From formula to bottle
Updated
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One: classify the hazards
Hazard class and category, which is the technical exercise the whole system rests on and which the appendices to the standard set out. Every label element follows from the classification rather than from judgment about the product.
Two: decide who you are selling to
A workplace buyer puts you in hazard communication. A consumer product subject to an FHSA or CPSC labeling requirement is outside it and inside that regime instead. That is a commercial decision with a labeling consequence.
Three: build the label for the regime you are in
For HazCom, the six elements in accordance with Appendix C for each hazard class and category, prominently displayed, in English, with the signal word, hazard statements and pictograms grouped together.
Four: write the safety data sheet
Sixteen numbered sections in the order the standard lists, with Appendix D setting the content of each. It is a fixed structure and the order is not optional.
Five: check the transport side
The label must not conflict with the DOT rules, and section 14 of the sheet carries the transport information. If the product is a Class 3 flammable liquid the limited quantity provisions set inner packaging limits by packing group.
Then the container, which is one question
Chemical resistance. 149 HDPE and 42 glass containers, and the liner against your chemistry is the part to put to the supplier in writing with the substance and the concentration named.
Keep the five answers together
Classification, buyer and regime, label artwork, the sheet with its revision date, and the container with its liner. A reformulation reopens the first and therefore most of the rest.
Classification is the work, everything else is derived
Five of the six label elements and most of the sheet fall out of the hazard class and category. Spending the effort there rather than on the label design is how this category is done efficiently.