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All Containers›Shop by use case›Industrial chemical›Tools and directories›The check, before the artworkShop all chemical →
Tools and directories

The check, before the artwork

By Dwight Davis, Founder

Updated

On this page9
Five questions. The second one decides which label you are writing, so it comes before the design.

One: what is the classification?

Hazard class and category, worked through properly, because five of the six label elements follow from it. A wrong classification produces a label where every prescribed element is wrong together.

Two: who is the buyer?

A workplace customer puts you in hazard communication. A consumer product subject to an FHSA or CPSC labeling requirement is outside it. If you sell both ways, that is two labels and two stock-keeping units, not one compromise.

Three: does the label carry all six, with three grouped?

Product identifier, signal word, hazard statements, pictograms, precautionary statements, and the responsible party with a telephone number. Signal word, hazard statements and pictograms located together, per Appendix C, prominently, in English.

Four: is the sheet sixteen sections, in order, and dated?

With Appendix D content under each heading, section 14 carrying the transport information, section 15 the regulatory information and section 16 the date of preparation or last revision.

Five: has the liner been tested against this chemistry?

Named substance, named concentration, named temperature, in writing from the closure supplier. Then keep a filled, sealed, weighed sample and look at it at one, three and six months.

And check the transport side does not conflict

The label must not conflict with the DOT rules, and if the product is a Class 3 flammable liquid the limited quantity inner limits and the 30 kg gross cap are the figures to work to.

File the five answers with the formula

Classification, channel, label artwork version, sheet with its revision date, and container and liner with the supplier’s tested position. A reformulation or a supplier change reopens the first and therefore most of the rest.

Two of the five are decided on paper before anything is bought

Classification and channel cost nothing to settle and determine almost everything downstream. Artwork, a print run and a case of closures are the expensive things, and they all depend on those two.

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
29 CFR 1910.1200(b)(5), the scope exclusions, which take out a consumer product or hazardous substance as defined in the Consumer Product Safety Act and the Federal Hazardous Substances Act when subject to a safety standard or labeling requirement of those Acts or of CPSC regulations, and pesticide-treated agricultural or vegetable seed labeled under the Federal Seed Act. law.cornell.edu
29 CFR 1910.1200(g), Safety data sheets, which requires a sheet for each hazardous chemical produced or imported, in English, with sixteen numbered sections in the order listed and the content of each set out in Appendix D, including section 14 Transport information and section 15 Regulatory information. 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
16 CFR 1700.14(a)(15) and 1700.15, which require special packaging for prepackaged liquid solvents for paints and similar surface-coating materials at 10 percent or more of named solvents under 100 SUS, and set the child-resistant effectiveness specifications the packaging has to meet. 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.