Reprinted from the ACJ - June, 1995
Signs, signs, everywhere the signs. Clogging up the scenery, choking my mind. Do this, don't do that, can't you read the signs.
If you sang those first few lines, groovy. If not, you are too old to be a hippie or too young to know where you were when man first walked on the moon.
I think they were singing about society's rules and regulations. The constant curtailing of freedom. The MAN putting his foot down squarely in the back of the planet's children. Repressing us, the offspring of Mother Earth!
Sorry, I got a little carried away there. But the point is that although signage and labeling sometimes seem to exert excessive control over us, most are there to inform, protect or educate us. From the seemingly inert but chronic hazards of lead to the "in your face" explosive danger of a fuel tank liner, product labels act as a warning and an educational tool to help us safely conduct our shop business.
Product labels can contain as varied an assortment of information as Peter Max posters have color, although the visual effect is nowhere near as interesting. OSHA has set up guidelines as to what should be on a label. It is these rules that we will discuss, or for you hippies out there, "rap" about.
The regulations governing the labeling of industrial use products are fairly simplistic, but somewhat ambiguous. Requirement number one is that the label contain the name and address of the manufacturer and/or importer. Secondly, the name or names of the hazardous ingredients within the product must be listed. Lastly, and most importantly, the label must contain "appropriate warnings."
The term "appropriate warnings" can lead to some confusion. Like hippies explaining specific details of their late sixties whereabouts, there is plenty of wiggle room for conjecture, opinion, varied interpretation, misinformation and trails following moving objects. Well, maybe that last statement only applies to flower children and not labeling.
Generally speaking, you should look at the product as it is packaged, as well as how it may be used. Think of the hazards in terms of acute (short term or single exposure) dangers and chronic (long term or repetitive exposure) hazards. Acute hazards may include: skin, eye and respiratory irritation or burns from the product or its fumes, as well as headache, nausea, cramps and/or vomiting from ingestion.
Physical hazards should be addressed as well. Flammability, corrosivity or poison potential should be called out. In terms of chronic hazards, information concerning detrimental effects on target organs, liver, kidneys or bodily systems like the nervous or reproductive for example should be cited.
A problem inherent in this requirement may be becoming apparent: finding room on the label for all of this information. That's why the hazard statements usually appear in condensed sentences. Terms like "avoid contact," "skin and eye irritant" and "avoid ingestion" are common.
Never depend solely on the product label for your protection. The MSDS is a far greater tool for hazard and safety determination. First aid information is sometimes listed on the label, but it is usually brief and not all encompassing.
A doctor is your best source for first aid information following excessive exposure to a nasty chemical. Don't be afraid to give him or her a call. The manufacturer is a source of information on product hazards but not necessarily on first aid treatments.
All of this on the label and we have not even mentioned the catch phrases like "keep away from children," "do not reuse container," "use in well ventilated area" or "long haired freaky people need not apply."
Now that we know what is required on the label, who is responsible for seeing it is there? You, me and everyone in between. The rules state that the manufacturer, importer, distributor and end user must ensure the product is properly labeled when received at their facility. You should not remove any labels placed on the container by the manufacturer unless replaced with a new label immediately.
The labels must be legible and written in English. If another language is spoken at your shop and English is not understood, steps must be taken to relay the hazards to all employees. If labeling is not feasible, as with pigs of metal or vats of chemicals, tags, placards or signs adjacent to the material are allowed.
The one exception to the labeling rules concerns "single use" containers. If a single employee (I'm referring to his work condition, not his marriage status) is going to use the product during a single shift and then return the unused material to a labeled container or dispose of it and discard the container, he is not required to label it.
An example would be if the bench guy poured a cupful of flux from a properly labeled drum and used it up during the course of his work that day. No labelling is required on the cup. But if he leaves the cup on the bench overnight, it must be labeled according to our discussion previously.
Instead of getting frustrated with the labeling authorities coming down on us good citizens, do what I did. I got myself some paper and I made up my own little sign. It says thank you Lord for thinking of me, I'm alive and doing fine. OK, now everybody sing the chorus.
The above article was written by David M. Brown, Chief Engineer of Johnson Manufacturing Company, Inc. and is published by JOHNSON with the expressed approval of the National Automotive Radiator Service Association and the Automotive Cooling Journal. Other reproduction or distribution of this information is forbidden without the written consent of JOHNSON and NARSA/ACJ. All rights reserved.
JOHNSON MANUFACTURING COMPANY
114 Lost Grove Road / PO Box 96 / Princeton, Iowa 52768-0096
Phone 563-289-5123 or Fax 563-289-3825