The question of whether to include a label and safety data sheet when shipping chemicals really hasn't changed under the new GHS rules, says the woman who led the revisions. At the American Industrial Hygiene Association's annual conference in early June, health and safety consultant Jennifer Silk said that GHS identification is usually warranted when there is one good study linking a substance to a health risk.
A report on her speech by Bloomburg BNA states that employers should generally use the same threshold for determining whether to mark a hazardous material under the revised hazard communication standard as they would have under the previous rule. Silk advises employers to consider the purpose of the standard - to make sure people have the information they need to protect workers.
OSHA reportedly is considering allowing manufacturers to provide product identifier, signal word, appropriate pictograms, name and phone number on packages that are too small for complete labeling, but would require full information on the outside package that holds the small packages. OSHA has developed technical guidance on hazard classification that the agency hopes to publish by the end of summer.