordance with local/regional/national/
international regulations.
Signal Word:
DANGER
Step 3: Create the Label
Putting together the above information on OXI252,
Hazard Statements:
a label might list the following information:
May cause fire or explosion; strong oxidizer
Causes severe skin burns and eye damage

Precautionary Statements:
Prevention:
Keep away from heat.
Keep away from clothing and other
combustible materials.
Take any precaution to avoid mixing with
combustibles.
Wear protective neoprene gloves, safety
goggles and face shield with chin guard.
Wear fire/flame resistant clothing. 4
In this example, the manufacturer determined that
Do not breathe dust or mists. calling a poison control center is the most appropri-
Wash arms, hands and face thoroughly ate emergency medical advice.
after handling. 5
Not all SDSs will have direction for specific treat-
ment on the label. This is only if the manufacturer
specifically notes a certain treatment that needs to be
used to treat a worker who has been exposed to this
chemical.
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 Example 2A: OXI252 Label inner package label with OSHA pictograms
OXI252
(disodiumflammy)
CAS #: 111-11-11xx

Danger
May cause fire or explosion; strong oxidizer
Causes severe skin burns and eye damage

Keep away from heat. Keep away from clothing and other combustible materials. Take any precaution to avoid
mixing with combustibles. Wear protective neoprene gloves, safety goggles and face shield with chin guard. Wear
fire/flame resistant clothing. Do not breathe dust or mists. Wash arms, hands and face thoroughly after handling.
Store locked up. Dispose of contents and container in accordance with local, state and federal regulations.

First aid:
IF ON SKIN (or hair) or clothing6: Rinse immediately contaminated clothing and skin with plenty of water before
removing clothes. Wash contaminated clothing before reuse.
IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do.
Continue rinsing.
IF INHALED: Remove person to fresh air and keep comfortable for breathing.
IF SWALLOWED: Rinse mouth. Do NOT induce vomiting.
Immediately call poison center.
Specific Treatment: Treat with doctor-prescribed burn cream.
Fire:
In case of fire: Use water spray. In case of major fire and large quantities: Evacuate area. Fight fire remotely due to
the risk of explosion.

Great Chemical Company, 55 Main Street, Anywhere, CT 064XX Telephone (888) 777-8888

Example 2B: OXI252 Label meeting DOT requirements for shipping7

OXI252
(disodiumflammy)
CAS #: 111-11-11xx

Danger
May cause fire or explosion; strong oxidizer
Causes severe skin burns and eye damage

Keep away from heat. Keep away from clothing and other combustible materials. Take any precaution to avoid
mixing with combustibles. Wear protective neoprene gloves, safety goggles and face shield with chin guard. Wear
fire/flame resistant clothing. Do not breathe dust or mists. Wash arms, hands and face thoroughly after handling.
Store locked up. Dispose of contents and container in accordance with local, state and federal regulations.

First aid:
IF ON SKIN (or hair) or clothing: Rinse immediately contaminated clothing and skin with plenty of water before
removing clothes. Wash contaminated clothing before reuse.
IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do.
Continue rinsing.
IF INHALED: Remove person to fresh air and keep comfortable for breathing. Immediately call a doctor.
IF SWALLOWED: Rinse mouth. Do NOT induce vomiting.
Immediately call poison center.
Specific Treatment: Treat with doctor-prescribed burn cream.
Fire:
In case of fire: Use water spray. In case of major fire and large quantities: Evacuate area. Fight fire remotely due to
the risk of explosion.

Great Chemical Company, 55 Main Street, Anywhere, CT 064XX Telephone (888) 777-8888
6
There are occasions where label preparers may cautionary statements were combined for exposure
combine statements on the label. In this case the to skin, hair and clothing.
similar statements were combined and the most 8 7
DOT Labels must comply with the size require-
stringent were listed. For example, the first-aid pre- ments presented in 49 CFR 172.
For more detailed information about labels and
Safety Data Sheets (SDSs) under the revised Disclaimer: This OSHA Brief provides a
Hazard Communication Standard, please refer general overview of the label requirements
to refer to 29 CFR1910.1200 - paragraphs (f) and in the Hazard Communication Standard
(g), and Appendix C. (see 29 CFR1910.1200(f) and Appendix
C of 29 CFR1910.1200). It does not alter
The revised Hazard Communication Standard or determine compliance responsibilities
and additional guidance materials are in the standard or the Occupational
available on OSHAs Hazard Communication Safety and Health Act of 1970. Since
page, located at: www.osha.gov/dsg/hazcom/ interpretations and enforcement policy
index.html. may change over time, the reader should
consult current OSHA interpretations
and decisions by the Occupational Safety
and Health Review Commission and the
courts for additional guidance on OSHA
compliance requirements.

This is one in a series of informational briefs highlighting OSHA programs, policies or standards. It does
not impose any new compliance requirements. For a comprehensive list of compliance requirements
of OSHA standards or regulations, refer to Title 29 of the Code of Federal Regulations. This information
will be made available to sensory-impaired individuals upon request. The voice phone is (202) 693-1999;
teletypewriter (TTY) number: (877) 889-5627.

DSG BR-3636 2/2013