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Art materials law

What the label must say

Updated

On this page8
Where chronic hazards exist the rule specifies the label’s content, order and relative type size.

The signal word

When only a chronic hazard exists, the signal word WARNING shall be used. When an acute hazard signal word is also mandated, the acute one is used. Either way it shall be prominently visible and set in bold capitals, in a size equal to or greater than the statement of potential chronic hazards.

The hazards, in order

Potentially chronic hazards shall be stated substantially in accordance with the statements the rule lists, limited to those that are clinically significant and might be expected with any reasonably foreseeable use, and grouped in order of relative descending severity.

Name the components

All components and known decomposition products with a potential for chronic hazards shall be listed prominently. Generically equivalent names may be used, which is the one concession to formulation confidentiality in the labeling clause.

Safe handling instructions

Appropriate precautionary statements on work practices, personal protection and ventilation, substantially conforming to the list in the rule. That list includes "Keep container tightly closed when not in use", which is a packaging instruction in a labeling standard.

Sensitizers get their own list

Each label shall contain a list of the sensitizers present in sufficient amounts to contribute significantly to a known skin or respiratory sensitization. That is a separate requirement from the chronic hazard list and is often the one missed.

And a source for more information

The precautionary label shall contain a statement identifying a source for additional health information, substantially conforming to one of the phrases the rule provides. Where chronic labeling applies, a US address and telephone number are required too.

It must not weaken the acute warnings

Labeling shall conform to any labeling practices prescribed by federal and state statutes or regulations and shall not diminish the effect of required acute toxicity warnings. Chronic labeling is added to those, not traded against them.

References

16 CFR 1500.14(b)(8)(i)(E), (F) and (G), on labeling practices: the signal word WARNING in bold capitals at least as large as the chronic hazard statement, chronic hazards grouped in descending severity, chronically hazardous components named prominently, safe handling instructions, and a list of sensitizing components. law.cornell.edu
16 CFR 1500.14(b)(8)(ii)(C), (D) and (E): describe the criteria used in writing and submit that description and a list of art materials needing hazard warnings to the Commission’s Division of Regulatory Management; carry the US name, address and telephone number and a statement that the material is inappropriate for use by children where chronic labeling applies; and get new hazard information onto labels within 12 months of discovery. law.cornell.edu
Written from federal regulation and from measured catalog data, not from a formulation bench. Whether a specific product needs chronic hazard labeling is a toxicologist’s determination and the rule says so; nothing here substitutes for that review. Anything on these pages is a starting point.