OSHA and DOT Issue Joint Memorandum on Hazardous Chemicals

The Occupational Safety and Health Administration (OSHA) and the Department of Transportation (DOT) issued a joint memorandum on September 19, 2016. The memorandum provided additional guidance on a directive released earlier in 2016 on the overlap in labeling requirements for OSHA’s Hazard Communication Standard and DOT’s Hazardous Materials Regulation. In this previous guidance released in July, OSHA has determined that the diamond-shaped placards required by the DOT will be considered pictograms for the purpose of HCS compliance. DOT has also allowed that HCS pictograms do not conflict with their requirements. Therefore, manufacturers, distributors, or importers may use either both the DOT label and the HCS label, or only the DOT label to be in compliance with both regulations. The memorandum released in September further clarified this guidance by addressing the labeling of hazardous chemicals for bulk shipping. During transportation, DOT’s regulations take precedence over OSHA’s. Therefore, OSHA labels are not required during the transportation process. OSHA labels are, however, required both before and after transportation. To avoid any confusion, HCS and DOT labels may both appear on the same package before, during, and after transportation to comply with both sets of rules. Sign up to receive the most up-to-date regulatory and legislative information about specialty imaging.