In House System for Labeling Chemicals
Hey Group! I have a department in my facility that handles solvents in spray bottles (secondary containers) to clean equipment. Whenever they label the bottles the solvent takes the labels off. They have tried laminate, tape over labels, and some others. They finally came up with the attached, which was to put these cards at every door (immediately available to all work areas). On the spray bottles they use they put colored tape only. The color of the tape matches the key. When I first saw it I said it is not labeled so no good based off the below excerpt from the regulations.
1910.1200(f)(6)(ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.
What do you think. Is this acceptable or not?
Comments (7)
This doesn't necessarily answer your question, but I have used ChemicoTAG for solvents and oils before, and it works well: https://www.labtag.com/shop/brand-name/chemicotag/
I think would be acceptable as long as they are trained on the colors, and know where the "key" is (the picture you attached). This is a very interesting question though. Looking forward to other's thoughts.
By definition it would not be complaint. This is one of the cases where they have estabilshed very specific requriements about labeling.
Seems like a system that would work really well most of the time but then you happen to catch that one new guy who happens to not pay close enough attaention. And then the inspectors sre gonna come looking and this will be the root casue they identify. And it becomes an easy fine.
This is a really good question. I think the key is certainly compliant. I feel like the big issue is if your employees understand the key well enough to associate the color with the correct chemical. This seems like a grey area.
Have you tried paint marker on the bottles?
No, this would not be compliant. Workplace labeling must have the required specified elements mentioned in 1910.1200(f)(6). While this could be used to supplement the workplace labeling, this by itself would not be compliant. The container itself has to contain the following: “Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.”
With this system, you’re relying on everyone memorizing this color coding system 100% properly 100% of the time. Some have “Danger” signal words, whereas others have “Warning” signal words, meaning some are more hazardous than others. I need to be able to look at the chemical’s container and see that it’s Heptane or Hexane and know with 100% certainty, regardless of whether or not I’m by the labeling system legend shown in the picture.
Also, NFPA 704 rating systems are for stationary containers only, not portable, since they’re designed for providing information to first responders, not workers.