OSHA, Health Canada issue joint guidance on GHS pictogram requirements

Washington — To support implementation of the Globally Harmonized System of Classification and Labeling of Chemicals, OSHA and Health Canada have released joint guidance on pictogram requirements for three hazard communication categories.

The categories are Hazards Not Otherwise Classified, Physical Hazards Not Otherwise Classified and Health Hazards Not Otherwise Classified. The guidance is part of the 2016-17 Regulatory Cooperation Council’s plan for workplace chemicals. Both countries have vowed to reduce and prevent differences in regulations “while respecting the legislative and regulatory requirements of each country.”

OSHA’s Hazard Communication Standard (1910.1200) does not differentiate between PHNOCs and HHNOCs, and does not require label elements for an HNOC. Health Canada’s Hazardous Products Regulations requires label elements for PHNOCs and HHNOCs.

“OSHA’s HCS Directive (Inspection Procedures for the Hazard Communication Standard, CPL 02-02-079, dated July 9, 2015) includes guidance allowing the chemical manufacturer, importer, or distributor to include hazard symbols on the label or safety data sheet (SDS) for HNOCs as long as that symbol is not an HCS pictogram and does not contradict or cast doubt on the information that is required,” an announcement from the agency states.

“However, OSHA provided clarification to this in the Sept. 21, 2016, field enforcement memorandum to permit the use of the exclamation mark pictogram for HNOCs.”

The agencies have agreed that the exclamation mark pictogram is appropriate for all three categories.

“OSHA will permit the use of the exclamation mark pictogram for HNOCs if the label also indicates that the pictogram is being used for a hazard not otherwise classified (e.g., the words ‘Hazard Not Otherwise Classified’ or ‘HNOC’ must appear below the exclamation mark pictogram),” the agency states.

For other hazard classifications, the hazard class name is not required below the pictogram(s). For Canada, no acronym – including HHNOC or PHNOC – is required below the exclamation mark pictogram. It does allow “HNOC” or “Hazards Not Otherwise Classified” to appear below the exclamation mark pictogram on a label.

“The exclamation mark pictogram may appear only once on a label; if it already appears as a required pictogram, it may not appear a second time as supplemental information for the HNOC,” OSHA states. “OSHA considers the exclamation mark pictogram to be acceptable for HNOCs because it conveys more general hazard information and does not contradict or cast doubt on the information that is required.”

Health Canada has confirmed that the use of the exclamation mark pictogram is acceptable for PHNOCs and HHNOCs, and meets the requirements to use an appropriate pictogram in each case.

OSHA has published two charts: the labeling requirements for hazardous products and the regulatory process in both countries.