Workplace GHS Labeling seems to be the single most asked about impact related the current transition of OSHA Hazcom 2012 with GHS. There is a great recent resource out there from OSHA (http://www.osha.gov/Publications/OSHA3636.pdf) that was released in February of this year on the various labeling requirements. Note that the labeling requirements and guidance for chemical manufacturers, importers and distributors is different from Employer responsibility and guidance. OSHA hasn’t changed general requirements for workplace labeling—and gives Employers the option to create their own workplace labels—however, there are caveats. Easy method–the Employer can provide all of the required information found on the label from the chemical manufacturer (the GHS labels you are starting to see out there now with Product Identifier, Pictograms, Signal Words, H&P statements, etc.). The other option for workplace labeling occurs if the employer has an in-plant/workplace labeling system that meets requirements of HazCom 1994—then you can continue using this system in CONJUNCTION with other information IMMEDIATELY available to employees, that provides the employees the information on all of the health and physical hazards of the hazardous chemical. If you continue to use NFPA, HMIS ,etc; the other information mentioned above must be immediately available—and “through training, insure that its employees are fully aware of the hazards of the chemicals used”.
SO, my take is you can use current workplace labeling with a few caveats—extra training, immediate availability of hazard data, and no inconsistency in your message. My personal opinion—it will be easier in the long term to train on 1 label (the GHS label that is going to be found on EVERY chemical container) and use NFPA for it’s intended use—Emergency Responder quick reference on buildings, storage, etc.
PS—See pages 4 and 5 for the real skinny on workplace labeling—and HOT NEWS—in the OSHA Brief in the link above—pictograms can be BLACK (don’t have to be red) for workplace labels!!!!