September 20, 2016
A chemical supplier told me that suppliers and manufacturers are not required to use pictograms to identify hazards in Section 2 of their products' Safety Data Sheets. He also said that pictograms are not required on safety data sheets or on labels for chemicals that are consumer products. Is he correct?
As you know, Section 2 of a safety data sheet identifies the product's hazards. Chemical manufacturers and suppliers have the option of using either pictograms (also called "hazard symbols") or the name of the symbol in Section 2 of a safety data sheet. So, using pictograms are not required. The Hazard Communication Standard says, "Hazard symbols may be provided as graphical reproductions in black and white or the name of the symbol…" [Italics added.]
Your supplier's statement about labels on consumer products was also correct. The Hazard Communication Standard states that the GHS labeling requirements do not apply to products with labels regulated by other government agencies. So, in this case – a consumer product with labeling covered by the Consumer Product Safety Commission – the label would not be covered by the Hazard Communication Standard and no pictograms would be required.
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