I have a customer asking about the new Globally Harmonized Standard (GHS) pictogram labels that will be mandatory starting in June 2015. As OSHA converts to the new GHS for chemical hazard identification, they are changing the pictogram. Do you have any insight into how picky they will be on shipping boxes. The pictograms consist of a symbol on a white background framed with a red border. This could result in a 2 or 3 color to print which could get expensive on a plain kraft box.
It’s not easy to find a definitive answer. I believe the end chemical manufacturer or shipper has ultimate accountability since they tell us what to print on the box, but really don’t want to leave my customers hanging like that if there are any interpretations out there that I could not find.
I had to do a lot of additional HAZCOM training of employees to teach the pictograms, and I still need to change the labels on all my decanted chemicals. Also as part of the GHS, MSDS forms will become SDS forms and OSHA will require the use of one single standardized form. Currently there are about four different MSDS form designs.
I can tell you that when the pictograms are required to be printed, they must have a RED border. OSHA has confirmed that (see attached presentation). For boxes that already carry DOT diamonds, those marks will suffice and the GHS marks are not required on the outer box, for ground shipment in the US. I am not 100% sure that they will need to be printed on the outer package of a combination package that is either not hazardous by DOT standards, or that meets the Limited Quantity/CC-ORM-D requirements for DOT. I am trying to get more clarification on that.
Here are a couple links to documents that might be helpful as well. Implementation of New HazMat Requirements and OSHA Brief – Hazard Communication Standard: Labels and Pictograms.
The new GHS rules are changing the way we do a lot of things. AICC is offering a HAZMAT training and Certification webinar and test on December 3, 2013. Hosted by Maryann Jashinske, “General Awareness and Security Awareness Training for Hazardous Materials Packaging Suppliers” this webinar provides two of the three types of training, testing and certification required for packaging suppliers: General Awareness and Security Awareness. Click here for details and registration.