Does the hazard warning on the label have to exactly match the MSDS warning or can it be simplified?
Further, what is the appropriate hazard warning for the listed examples? OSHA’s policy is that the hazard warning must be included on the label and must specifically convey the hazards of the chemical. OSHA has consistently maintained that this includes target organ effects. The answers to the three examples in the order they were presented in your letter are: contact may cause eye damage, may damage the respiratory system, and may cause respiratory tract damage, respectively. Appendix A of 29 CFR 1910.1200 clearly states that employees exposed to health hazards must be apprised of both changes in body functions and the signs and symptoms that may occur to signal the changes. The definition of “hazard warning” states that the warning must convey the hazards of the chemical and is intended to include the target organ effects. For example, if, when inhaled, the chemical causes lung damage, then that is the appropriate warning. Lung damage is the hazard, not inhalation. Further, there are
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- Does the hazard warning on the label have to exactly match the MSDS warning or can it be simplified?
