NPGA Clarifies Revised OSHA Label Compliance Requirements

The association clarifies that OSHA defines a responsible party as “someone who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.” Further, while a propane marketer can be the responsible party, the Name, Address, and Telephone Number of another entity may be substituted to satisfy the requirement, such as an emergency response company contracted by a firm to provide such information.

In addition, container labels must include: (1) the product name—Liquefied Petroleum Gas or Propane; (2) the signal word Danger; (3) the hazard statement Extremely Flammable Gas; (4) a precautionary statement; (5) pictograms; and (6) contact information.

NPGA has developed “5 Things to Know About the OSHA HCS 2012 Regulation” to provide clarification. HCS 2012 updates four elements of OSHA’s requirements, including written hazard communication programs at the workplace, employee training, safety data sheets, and labels. HCS 2012 does not expand the scope of containers that must be labeled. If the container had an OSHA label prior to HCS 2012, it must have one today. HCS 2012 requires more specific information on labels than previously required and changes how information is displayed. HCS 2012 is an OSHA regulation applicable to the workplace environment and is enforceable by that agency alone.
It does not regulate transportation or involve Department of Transportation regulations. Finally, the compliance deadline for HCS 2012 labels was Dec. 1, 2015.

NPGA comments that while there is likely to be ongoing confusion regarding the new regulations, Sarah Reboli, NGPA director of regulatory affairs, is available to explain many of the compliance requirements. She may be contacted at This email address is being protected from spambots. You need JavaScript enabled to view it..

OSHA introduced HCS to align labeling with the Globally Harmonized System of Classification and Labeling of Chemicals, with the aim of providing a common and coherent approach to classifying chemicals and communicating
hazard information on labels and safety data sheets. The update also sought to reduce trade barriers while improving productivity at American businesses that regularly handle, store, and use hazardous chemicals.