The US Occupational Safety and Health Administration (OSHA) and Health Canada have released a joint guidance on pictogram requirements for three hazard communication categories, to support the implementation of the Globally Harmonized System of Classification and Labeling of Chemicals.
The categories are:
- Hazards Not Otherwise Classified (HNOC);
- Physical Hazards Not Otherwise Classified (PHNOC); and
- Health Hazards Not Otherwise Classified (HHNOC).
OSHA’s Hazard Communication Standard (1910.1200) does not differentiate between PHNOCs and HHNOCs, and does not require label elements for an HNOC.
Health Canada’s Hazardous Products Regulations requires label elements for PHNOCs and HHNOCs.
The agencies have agreed that the exclamation mark pictogram is appropriate for all three categories.
The agency states. “OSHA will permit the use of the exclamation mark pictogram for HNOCs if the label also indicates that the pictogram is being used for a hazard not otherwise classified (e.g., the words ‘Hazard Not Otherwise Classified’ or ‘HNOC’ must appear below the exclamation mark pictogram)”.
For other hazard classifications, the hazard class name is not required below the pictogram(s).
For Canada, no acronym – including HHNOC or PHNOC – is required below the exclamation mark pictogram. It does allow “HNOC” or “Hazards Not Otherwise Classified” to appear below the exclamation mark pictogram on a label.
Health Canada has confirmed that the use of the exclamation mark pictogram is acceptable for PHNOCs and HHNOCs, and meets the requirements to use an appropriate pictogram in each case.