BRIEF

OSHA has adopted new hazardous chemical 

labeling requirements as a part of its recent 

revision of the Hazard Communication 

Standard, 29 CFR 1910.1200 (HCS), bringing 

it into alignment with the United Nations’ 

Globally Harmonized System of Classification 

and Labelling of Chemicals (GHS). These 

changes will help ensure improved quality and 

consistency in the classification and labeling 

of all chemicals, and will also enhance worker 

comprehension. As a result, workers will 

have better information available on the safe 

handling and use of hazardous chemicals, 

thereby allowing them to avoid injuries and 

illnesses related to exposures to hazardous 

chemicals. 

The revised HCS changes the existing Hazard 

Communication Standard (HCS/HazCom 19941) 

from a performance-based standard to one 

that has more structured requirements for the 

labeling of chemicals. The revised standard 

requires that information about chemical 

hazards be conveyed on labels using quick 

visual notations to alert the user, providing 

immediate recognition of the hazards. Labels 

must also provide instructions on how to 

handle the chemical so that chemical users are 

informed about how to protect themselves.

The label provides information to the workers 

on the specific hazardous chemical. While 

labels provide important information for 

anyone who handles, uses, stores, and 

transports hazardous chemicals, they are 

limited by design in the amount of information 

they can provide. Safety Data Sheets (SDSs), 

which must accompany hazardous chemicals, 

are the more complete resource for details 

regarding hazardous chemicals. The revised 

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 Prior to the 2012 update, the Hazard Communication 

Standard had last been amended in 1994. ‘HazCom 

1994’ refers to the version of the Hazard Communication Standard in effect directly prior to the 2012 

revision, printed in the 1995 through 2011 versions of 

the Code of Federal Regulations. It is also available on 

OSHA’s webpage.

Hazard Communication Standard: Labels and Pictograms

standard also requires the use of a 16-section 

safety data sheet format, which provides 

detailed information regarding the chemical. 

There is a separate OSHA Brief on SDSs

that provides information on the new SDS 

requirements.

All hazardous chemicals shipped after June 1, 

2015, must be labeled with specified elements 

including pictograms, signal words and hazard 

and precautionary statements. However, 

manufacturers, importers, and distributors 

may start using the new labeling system in the 

revised HCS before the June 1, 2015 effective 

date if they so choose. Until the June 1, 2015 

effective date, manufacturers, importers and 

distributors may maintain compliance with 

the requirements of HazCom 1994 or the 

revised standard. Distributors may continue 

to ship containers labeled by manufacturers 

or importers (but not by the distributor 

themselves) in compliance with the HazCom 

1994 until December 1, 2015. 

This document is designed to inform chemical 

receivers, chemical purchasers, and trainers 

about the label requirements. It explains the 

new labeling elements, identifies what goes on 

a label, and describes what pictograms are and 

how to use them.

Label Requirements

Labels, as defined in the HCS, are an 

appropriate group of written, printed or 

graphic informational elements concerning a 

hazardous chemical that are affixed to, printed 

on, or attached to the immediate container 

of a hazardous chemical, or to the outside 

packaging.

The HCS requires chemical manufacturers, 

importers, or distributors to ensure that each 

container of hazardous chemicals leaving the 

workplace is labeled, tagged or marked with 

the following information: product identifier; 

signal word; hazard statement(s); precautionary 

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statement(s); and pictogram(s); and name, 

address and telephone number of the chemical 

manufacturer, importer, or other responsible 

party.

To develop labels under the revised HCS, 

manufacturers, importers and distributors 

must first identify and classify the chemical 

hazard(s). Appendices A, B, and C are all 

mandatory. The classification criteria for health 

hazards are in Appendix A and the criteria for 

physical hazards are presented in Appendix 

B of the revised Hazard Communication 

Standard. After classifying the hazardous 

chemicals, the manufacturer, importer or 

distributor then consults Appendix C to 

determine the appropriate pictograms, 

signal words, and hazard and precautionary 

statement(s), for the chemical label. Once this 

information has been identified and gathered, 

then a label may be created.

Label Elements

The HCS now requires the following elements 

on labels of hazardous chemicals:

•	 Name, Address and Telephone Number 

of the chemical manufacturer, importer or 

other responsible party.

•	 Product Identifier is how the hazardous 

chemical is identified. This can be (but 

is not limited to) the chemical name, 

code number or batch number. The 

manufacturer, importer or distributor can 

decide the appropriate product identifier. 

The same product identifier must be both 

on the label and in section 1 of the SDS. 

•	 Signal Words are used to indicate the 

relative level of severity of the hazard and 

alert the reader to a potential hazard on 

the label. There are only two words used 

as signal words, “Danger” and “Warning.” 

Within a specific hazard class, “Danger” 

is used for the more severe hazards and 

“Warning” is used for the less severe 

hazards. There will only be one signal 

word on the label no matter how many 

hazards a chemical may have. If one of 

the hazards warrants a “Danger” signal 

word and another warrants the signal word 

“Warning,” then only “Danger” should 

appear on the label.

•	 Hazard Statements describe the nature 

of the hazard(s) of a chemical, including, 

where appropriate, the degree of hazard. 

For example: “Causes damage to kidneys 

through prolonged or repeated exposure 

when absorbed through the skin.” All of 

the applicable hazard statements must 

appear on the label. Hazard statements may 

be combined where appropriate to reduce 

redundancies and improve readability. 

The hazard statements are specific to 

the hazard classification categories, and 

chemical users should always see the same 

statement for the same hazards no matter 

what the chemical is or who produces it.

•	 Precautionary Statements describe 

recommended measures that should be 

taken to minimize or prevent adverse effects 

resulting from exposure to the hazardous 

chemical or improper storage or handling. 

There are four types of precautionary 

statements: prevention (to minimize 

exposure); response (in case of accidental 

spillage or exposure emergency response, 

and first-aid); storage; and disposal. For 

example, a chemical presenting a specific 

target organ toxicity (repeated exposure) 

hazard would include the following on the 

label: “Do not breathe dust/fume/gas/mist/

vapors/spray. Get medical advice/attention 

if you feel unwell. Dispose of contents/

container in accordance with local/regional/ 

national and international regulations.” 

A forward slash (/) designates that 

the classifier can choose one of the 

precautionary statements. In the example 

Labels for a hazardous chemical must contain:

•	 Name, Address and Telephone Number

•	 Product Identifier

•	 Signal Word

•	 Hazard Statement(s)

•	 Precautionary Statement(s)

•	 Pictogram(s)
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above, the label could state, “Do not 

breathe vapors or spray. Get medical 

attention if you feel unwell. Dispose of 

contents in accordance with local/regional/

national/international regulations.” See 

Examples 1 and 2A of this document as an 

example. 

In most cases, the precautionary 

statements are independent. However, 

OSHA does allow flexibility for applying 

precautionary statements to the label, such 

as combining statements, using an order of 

precedence or eliminating an inappropriate 

statement. 

Precautionary statements may be 

combined on the label to save on space 

and improve readability. For example, 

“Keep away from heat, spark and open 

flames,” “Store in a well-ventilated place,” 

and “Keep cool” may be combined to read: 

“Keep away from heat, sparks and open 

flames and store in a cool, well-ventilated 

place.” Where a chemical is classified for a 

number of hazards and the precautionary 

statements are similar, the most stringent 

statements must be included on the label. 

In this case, the chemical manufacturer, 

importer, or distributor may impose 

an order of precedence where phrases 

concerning response require rapid action 

to ensure the health and safety of the 

exposed person. In the self-reactive hazard 

category Types C, D, E or F, three of the four 

precautionary statements for prevention 

are: 

•	 “Keep away from heat/sparks/open

flame/hot surfaces. - No Smoking.”; 

•	 “Keep/Store away from clothing/.../

combustible materials”; 

•	 “Keep only in original container.” 

These three precautionary statements 

could be combined to read: “Keep in 

original container and away from heat, 

open flames, combustible materials and 

hot surfaces. - No Smoking.”

Finally, a manufacturer or importer may 

eliminate a precautionary statement if 

it can demonstrate that the statement is 

inappropriate. 

•	 Supplementary Information. The 

label producer may provide additional 

instructions or information that it deems 

helpful. It may also list any hazards not 

otherwise classified under this portion of 

the label. This section must also identify 

the percentage of ingredient(s) of unknown 

acute toxicity when it is present in a 

concentration of ≥1% (and the classification 

is not based on testing the mixture as a 

whole). If an employer decides to include 

additional information regarding the 

chemical that is above and beyond what 

the standard requires, it may list this 

information under what is considered 

“supplementary information.” There is also 

no required format for how a workplace 

label must look and no particular format 

an employer has to use; however, it cannot 

contradict or detract from the required 

information. 

An example of an item that may be 

considered supplementary is the personal 

protective equipment (PPE) pictogram 

indicating what workers handling the 

chemical may need to wear to protect 

themselves. For example, the Hazardous 

Materials Identification System (HMIS) 

pictogram of a person wearing goggles 

may be listed. Other supplementary 

information may include directions of use, 

expiration date, or fill date, all of which may 

provide additional information specific to 

the process in which the chemical is used.

•	 Pictograms are graphic symbols used 

to communicate specific information 

about the hazards of a chemical. On 

hazardous chemicals being shipped or 

transported from a manufacturer, importer 

or distributor, the required pictograms 

consist of a red square frame set at a point 

with a black hazard symbol on a white 

background, sufficiently wide to be clearly 

visible. A square red frame set at a point 

without a hazard symbol is not a pictogram 

and is not permitted on the label. 

The pictograms OSHA has adopted 

improve worker safety and health, conform 

with the GHS, and are used worldwide. 
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While the GHS uses a total of nine 

pictograms, OSHA will only enforce the use 

of eight. The environmental pictogram is 

not mandatory but may be used to provide 

additional information. Workers may 

see the ninth symbol on a label because 

label preparers may choose to add the 

environment pictogram as supplementary 

information. Figure 1 shows the symbol 

for each pictogram, the written name 

for each pictogram, and the hazards 

associated with each of the pictograms. 

Most of the symbols are already used for 

transportation and many chemical users 

may be familiar with them. 

Figure 1: Pictograms and Hazards

It is important to note that the OSHA 

pictograms do not replace the diamondshaped labels that the U.S. Department of 

Transportation (DOT) requires for the transport 

of chemicals, including chemical drums, 

chemical totes, tanks or other containers. 

Those labels must be on the external part 

of a shipped container and must meet the 

DOT requirements set forth in 49 CFR 172, 

Subpart E. If a label has a DOT transport 

pictogram, Appendix C.2.3.3 states that the 

corresponding HCS pictogram shall not 

appear. However, DOT does not view the 

HCS pictogram as a conflict and for some 

international trade both pictograms may need 

to be present on the label. Therefore, OSHA 

intends to revise C.2.3.3. In the meantime, 

the agency will allow both DOT and HCS 

pictograms for the same hazard on a label. 

While the DOT diamond label is required for all 

hazardous chemicals on the outside shipping 

containers, chemicals in smaller containers 

inside the larger shipped container do not 

require the DOT diamond but do require the 

OSHA pictograms. (See Example 2.)

Labels must be legible, in English, and 

prominently displayed. Other languages 

may be displayed in addition to English. 

Chemical manufacturers, importers, and 

distributors who become newly aware of any 

significant information regarding the hazards 

of a chemical must revise the label within six 

months.

Employer Responsibilities

Employers are responsible for maintaining 

the labels on the containers, including, but not 

limited to, tanks, totes, and drums. This means 

that labels must be maintained on chemicals in 

a manner which continues to be legible and the 

pertinent information (such as the hazards and 

directions for use) does not get defaced (i.e., 

fade, get washed off) or removed in any way. 

The employer is not responsible for updating 

labels on shipped containers, even if the 

shipped containers are labeled under HazCom 

1994. The employer must relabel items if the 

labels are removed or defaced. However, if 

the employer is aware of newly-identified 

hazards that are not disclosed on the label, the 

employer must ensure that the workers are 

aware of the hazards as discussed below under 

workplace labels. 

Workplace Labels

OSHA has not changed the general 

requirements for workplace labeling. 

Employers have the option to create their own 

workplace labels. They can either provide 

all of the required information that is on the 
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label from the chemical manufacturer or, the 

product identifier and words, pictures, symbols 

or a combination thereof, which in combination 

with other information immediately available 

to employees, provide specific information 

regarding the hazards of the chemicals. 

If an employer has an in-plant or workplace 

system of labeling that meets the requirements 

of HazCom 1994, the employer may continue 

to use this system in the workplace as long 

as this system, in conjunction with other 

information immediately available to the 

employees, provides the employees with 

the information on all of the health and 

physical hazards of the hazardous chemical. 

This workplace labeling system may include 

signs, placards, process sheets, batch tickets, 

operating procedures, or other such written 

materials to identify hazardous chemicals. Any 

of these labeling methods or a combination 

thereof may be used instead of a label from the 

manufacturer, importer or distributer as long 

as the employees have immediate access to 

all of the information about the hazards of the 

chemical. Workplace labels must be in English. 

Other languages may be added to the label if 

applicable. 

If the employer chooses to use the pictograms 

that appear in Appendix C on the workplace (or 

in-plant) labels, these pictograms may have a 

black border, rather than a red border. 

Employers may use additional instructional 

symbols that are not included in OSHA’s 

HCS pictograms on the workplace labels. An 

example of an instructional pictogram is a 

person with goggles, denoting that goggles 

must be worn while handling the given 

chemical. Including both types of pictograms 

on workplace labels is acceptable. The same is 

true if the employer wants to list environmental 

pictograms or PPE pictograms from the HMIS 

to identify protective measures for those 

handling the chemical.

Employers may continue to use rating systems 

such as National Fire Protection Association 

(NFPA) diamonds or HMIS requirements 

for workplace labels as long as they are 

consistent with the requirements of the Hazard 

Communication Standard and the employees 

have immediate access to the specific hazard 

information as discussed above. An employer 

using NFPA or HMIS labeling must, through 

training, ensure that its employees are fully 

aware of the hazards of the chemicals used.

If an employer transfers hazardous chemicals 

from a labeled container to a portable 

container that is only intended for immediate 

use by the employee who performs the 

transfer, no labels are required for the portable 

container.

Sample Labels

The following examples demonstrate how 

a manufacturer or importer may display 

the appropriate information on the label. As 

mentioned above, once the manufacturer 

determines the classification of the chemical 

(class and category of each hazard) using 

Appendices A and B, it would determine the 

required pictograms, signal words, hazard 

statements, and precautionary statements 

using Appendix C. The final step is to put the 

information on the label. 

The examples below show what a sample 

label might look like under the revised HCS 

requirements. The examples break the 

labeling out into “steps” to show the order of 

information gathering and how label creation 

occurs. Step 1 is performing classification; step 

2 is gathering full label information; and step 3 

is creating the label.

These examples are for informational 

purposes only and are not meant to represent 

the only labels manufacturers, importers and 

distributors may create for these hazards. 
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Example 1: This example demonstrates a 

simple label. 

The Substance: 

HS85

Batch Number: 85L6543

Step 1: Perform Classification

Class: Acute Oral Toxicity; Category 4

Step 2: Gather Labeling Information

Pictograms:

Signal Word:

WARNING

Hazard Statements:

Harmful if Swallowed

Precautionary Statements:

Prevention:

•	 Wash hands and face thoroughly after 

handling.

•	 Do not eat, drink or smoke when using this 

product.

Response:

•	 If swallowed: Call a doctor if you feel 

unwell.2

•	 Rinse mouth

Storage:

None specified

Disposal:

•	 Dispose of contents/container in 

accordance with local/regional/national/

international regulations.3

Step 3: Create the Label

Putting together the above information on HS85, a 

label might list the following information:

Example 1: HS85 Label

HS85

Batch number: 85L6543

Warning

Harmful if swallowed

Wash hands and face thoroughly after handling. Do not eat, drink or smoke when using this 

product. Dispose of contents/container in accordance with local, state and federal regulations.

First aid:

If swallowed: Call a doctor if you feel unwell. Rinse mouth.

GHS Example Company, 123 Global Circle, Anyville, NY 130XX Telephone (888) 888-8888

2 The manufacturer of this chemical determined that 

calling a doctor was the most appropriate emergency 

medical advice; therefore, it is listed as part of the 

first-aid procedures.

3

 The downstream users must familiarize themselves 

with the proper disposal methods in accordance 

with local, regional, state and federal regulations. It 

is impractical to expect the label preparer to list all 

potential regulations that exist.
7

Example 2: This example demonstrates a 

more complex label.

Example 2 is for a substance that is a severe 

physical and health hazard. For shipping 

packages of chemicals that will be transported 

in the United States (i.e., drums, totes, tanks, 

etc.), the U.S. DOT requires a DOT label(s) 

on the outside container(s) for hazardous 

chemicals. Two versions of this label are 

presented below to demonstrate the difference 

between an OSHA label with pictograms from 

the HCS and a DOT label required for transport 

of a shipping container.

The Substance: 

OXI252 (disodiumflammy)

CAS number: 111-11-11xx

Step 1: Perform Classification

Class: Oxidizing Solid, Category 1

Class: Skin Corrosive, Category 1A

Step 2: Gather Labeling Information

Pictograms:

Signal Word:

DANGER

Hazard Statements:

•	 May cause fire or explosion; strong oxidizer

•	 Causes severe skin burns and eye damage

Precautionary Statements:

Prevention:

•	 Keep away from heat. 

•	 Keep away from clothing and other 

combustible materials. 

•	 Take any precaution to avoid mixing with 

combustibles. 

•	 Wear protective neoprene gloves, safety 

goggles and face shield with chin guard. 

•	 Wear fire/flame resistant clothing. 

•	 Do not breathe dust or mists.

•	 Wash arms, hands and face thoroughly 

after handling.

Response:

•	 IF ON SKIN (or hair): Take off immediately 

all contaminated clothing. Rinse skin with 

water. 

•	 IF ON CLOTHING: Rinse immediately 

contaminated clothing and skin with plenty 

of water before removing clothes. Wash 

contaminated clothing before reuse.

•	 IF IN EYES: Rinse cautiously with water for 

several minutes. Remove contact lenses, if 

present and easy to do. Continue rinsing.

•	 IF INHALED: Remove person to fresh air 

and keep comfortable for breathing. 

•	 IF SWALLOWED: Rinse mouth. Do NOT 

induce vomiting. 

•	 Immediately call poison center.4

Specific Treatment: 

Treat with doctor-prescribed burn cream.5 

In case of fire: 

Use water spray. In case of major fire and large 

quantities: Evacuate area. Fight fire remotely 

due to the risk of explosion.

Storage: 

Store locked up.

Disposal:

•	 Dispose of contents/container in 

accordance with local/regional/national/

international regulations.3 

Step 3: Create the Label

Putting together the above information on OXI252, 

a label might list the following information:

4

 In this example, the manufacturer determined that 

calling a poison control center is the most appropriate emergency medical advice.

5

 Not all SDSs will have direction for “specific treatment” on the label. This is only if the manufacturer 

specifically notes a certain treatment that needs to be 

used to treat a worker who has been exposed to this 

chemical.
OXI252

(disodiumflammy)

CAS #: 111-11-11xx

Danger

May cause fire or explosion; strong oxidizer

Causes severe skin burns and eye damage

Keep away from heat. Keep away from clothing and other combustible materials. Take any precaution to avoid 

mixing with combustibles. Wear protective neoprene gloves, safety goggles and face shield with chin guard. Wear 

fire/flame resistant clothing. Do not breathe dust or mists. Wash arms, hands and face thoroughly after handling. 

Store locked up. Dispose of contents and container in accordance with local, state and federal regulations.

OXI252

(disodiumflammy)

CAS #: 111-11-11xx

Danger

May cause fire or explosion; strong oxidizer

Causes severe skin burns and eye damage

Keep away from heat. Keep away from clothing and other combustible materials. Take any precaution to avoid 

mixing with combustibles. Wear protective neoprene gloves, safety goggles and face shield with chin guard. Wear 

fire/flame resistant clothing. Do not breathe dust or mists. Wash arms, hands and face thoroughly after handling. 

Store locked up. Dispose of contents and container in accordance with local, state and federal regulations.

Example 2A: OXI252 Label inner package label with OSHA pictograms

Example 2B: OXI252 Label meeting DOT requirements for shipping7

First aid:

IF ON SKIN (or hair) or clothing6: Rinse immediately contaminated clothing and skin with plenty of water before 

removing clothes. Wash contaminated clothing before reuse.

IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. 

Continue rinsing.

IF INHALED: Remove person to fresh air and keep comfortable for breathing.

IF SWALLOWED: Rinse mouth. Do NOT induce vomiting. 

Immediately call poison center.

Specific Treatment: Treat with doctor-prescribed burn cream.

Fire:

In case of fire: Use water spray. In case of major fire and large quantities: Evacuate area. Fight fire remotely due to 

the risk of explosion.

Great Chemical Company, 55 Main Street, Anywhere, CT 064XX Telephone (888) 777-8888

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First aid:

IF ON SKIN (or hair) or clothing: Rinse immediately contaminated clothing and skin with plenty of water before 

removing clothes. Wash contaminated clothing before reuse.

IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. 

Continue rinsing.

IF INHALED: Remove person to fresh air and keep comfortable for breathing. Immediately call a doctor.

IF SWALLOWED: Rinse mouth. Do NOT induce vomiting. 

Immediately call poison center.

Specific Treatment: Treat with doctor-prescribed burn cream.

Fire:

In case of fire: Use water spray. In case of major fire and large quantities: Evacuate area. Fight fire remotely due to 

the risk of explosion.

Great Chemical Company, 55 Main Street, Anywhere, CT 064XX Telephone (888) 777-8888

6

 There are occasions where label preparers may 

combine statements on the label. In this case the 

similar statements were combined and the most 

stringent were listed. For example, the first-aid precautionary statements were combined for exposure 

to skin, hair and clothing.

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 DOT Labels must comply with the size requirements presented in 49 CFR 172.
This is one in a series of informational briefs highlighting OSHA programs, policies or standards. It does 

not impose any new compliance requirements. For a comprehensive list of compliance requirements 

of OSHA standards or regulations, refer to Title 29 of the Code of Federal Regulations. This information 

will be made available to sensory-impaired individuals upon request. The voice phone is (202) 693-1999; 

teletypewriter (TTY) number: (877) 889-5627.

DSG BR-3636 2/2013

For more detailed information about labels and 

Safety Data Sheets (SDSs) under the revised 

Hazard Communication Standard, please refer 

to refer to 29 CFR 1910.1200 - paragraphs (f) and 

(g), and Appendix C. 

The revised Hazard Communication Standard 

and additional guidance materials are 

available on OSHA’s Hazard Communication 

page, located at: www.osha.gov/dsg/hazcom/

index.html. 

Disclaimer: This OSHA Brief provides a 

general overview of the label requirements 

in the Hazard Communication Standard 

(see 29 CFR 1910.1200(f) and Appendix 

C of 29 CFR 1910.1200). It does not alter 

or determine compliance responsibilities 

in the standard or the Occupational 

Safety and Health Act of 1970. Since 

interpretations and enforcement policy 

may change over time, the reader should 

consult current OSHA interpretations 

and decisions by the Occupational Safety 

and Health Review Commission and the 

courts for additional guidance on OSHA 

compliance requirements.