The feedback I was given by OSHA at this fall’s Society for Chemical Hazard Communication conference on this subject is that OSHA will not prohibit you from including more information on the label than is prescribed under GHS, however, they do not recommend placing NFPA or HMIS labels near the GHS label as the numbering system for hazard severity is conflicting.  Under GHS a category 1 is the most dangerous whereas under NFPA or HMIS a rating of 1 is the least dangerous. 

 

This is from the OSHA guidance available at their website:  https://www.osha.gov/dsg/hazcom/hazcom-faq.html

 

Q. How will workplace labeling provisions be changing under the revised Hazard Communication Standard?

A. The current standard provides employers with flexibility regarding the type of system to be used in their workplaces and OSHA has retained that flexibility in the revised Hazard Communication Standard (HCS). Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard. Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Identification System (HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms.

Best,

Nicole Shoshenskiy
Authoring Team Lead
MSDSonline

350 North Orleans Street, Suite 950

Chicago, IL 60654
Direct: 1.312.881.2894

Fax: 1.312.881.2001
Email: nshoshenskiy**At_Symbol_Here**MSDSonline.com

 

 

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Eileen Mason
Sent: Friday, October 17, 2014 12:24 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] GHS and NFPA query