UWM Chemical Labeling Procedures
What Must be Labeled and Why is it Required?
The OSHA Hazard Communication Standard (HCS) specifically mandates that all containers of hazardous materials be labeled with an appropriate warning. While this warning does not have to include all of the information contained on the Material Safety Data Sheet, it does have to convey critical information to the user.
The Hazardous Materials Identification Guide (HMIG) or Hazardous Materials Information System® (HMIS) was devised as a tool to comply with the Hazard Communication Standard and has employees who must handle hazardous chemicals in the workplace as the intended audience. HMISŪ includes hazard evaluations; a rating system for acute and chronic health, flammability and physical hazards. These labels provide at-a-glance information on the hazards and the appropriate personal protective equipment (PPE). HMIS was developed by the National Paint and Coatings Association (NPCA).
National Fire Protection Association (NFPA) is a fire protection hazard warning system designed to provide rapid, clear information to emergency responders on materials under conditions of fire, chemical spill, or other emergency situations. Like HMIS, it includes labels and a numerical rating system, but the basic purpose of the label information is different. Therefore, the numbers assigned in the NFPA system assume that a fire is present. No such assumption holds in the HMIG/HMIS system. For this reason, the numbers that are assigned to the flammability, health, and reactivity hazards may differ between the NFPA and HMIG systems, even for the exact same chemical.
The following are examples of chemical labeling schemes used at UWM. At a minimum, all chemical containers must include:
- Name or Identity of the Chemical, and
- Appropriate Hazard Warnings, (e.g., poison, corrosive, flammable, explosive, oxidizer)
- NFPA 704 or HMIS placards, etc.
What is a Hazardous Substance?
A hazardous substance includes, but is not limited to products that are toxic, corrosive, flammable, irritants, oxidizers, sensitizers, water reactives or explosives. The key question to ask is, 'Do these materials create an unusual health or safety risk through its use, storage, accidental mixing or possible combustion?' If yes, the material is likely hazardous and you must label the building, room and/or container.
At What Quantity Must I Use Placards?
When any amount of a substance or combination of substances would cause, or significantly contribute to an increased risk of serious injury, incapacitating illness or increased risk of death.
Source: City of Milwaukee Department of Building Inspection Hazardous Occupancy Section, Code Requirements for Indentification of Fire Hazards of Materials NFPA 704
National Fire Protection Association (NFPA) 704 System:
The NFPA 704 system provides a readily recognized, easily understood system for identifying specific hazards and their severity using spatial, visual, and numerical methods to describe in simple terms the relative hazards of a material. It addresses the health, flammability, instability, and related hazards that may be presented as short-term, acute exposures that are most likely to occur as a result of fire, spill, or similar emergency.
The NFPA 704 system was originally conceived to safeguard the lives of those individuals who may be called upon to remedy a hazardous emergency situation where the location or storage of fire hazards may not be readily apparent. Its objectives are to provide an appropriate signal or alert to the type of hazards present.
The NFPA 704 Hazard Placard identifies the following hazards of chemicals:
The hazards are arranged spatially as follows: health at nine o'clock position, flammability at twelve o'clock position, and instability at three o'clock position. The six o'clock position on the symbol represents special hazards and has a white background. The special hazards in use are W, which indicates unusual reactivity with water and is a caution about the use of water in either fire fighting or spill control response, and OX, which indicates that the material is an oxidizer.
Each hazard class is ranked to indicate the degree of hazard. These rankings range from "0" designating a "minimal" hazard, "1" indicating a "slight hazard", "2" indicating a "moderate hazard, "3" indicating a "serious hazard" and "4" indicating a "severe" hazard.
Flammability ratings are determined by the flashpoint temperature. A rating of "4" indicates a flashpoint below 73°F, "3" is a flashpoint below 100°F, a rating of "2" indicates a flashpoint below 200°F, 1 indicates a flashpoint above 200°F and a "0" indicates the material will not burn.
The City of Milwaukee Department of Building Inspection-Hazardous Occupancy Section requires that:
- All tanks, areas, rooms, storage areas and all doors that directly access the tanks, areas, rooms and storage areas that contain a hazardous substance be placarded.
- A placard with no numbers shall be placed on the front of the building to identify the building to the Fire Department as a labeled building.
- Any room or area that has more than one hazardous substance will list the highest number of the most hazardous substance for each section of the placards that are placed on the doors that lead to these areas. Individual hazardous substances must still be labeled.
Hazardous Materials Information System® (HMIS)
Similar to the NFPA 704 identification method referenced above, is the Hazardous Materials Information System® (HMIS) developed by the National Paint and Coatings Association. This system uses blue, red, orange, and white horizontal bars for the health, flammability, physical hazards and special hazard categories. The label identifies general Health, Flammability, and Physical Hazards, using color-coded fields, as well as recommendations for personal protective equipment. Icons then show the specific type of Health, Physical Hazard, or PPE; i.e., the specific target organ affected or that the noted physical hazard is explosive, and that the PPE combination of choice consists of a splash shield, protective gloves, and a synthetic apron. The icons are a new aspect of the HMIS®.
The HMIS® labeling system satisfies a portion of the Hazard Communication Standard requirements by allowing workers to identify, at a glance, the type and degree of hazards associated with each product they use. HMIS® labels can appear in a variety of formats. Some will include additional spaces to list target organ effects (a labeling requirement under 29 CFR 1910.1200) and other information, but the four colored areas shown here will always be present.
HMIS® III provides more information about a chemical's physical hazard(s). The specific physical hazards that the Hazard Communication Standard addresses are flammability, compressed gases, explosives, organic peroxides, oxidizers, pyrophorics, unstable-reactive and water-reactive chemicals. The new HMIS® III not only specifically incorporates each hazard, with specific criteria to evaluate the degree of hazard, but permits employers to identify the hazard present with an icon or symbol.
In the orange "physical hazards" section the following ratings apply:
"4" -- Materials that are readily capable of explosive water reaction, detonation or explosive decomposition, polymerization, or self-reaction at normal temperature and pressure.
"3" -- Materials that may form explosive mixtures with water and are capable of detonation or explosive reaction in the presence of a strong initiating source. Materials may polymerize, decompose, self-react, or undergo other chemical change at normal temperature and pressure with moderate risk of explosion.
"2" -- Materials that are unstable and may undergo violent chemical changes at normal temperature and pressure with low risk for explosion. Materials may react violently with water or form peroxides upon exposure to air.
"1" -- Materials that are normally stable but can become unstable (self-react) at high temperatures and pressures. Materials may react non-violently with water or undergo hazardous polymerization in the absence of inhibitors.
"0" -- Materials that are normally stable, even under fire conditions, and will not react with water, polymerize, decompose, condense, or self-react. Non-explosives.
A major difference between NFPA 704 and HMIS® is in the white "Personal Protection" section which incorporates a letter coding indicating what personal protective equipment should be used when working with the material. The following letter scheme is used:
| A | Safety Glasses |
| B | Safety Glasses and Gloves |
| C | Safety Glasses, Gloves and Protective Apron |
| D | Faceshield, Gloves and Protective Apron |
| E | Safety Glasses, Gloves and Dust Respirator |
| F | Safety Glasses, Gloves, Protective Apron and Dust Respirator |
| G | Safety Glasses, Gloves and Vapor Respirator |
| H | Splash Goggles, Gloves, Protective Apron and Vapor Respirator |
| I | Safety Glasses, Gloves, Dust Respirator and Vapor Respirator |
| J | Splash Goggles, Gloves, Protective Apron, Dust Respirator and Vapor Respirator |
| K | Airline Mask or Hood, Gloves, Full Suit and Boots |
Always reference the manufacturer's label or the MSDS for more detailed hazard information and safe handling procedures.
Additional Resources:
More information regarding UWM's Chemical Hazard Communication Program can be obtained by contacting Zack Steuerwald at x5808.
Updated November 19, 2007 by SAK
