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The label

Grouped, and not in conflict

Updated

On this page9
Two requirements about arrangement rather than content, and both are easy to miss in artwork.

The grouping requirement

The manufacturer, importer or distributor shall ensure that the signal word, the hazard statements and the pictograms are located together on the label, tag or mark. Three of the six elements, physically together.

Which rules out a common layout

Pictograms along one edge, the signal word under the product name and the hazard statements on the back is a natural design and it does not satisfy the paragraph. The grouping is the point.

And the non-conflict requirement

Each container leaving the workplace must be labeled in a manner which does not conflict with the requirements of the Hazardous Materials Transportation Act and the DOT regulations issued under it.

Which matters because the pictograms differ

The GHS pictograms on a hazard communication label and the DOT hazard labels for transport are different marks for overlapping hazards. Putting both on one container needs care so neither contradicts the other.

Appendix C is the authority on the content

The information has to be in accordance with Appendix C for each hazard class and associated hazard category. So the precise wording of a hazard statement is prescribed rather than paraphrased from the appendix.

Solid materials have a narrow concession

For solid metal, solid wood or plastic items not exempt as articles, and for shipments of whole grain, the label may be transmitted at the first shipment and need not accompany later ones unless the information changes. That does not reach a liquid.

Design the label against the regulation, not a competitor

Because a competitor’s layout may predate a reclassification or may simply be wrong, and the grouping requirement is the one most often absent from labels in the wild.

The grouping is the requirement labels in the wild most often miss

Which makes a competitor's label a poor template. Designing from the paragraph rather than from a photograph of a shelf is the practical advice.

References

29 CFR 1910.1200(f), Labels and other forms of warning. Paragraph (f)(1) lists the six required elements on a shipped container: product identifier, signal word, hazard statements, pictograms, precautionary statements, and the name, address and telephone number of the responsible party. (f)(2) requires them to accord with Appendix C for each hazard class and category, prominently displayed and in English; (f)(3) requires the signal word, hazard statements and pictograms to be located together; (f)(5) requires the label not to conflict with the DOT transport rules. law.cornell.edu
49 CFR 173.150, Exceptions for Class 3 (flammable and combustible liquids), the limited quantity provisions with inner packaging limits of 0.5 L, 1.0 L and 5.0 L by packing group and a 30 kg gross cap per package. law.cornell.edu
Written from federal regulation and from measured catalog data, not from a plant floor. Hazard classification is a technical exercise with appendices behind it, and nothing here classifies a chemical or writes a label. The point of these pages is to show which regime applies and what it asks for.