If your business stores, handles, or ships any materials that pose physical or health hazards—such as adhesives, sealants, cleaning agents, concrete additives, or fuels—you are legally responsible for ensuring those materials are properly labeled at all times. A clear, compliant labeling policy protects employees, reduces liability, and ensures your operation meets local, state, and federal safety regulations.
Here’s what to include in your company policy on hazardous material labeling:
- Purpose and Scope
Start by defining why the policy exists and who it applies to:
Explain that the policy is in place to protect employee safety and ensure compliance with OSHA’s Hazard Communication Standard (HCS) and/or other relevant regulations (e.g., WHMIS in Canada, GHS internationally).
Clarify that the policy applies to all employees involved in receiving, storing, handling, or shipping hazardous materials—including warehouse, yard, and delivery staff.
- Labeling Requirements (OSHA/GHS Standards)
Outline the required elements that must appear on hazardous material labels under OSHA’s Globally Harmonized System (GHS):
Product identifier (e.g., name or code matching the Safety Data Sheet)
Signal word (e.g., “Danger” or “Warning”)
Hazard statement(s) (describes the nature of the hazard, such as “flammable” or “causes skin irritation”)
Pictograms (standardized icons like flame, skull, exclamation mark, etc.)
Precautionary statements (recommended safety measures)
Supplier identification (manufacturer or distributor contact info)
These elements must be clearly visible, written in English, and firmly attached to the container.
- Label Maintenance and Replacement
Include a policy on keeping labels readable and intact:
Labels must be maintained in good condition and replaced if they become faded, damaged, or illegible.
No container of hazardous material should be stored or used without an appropriate label.
If a label is missing, the product must be taken out of service until it’s correctly relabeled.
You may also want to outline who is responsible for relabeling (e.g., warehouse manager, safety officer, or yard lead).
- Secondary Containers and On-Site Transfers
Clarify how employees should handle relabeled or transferred materials (e.g., when chemicals are moved into smaller or temporary containers):
Secondary containers must also be labeled with at least the product identifier and general hazard info.
Portable containers used immediately and exclusively by one person may be exempt—but best practice is still to label.
Pre-printed secondary labels should be kept readily available near workstations or in inventory areas.
- Labeling of Incoming Shipments
Specify procedures for verifying that incoming shipments are properly labeled before they are received or placed into stock:
Designated personnel must check all delivered hazardous materials for compliant labeling.
Discrepancies must be reported immediately, and improperly labeled materials should not be distributed, opened, or used.
This helps ensure compliance across the supply chain and prevents legal exposure from mislabeled goods.
- Integration With Safety Data Sheets (SDS)
The policy should tie directly into your SDS system:
Every hazardous product in inventory must have a matching, up-to-date SDS on file and accessible to employees.
Labels must match the product identifier and hazard statements listed on the SDS.
Consider including a section on how SDSs are stored (physically or digitally), updated, and accessed.
- Training and Awareness
Make training part of the policy:
All employees must be trained on how to read and understand hazardous material labels and SDSs.
Training should be provided during onboarding and refreshed regularly (e.g., annually or with new product introductions).
Keep records of all label and hazard communication training for compliance purposes.
- Responsibilities and Compliance Monitoring
Clearly define who is responsible for what:
Safety Officer or EH&S Manager: Maintains labeling program and ensures regulatory updates
Warehouse/Yard Managers: Oversee daily compliance, replace damaged labels, verify incoming shipments
Employees: Must follow labeling rules and report any missing or unclear labels
Include language around disciplinary actions for repeated non-compliance if necessary.
Final Thought
A strong hazardous materials labeling policy isn’t just about compliance—it’s about creating a safer, more professional work environment. With the right standards, clear responsibilities, and regular training, you’ll reduce risk, improve inspection readiness, and help protect your team from unnecessary harm.
