Overview
Commercial containers must be labeled in ENGLISH and with the following:
- Product Identifier/Chemical name
- Signal Word
- Hazard Statement(s)
- Pictogram(s)
- Precautionary Statements
- Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party
Manufacturers’ labels must not be removed or defaced while containing original product.
If a chemical substance is produced for another user outside of UNL, it must be labeled as described above.
In accordance with OSHA’s HazCom and Laboratory Standards, chemical manufacturers/suppliers are required to provide labels that contain the information listed in the overview. This requirement evolves from the recent revisions to the OSHA HazCom standard. There was a phase-in period, and although manufacturers/suppliers did not have to come into full compliance until June 1, 2015, some were issued extensions. So, you may see new and old-style labels for a while.
So, how does manufacturer’s labels figure into your role as an auditor? There are a couple of situations where this checklist item may be cited:
- If the manufacturer’s label has been defaced or removed from a non-waste, manufacturer/supplier container. In these situations, the recommendation should be to obtain a replacement label from the supplier.
- There is also a nuance in the Laboratory Standard that is easily overlooked. If a chemical substance is shipped off-site by a commercial carrier, it must be labeled as if it were a manufacturer’s container. An example would be a laboratory that synthesizes a chemical and sends it to another laboratory for efficacy testing. The key here is whether the material is shipped off-site to a non-UNL site for use by someone other than the preparer. It is not intended to apply to inter-UNL transfers.