Modifying hazcom/GHS pictograms

Responding is Heather Marenda, Brady client services’ engagement manager, Brady Corp., Milwaukee.

On primary containers, pictograms should be consistent with the pictograms that OSHA has provided, utilizing matching symbols and color schemes. However, OSHA is more flexible with secondary container labels or workplace labels. For these labels, design and format can be modified as long as proper training is followed and the pictograms are included in the written hazard communication program.

For workplace labeling specifically, OSHA has not changed the general requirements. That means employers have the option to create their own workplace labels. They can choose to create labels in the following ways:

• Use all of the required information that is on the label provided by the chemical manufacturer.
• Use a combination of the product identifier, words, pictures and symbols to provide specific information regarding the hazards of the chemicals.

When it comes to the designs, OSHA states: “If the employer chooses to use the pictograms that appear in Appendix C on the workplace (or in-plant) labels, these pictograms may have a black border, rather than a red border.”

Additionally, if the label is pre-printed with diamonds, the diamond may be colored in; however, the red cannot be visible. An “X” or other symbol through the diamond is not permitted.

Best practice is to provide pictograms and label formats that are consistent with the primary containers the product is shipped in. This reduces training time and costs, and provides a standardized approach to labeling, thus reducing potential injury and risk.

Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.