This does not extend coverage to adverse physical and health effects for which there is a hazard class addressed in the HCS, but the effect either falls below the cut-off value/concentration limit of the hazard class or is under a GHS hazard cat- egory that has not been adopted by OSHA (e.g., acute toxicity Category 5). There are no labeling requirements for HNOCs. In an OSHA Letter of Interpreta- tion dated January 31, 2013, OSHA offers the following regarding labeling of HNOCs: Question 1: Does supplemental information on a label, such as information regarding an environmental hazard or a hazard not otherwise classified (HNOC), need to be physically separated from the harmonized information? Response: The HCS 2012 does not prohibit a manufacturer from adding supple- mental information to a label, as long as it does not lead to unnecessarily wide variation or undermine the required label information . . . supplementary informa- tion may only be provided if it provides further detail and does not contradict or cast doubt on the validity of the information required by the HCS 2012. The HCS 2012 does not specify the format of the label, only the information required on the label. Supplemental information need not be physically separated from the required information on the label; however, section C.3.2 provides that the place- ment of supplemental information must not impede identification of information required by HCS 2012. How a manufacturer designs the layout of the label is up to the preparer, as long as all the required information is present. Question 2: Is it permissible to include signal words on the safety data sheet (SDS) and label for an HNOC? Response: Under section 1910.1200(f)(1), HNOCs need not be addressed on an HCS label, and there are no harmonized label requirements for HNOCs . . . It is not permissible to use signal words other than ″ danger ″ or ″ warning ″ for HNOCs. The correct signal word for HNOCs must appear on the SDS. Question 3 : Is it permissible to include hazard symbols on the SDS and label for an HNOC, or should information only be displayed as a statement similar to the hazard and precautionary statements adopted from the Globally Harmonized Sys- tem (GHS)? Response: The HCS 2012 requires the use of up to eight pictograms. The num- ber of pictograms required depends upon the classification of the hazardous chemical. However, the manufacturer may add additional symbol(s) to the label and SDS as long as that symbol is not an HCS 2012 pictogram and does not con- tradict or cast doubt on the information that is required on the label. Question 4: Can HNOCs be included with other classifications which are described in Section 2 of the SDS, subsection (a), or should they remain under their own sub-header on the SDS? Hazard Communication Pro Labels/Forms of warning–15 10/14 Original content is the copyrighted property of J. J. Keller & Associates, Inc.
Response: Section 2, subheading (a) of Table D.l requires the manufacturer to provide the classification of the chemical in accordance with section 1910.1200(d).
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