In 2012, the US Occupational Safety & Health Administration (OSHA) published rule,29 CFR 1910.1200, for the US to standardize labeling requirements in line with the UN Globally Harmonized System (GHS).
Manufactures and distributors are subject to this rule. Those shipping hazardous chemicals, even in the smallest amounts,must provide labeling for GHS(also known as Hazardous Chemical Standard 2012). This rule also applies to Environmental Laboratories who ship out containers with common preservatives such as hydrochloric, nitric and sulfuric acid.
Under the rule, each individual sample container that contains hazardous substances, must be labeled with:
- a product identifier
- a signal word
- a hazardous statement
- appropriate hazardous pictograms
- precautionary statements
- a name, address and telephone number of responsible party.
Manufactures were to be incompliance by June 1, 2015. Distributors (Laboratories) were to be in compliance December 1,2015.
Some suppliers of standards and preserved containers claimed compliance. This was not always the case. Some made reference to partial elements being included on outer packaging. True compliance is the listing of “all” six elements on each individual unit. ESS included all elements from the start.
However, difficulty does occur with smaller items. Reference standard suppliers have had the toughest job- chemical mixes in glass ampules down to 2 mL.
Our 40mL EPA vial was our primary challenge. ESS includes the six GHS elements around our sample I.D. label. This was necessitated by three items that we commonly print on vial labels; Container lot number, reagent lot number an tare weights. Future modifications to the label may occur. Feel free to give us your feedback. Of a practical matter, ESS (and our competitors) have been burdened by the Federal Mandate. We have had to incur unforeseen costs in both label costs and label attaching. This may surely affect pricing in the near future.Of greater concern to Laboratories in our industry,(no matter how small)is their compliance.If they decide to preserve bottles themselves, then they are subject to the same laws and possible fines if they do not comply.