Will OSHA allow blank red borders?
The revised Hazard
Communication Standard (HCS) requires that all red borders printed on the label have a symbol printed
inside it. If OSHA were to allow blank red borders, workers may be confused about what they mean and
concerned that some information is missing. OSHA has determined that prohibiting the use of blank red
borders on labels is necessary to provide the maximum recognition and impact of warning labels and to
ensure that users do not get desensitized to the warnings placed on labels.
When must label information be updated?
revised Hazard Communication Standard (HCS), OSHA is lifting the stay on enforcement regarding the
provision to update labels when new information on hazards becomes available. Chemical
manufacturers, importers, distributors, or employers who become newly aware of any significant
information regarding the hazards of a chemical shall revise the labels for the chemical within
six months of becoming aware of the new information, and shall ensure that labels
on containers of hazardous chemicals shipped after that time contain the new information. If the
chemical is not currently produced or imported, the chemical manufacturer, importer, distributor,
or employer shall add the information to the label before the chemical is shipped or introduced
into the workplace again.
How will workplace labelling provisions be changing under the
revised Hazard Communication Standard?
The current standard provides
employers with flexibility regarding the type of system to be used in their workplaces and OSHA
has retained that flexibility in the revised Hazard Communication Standard (HCS). Employers may
choose to label workplace containers either with the same label that would be on shipped
containers for the chemical under the revised rule, or with label alternatives that meet the
requirements for the standard. Alternative labelling systems such as the National Fire
Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System
(HMIS) are permitted for workplace containers. However, the information supplied on these
labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or