
Is a GHS-Label Required?
Does a 100,000-gallon aboveground storage tank (AST) containing sulfuric acid (98% concentration) require a GHS-compliant label in accordance with 29 CFR 1910.1200?
If "yes", what information must be on the label? If "no", why is it exempt from OSHA's HazCom standard?

Comments (26)

My initial reaction was "Yes". If I only had two to choose from I would have said "Yes". However, I would have to look it it up to be 100% so I put "Not Sure".
This storages tank would be covered under OSHA PSM 191.119 which does not have requirements for storage tank labeling. It would be covered under 1910.1200 to be labeled so first responders now what is in the tanks.
Plus since it is covered under OSHA PSM the employer would need to follow an consensus standard and would be required to follow what is required in the consensus standard regarding labeling that is above what is required in 1910.1200.
1) Name of the material
2) Hazard statement
It may not be covered under PSM if only storing product for sale and not processing the chemical after looking at the picture of the tanks. The reason I said for first responders is diamond label does not give as much information like what would be given with GHS labeling. Yes fore sure would be for the employees exposed to the chemicals.
Other communications are permissible and required

Type of chemical stored and hazard warnings,

Unless it is privately owned with no employees it requires a label meeting the requirements of 1910.1200(f)(1).
1910.1200(b) Container means any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical. For purposes of this section, pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers.

1910.119(b) definitions Process means any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process.
Or if the storage facility is usually unoccupied, a PSM exception.
We don't know what is in the container so we can't say if PSM or Haz Comm standards apply.

So here’s my dilemma (and it’s only subject adjacent) I’m running Safety for a cast house. Within the cast house is molten metal (obviously). it’s not a chemical so it’s not covered the requirement for labeling (I don’t think) but it is a serious explosion hazard if you add water and I feel they should be some labeling like the NFPA diamond for the areas so if first responders came in and we’re not trained to the area during the walk-through they would spray water on molten. What’s the best way for me to address this hazard?
Haz Com labelling fits into two categories- shipping labels, and workplace labels. If a product is being shipped off site, it must have a GHS label. If a product is in a container at the work place it can be labeled using whatever method the employer chooses provided employees have been trained and understand the system. The only time labeling is not required is if the person in control of it will not leave it. For example, if I pull a sample, then take it to the lab for testing and have it under my control the whole time, I do not need to label it.

NFPA 704 Diamond