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“I have been using generic HMIS II type labels for years to label solvent ‘plunger cans’, but I was recently told that this type of labeling no longer satisfies OSHA.  Is this true?”

Rewording your question, you appear to be asking whether a secondary containment label based on the HMIS® (Hazardous Material Information System) label version II will satisfy the OSHA Hazard Communication standard (29 CFR 1910.1200) labeling requirement.  The short answer is yes, but this answer must be qualified to be truly meaningful.

The Hazard Communication standard is a performance oriented standard, which allows a variety of acceptable labeling approaches for secondary containers.  The HMIS® system developed by the National Paint and Coatings Association uses red, blue, yellow and white bars  and a 0 – 4 numerical hazard rating system similar to the NFPA (National Fire Protection Association) diamond.  Unique to this system, the white bar is used to communicate personal protection requirements for product handling.  Version II included the addition of a chronic hazard box into the label – providing additional hazard data.  There is now a third HMIS® version (HMIS®III) that has incorporated more sweeping changes.  Any of these systems can be incorporated into a compliant Hazard Communication labeling program.

It may be that the individual who misinformed you that HMIS® II labeling was unacceptable was referring to the OSHA requirement to provide “appropriate hazard warnings” on hazardous material product labels.  “Hazard warnings” are defined in the standard as including “target organ effects” – that is, identification of the organs of the body that may be damaged by the product.  Neither NFPA nor HMIS II labels would convey this information (HMIS III offers stickers to address this issue).  However, the OSHA target organ effect labeling requirement is addressed only to manufacturers’ primary container labels.  Workplace secondary label requirements do not require this information.  However, OSHA has stated that “An employer relying on one of the above-mentioned labeling systems (including HMIS®) may therefore have to augment his hazard communication training program to specifically address the target organ effects that may not be easily discernable from a numerical warning system.”  In other words, if target organ effects are not included on workplace labels, the employee training program should address this issue in a manner that ensures that employees are made aware of this important safety data.

Betty J. Hicks is the manager of 3E Company's US Authoring Operations. Betty has 17 years of experience in the areas of hazard communication and regulatory compliance. Before advancing to her current position, Betty was a senior MSDS author for Ariel. In this position, Betty made hazard assessment determinations and regulatory compliance decisions for global Hazard Communication Documents. Prior to joining Ariel, Betty worked as an technician associate in the environmental, health and safety (EH&S) department of a large chemical company. Betty has a diverse background in project management, training, coaching and process improvement management. She is proficient in the functionality of the EHS module of SAP R3. Betty holds Associates Degrees in both business finance and chemical technology.

"I enjoy working for a company that offers one-stop shopping. As a provider of chemical, global regulatory and compliance information services, 3E Company provides comprehensive online support, management and distribution for Material Safety Data Sheets," said Ms. Hicks.  "We utilize our vast industry resources and knowledge to assist companies with their authoring needs and challenges. Each project has its own specific set of challenges, as we can develop 'co-source' solutions that work on the customer's own platform, or develop a full outsourcing solution on our platform. With the growing complexities of changing regulatory compliance, I enjoy helping make our customers' jobs easier! It’s nice to be asked about what we can provide and be able to say all the pieces of the puzzle can be completed by 3E."