Labels

1. Where do I find the requirements for preparing an OSHA compliant label?

   • The OSHA requirements are found here.

2. How do I create my own format of the label?

• • SDScribe™ provides the required text and pictograms in the Label tab of each SDS that you create in a standard 8.5 x 11 inch document upon pressing the "Generate label text" button. For greater editing flexibility (e.g., to double column, etc), select File /Save as and save it on your desktop as a Word document (.doc). Use Word or your other favorite editor to edit it to your requirements or tastes.

  • View our Youtube videos on labels

3. How do I create a basic GHS label?

• • If you have already created the SDS using SDScribe™ , then click in Label tab and press the “Generate label text” button

  • If you have not already created the SDS using SDScribe™, but just wish to create a basic GHS label for your product, then enter the minimum information which includes:

    • Product name (in Identification tab)

    • (optional) CAS no, EC no, Formula (in Identification tab)

    • Applicable GHS Class(es), Pictogram(s), Hazard and Precautionary statement(s) (in Hazard tab) or check off “Not a hazardous material” checkbox.

      • You can edit the Precautionary statements as described in this FAQ or also delete unnecessary ones by pressing the [-] button to the left of the table

    • Then click in Label tab and press the “Generate label text” button.

4. Is a GHS label required on every product?

• • Per OSHA, labels on shipped containers. The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged, or marked. Hazards not otherwise classified do not have to be addressed on the container. Where the chemical manufacturer or importer is required to label, tag or mark the following information shall be provided:

    • Product identifier

    • Signal word;

    • Hazard statement(s);

    • Pictogram(s);

    • Precautionary statement(s); and,

    • Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.

  • FYI. Hazardous chemical means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

5. What is the precedence of hazard information?

• • OSHA has the following rules per APPENDIX C TO §1910.1200—ALLOCATION OF LABEL ELEMENTS (MANDATORY)

  • C.2.1.1 If the signal word "Danger" is included, the signal word "Warning" shall not appear;

    • • C.2.1.2 If the skull and crossbones pictogram is included, the exclamation mark pictogram shall not appear where it is used for acute toxicity;

      • C.2.1.3 If the corrosive pictogram is included, the exclamation mark pictogram shall not appear where it is used for skin or eye irritation;

      • C.2.1.4 If the health hazard pictogram is included for respiratory sensitization, the exclamation mark pictogram shall not appear where it is used for skin sensitization or for skin or eye irritation.

  • The program may provide a warning message if it appears that you have added an extra pictogram. But it is up to you to delete it.

  • I am interested in knowing the size requirements for GHS labels.

6a. Are there any font size requirements for GHS labels or text?

• • Note: here is a link to a private company's website which provides some information that may be useful.

  • US Federal Hazardous Substances Act (FHSA) Requirements include font size which may be applicable.

6b. Does OSHA have any guidance for labeling small bottles?

• • Yes. Read this letter of interpretation.

7. Does OSHA allow supplemental information (such as PPE icons, consumer product safety information, etc) on a label?

• • Under certain circumstances. Read OSHA's letter of interpretation (Question 1)

8. Are HMIS labels required under the GHS standard?

• • No. Per OSHA's brief on labeling, they could be included as supplementary information.

9. Can you describe HMIS labels to me

• • This link has some background

10. How do I add NFPA and HMIS labels to my SDS?

• • First, populate Section Section 15.2 Regulatory with the applicable NFPA and HMIS ratings

  • Next, go to the Build report and press the Generate SDS text (EN) button. You can check off the NFPA-HMIS text only check box if you wish to display only the text.

11. What are the rules for labelling of outer packaging, inner packaging and single packaging

• CLP labelling is normally required on every layer of a packaging intended for supply and use. Transport labelling will have to appear on the outer packaging of hazardous substances and mixtures if these are “dangerous goods” according to the rules on the transport of dangerous goods.

• In such cases, a CLP label may also appear on an outer packaging. Single packages need to carry both the CLP label and transport labelling. If a CLP hazard pictogram on single or outer packaging relates to the same hazard as in the rules for the transport of dangerous goods, the CLP pictogram may be omitted to avoid unnecessary double labelling.

12. Are pesticides required to have GHS labels?

• • The EPA regulated pesticides and as of April 2016, has not adopted GHS for pesticide product classification and labeling. In most cases, GHS hazard statements and pictograms should not appear on pesticide product labels sold and distributed in the United States. Here is some more information on the topic.

  • To search for approved labels click here.

13. I have a consumer product, what are the labeling requirements of this?

• • SDScribe is a tool for authoring SDS and GHS labels. Although it could be used to create consumer product labels, we can not provide any resources, assistance, guarantees, etc.

  • Here are some websites that may assist you in determining the labeling requirements for your consumer product

    • OSHA letter of interpretation on additional labeling (such as consumer product) in relation to GHS required labels

    • Federal Hazardous Substances Act (FHSA) Requirements (consumer products which are classified as hazardous household products)

    • US CONSUMER PRODUCT SAFETY ACT

    • US Consumer Product Safety Act Policy on tracking labels for children's products

    • US Consumer Product Safety Act list of specifically regulated chemicals and materials

    • US FDA Summary of Labeling Requirements (cosmetics)

    • Canadian Guide to the Consumer Packaging and Labelling Act and Regulations

    • FDA animal product labeling

14. I have a cosmetic product, what are the labeling requirements of this?

• • This can be complicated. This is a link to the FDA cosmetic labeling guide