Technical_Exhibit_1_-_Chemical_Labeling.pdf

Example 1: This example demonstrates a simple label.

The Substance:

HS85

Batch Number: 85L6543

Step 1: Perform Classification

Class: Acute Oral Toxicity; Category 4

Step 2: Gather Labeling Information

Pictograms:

Signal Word:

WARNING

Hazard Statements:

Harmful if Swallowed

Precautionary Statements:

Prevention:

Wash hands and face thoroughly after handling.

Do not eat, drink or smoke when using this product.

Response:

If swallowed: Call a doctor if you feel unwell.2

Rinse mouth

Storage:

None specified

Disposal:

Dispose of contents/container in accordance with local/regional/national/ international regulations.3

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.

Example 2: This example demonstrates a more complex label.

Example 2 is for a substance that is a severe physical and health hazard. For shipping packages of chemicals that will be transported in the United States (i.e., drums, totes, tanks, etc.), the U.S. DOT requires a DOT label(s) on the outside container(s) for hazardous chemicals. Two versions of this label are presented below to demonstrate the difference between an OSHA label with pictograms from the HCS and a DOT label required for transport of a shipping container.

The Substance:

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

Step 1: Perform Classification

Class: Oxidizing Solid, Category 1 Class: Skin Corrosive, Category 1A

Step 2: Gather Labeling Information Pictograms:

Signal Word:

DANGER

Hazard Statements:

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.

Do not breathe dust or mists.

Wash arms, hands and face thoroughly after handling.

Response:

IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water.

IF ON 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.

IF SWALLOWED: Rinse mouth. Do NOT induce vomiting.

Immediately call poison center.4

Specific Treatment:

Treat with doctor-prescribed burn cream.5

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.

Storage:

Store locked up.

Disposal:

Dispose of contents/container in accordance with local/regional/national/ international regulations.³

Step 3: Create the Label

Putting together the above information on OXI252, a label might list the following information:

4 In this example, the manufacturer determined that calling a poison control center is the most appropri-ate emergency medical advice.

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.

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.

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.

Example 2A: OXI252 Label inner package label with OSHA pictograms

Example 2B: OXI252 Label meeting DOT requirements for shipping7

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

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 combine statements on the label. In this case the similar statements were combined and the most stringent were listed. For example, the first-aid pre-cautionary statements were combined for exposure to skin, hair and clothing.

7 DOT Labels must comply with the size require-ments presented in 49 CFR 172.

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

For more detailed information about labels and Safety Data Sheets (SDSs) under the revised Hazard Communication Standard, please refer to refer to 29 CFR 1910.1200 - paragraphs (f) and (g), and Appendix C.

The revised Hazard Communication Standard and additional guidance materials are available on OSHA’s Hazard Communication page, located at: www.osha.gov/dsg/hazcom/ index.html.

Disclaimer: This OSHA Brief provides a general overview of the label requirements in the Hazard Communication Standard (see 29 CFR 1910.1200(f) and Appendix C of 29 CFR 1910.1200). It does not alter or determine compliance responsibilities in the standard or the Occupational Safety and Health Act of 1970. Since interpretations and enforcement policy 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.