A system created to standardize hazardous material label requirements across multiple jurisdictions is causing unexpected headaches for environmental laboratories.
The US Occupational Safety & Health Administration (OSHA) adopted the United Nations’ Globally Harmonized System (GHS) of Classification and Labeling of Chemicals (3rd Revision) for the purpose of standardizing hazmat labeling so information on the nature of the hazard is always consistently displayed and readily available when needed (figure 1).
GHS classification was incorporated into OSHA’s regulatory requirements under 29 CFR 1910-1200, also referred to as OSHA’s Hazard Chemical Standard 2012, (HCS 2012).
OSHA’s HCS 2012 applies to all chemical manufacturers, importers and distributors. However, they also apply to environmental labs that do typical kinds of sample pre-preserving and shipping, with substances such as hydrochloric acid, sodium hydroxide, nitric acid, among others (figure 2).
As of December 1, 2015, if a lab obtains sampling containers pre-preserved with a hazardous chemical, all the individual containers, even down to the smallest vial, must have labels that meet HCS 2012 standards (see figure 1). A lab that pre-preserves its own containers then conveys them to a sampling site must provide HCS-compliant labeling for all containers and packaging when a hazardous substance is involved.
Notwithstanding the impacts to environmental labs in terms of potential costs in material, labor, and time, it is unlikely that OSHA will change its HCS 2012 rules in the foreseeable future. QEC is committed, therefore, to follow HCS 2012, and to provide our Custom-Preserved™ users with the means to do so as well, in order to protect our customers and ourselves from any potential OSHA penalties or fines.
For more information on HCS 2012 compliance and QEC’s involvement in addressing the issue for our industry, contact Darrell Fuller (dfuller@qecusa.com/800-255-3950)
Quality Environmental Containers has redesigned the labeling on its entire line of Custom-Preserved™ products to be in full compliance with OSHA HCS 2012 standards, as well as with all applicable US DOT requirements.
Our customers never have to worry about compliance because we’ve taken care of all that before their QEC product ever reaches their doorstep.
“We call it our Total Labeling Protocol, and it applies to every classified chemical compound we handle in our production facilities,” said Michael McCune, vice president sales and marketing. “Total” means QEC Custom-Preserved™ products come complete with all required hazardous material information and labeling. That includes safety data sheets, outside package labeling (when required), and individual container labels.
To be HCS compliant, QEC has taken great care to make sure that signal words, hazard statements, precautionary statements, pictograms, and all other content are word-for-word consistent with the safety data sheet throughout the entire labeling protocol.
QEC has also developed a unique solution to provide HCS-compliant labeling for vials and other small preserved containers. Our small container labels are concise, informative, and still leave room for your lab’s labeling needs. For more information on QEC Custom-Preserved™ products, contact your QEC representative or Michael McCune (mmccune@qecusa.com / 800-255-3950).
QEC has reorganized the technical information on our website (qecusa.com) and made several additions.
The new content includes several videos on soil sampling tools and techniques, provided with the cooperation of En Novative Technologies, Inc. (manufacturers of EnCore® and Terra Core® samplers, EasyDraw® Syringe, and PowerStop™ handle). QEC is an authorized reseller for En Novative Technologies.
All technical information on QEC's website can now be accessed from a new top menu tab, "News & Info", with access to our newsletter, the videos, and a centralized menu of the various informational PDFs found on the site. Other content additions include (among others):
• A more concise chemical resistance guide for plastics
• A septa selection guide
• A complete list of our Standard & Custom Field Sampling Kits
Also, we are continuing to add to our library of technical drawings of our glass and plastic containers and vials.
® 2016 Quality Environmental Containers, Inc. • info@qecusa.com