Does this system satisfy labeling requirements of the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard?
The methods described in your question appear to fit into the category of labeling alternatives found in paragraph [29 CFR 1910.1200(f)(6)]. As such they will meet the intent of the standard as long as the use of this method is restricted to stationary process containers. Scenario: A manufacturing plant identifies a sulfuric acid tank with a label: DANGER: – SULFURIC ACID. Next to it is the Department of Transportation (DOT) label for corrosive substances showing the picture of a liquid spill on a hand. Question 2: Does this composite label meet the OSHA requirements? Answer: For in-plant labels the standard identifies two requirements: chemical identity and appropriate hazard warnings ([29 CFR 1910.1200(f)(5)(i) and 1910.1200(f)(5)(ii)]). The “SULFURIC ACID” wording would satisfy the identity requirements as long as the same term was utilized for cross-referencing purposes on the material safety data sheets and required list of hazardous chemicals. The requirement for “appropriate haz
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