NEW OSHA Requirements For Oxygen Cylinder Labels
New OSHA Compliant Label
OSHA, FDA and DOT have guidelines developed for precautionary labels for use on oxygen cylinders and cryogenic vessels. These are to be used to identify the contents, warning of principal physical and health hazards, and providing appropriate precautionary information. It is the responsibility of the company(s) that fills, stores, delivers, handles and uses the gas to ensure that the label complies with applicable government regulations.
Here’s a break down of what’s required – by regulatory agency.
OSHA: The Newest Changes
OSHA has adopted GHS. GHS, or Globally Harmonized System of Classification of Labeling of Chemicals, is a system used world wide to standardize the labeling and safety data sheets (SDS) for chemicals. Because there are so many chemicals and hazardous substances used world wide, GHS is used to make everyone safer by creating a universal system.
The GHS is not a regulatory body in and of itself, but rather a set of standards that regulatory bodies can adopt to create a uniform system across the globe. Think of GHS as akin to the metric or imperial system- metric or imperial are not themselves a regulation, but something that regulating bodies adopted.
Similarly, GHS has recently been adopted by OSHA, the Occupational Safety and Health Administration of the Federal Government, to standardize hazardous material safety in the US. This means that the way things look on the chemicals you use and the material safety data sheets (now called SDS sheets) you see will change. You’ll also have to do some training for your employees on what the new standard looks like.
For Oxygen Cylinder Labels, to meet OSHA requirements, the new labels will use two of the GHS symbols, one for oxidizers (a flame over a circle) and one for gases under pressure (cylinder).
Oxidizer PictogramGases Under Pressure Symbol
FDA & DOT: Upcoming Changes
FDA requires the name of the manufacturer on the label and their principal place of business. Distributors can have their name on the label, but must have the qualifier “Distributed by” placed on the label. Also, the FDA requires “Rx Only” on the label, among a few other things. The DOT requires the proper shipping name, oxygen diamond and fine print that is listed in CGA C-7. Due to the new OSHA changes, many in the industry expect the FDA and DOT to update their requirements by 2015 as well.
OSHA Compliant Labels Available Now!
Card Cube has developed labels that meet the new OSHA requirements. They have the new required symbols, and the updated required signal word (Danger). OSHA’s requirement is a “rolling change” meaning you can start using the new labels as you need to replace them, you are not required to strip the labels off all of your cylinders and replace them now. (Please note: if you use cylinders with labels under the clear coat, you can NOT place these labels on top of them. The FDA strictly prohibits “label stacking.” ) While there is no information or date on the new FDA and DOT requirements, Card Cube anticipates that these changes will be rolling as well.