Every chemical container on a New York City construction site must carry a GHS-compliant label — and every worker must be able to read it. Labels are the first line of defense when a worker needs to know quickly whether a product is flammable, corrosive, toxic, or safe to use without respiratory protection. Ignoring or misreading a chemical label is how people get hurt.
The 6 Required GHS Label Elements
- 1. Product identifier: The chemical's name or code as it appears on the SDS — must match between label and SDS
- 2. Supplier identification: Manufacturer's name, address, and phone number — required for emergency contact
- 3. Signal word: "DANGER" (more severe) or "WARNING" (less severe) — these are defined terms, not marketing language
- 4. Hazard statement(s): Standardized phrases describing the hazard — "Flammable liquid and vapor," "Causes skin burns," etc.
- 5. Precautionary statement(s): What to do — "Wear protective gloves," "Keep away from heat/sparks," "Store in a well-ventilated place"
- 6. Pictogram(s): The GHS diamond symbols indicating the hazard category — all workers must recognize them
Secondary Container Labeling
- When you transfer a chemical from its original container to a secondary container: the secondary container must be labeled
- Exception: if the secondary container is used immediately and emptied by the same worker in the same shift — label is not required but SDS knowledge is
- Never use unlabeled containers — even for short temporary transfers. An unlabeled container is a hazard waiting to injure someone on the next shift
NYC Construction HazCom Requirements- All workers must receive site-specific HazCom training before working with chemicals — documented in PL-021 (Safety Orientation)
- SDS for every chemical on site must be accessible to all workers — physical binder or electronic system acceptable
- Non-English-speaking workers: HazCom training must be provided in a language they understand — NYC sites with multilingual workforces must plan for this
Discussion Questions- Name all 6 required elements of a GHS label and give an example of each from a product you use on this site.
- What is the difference between "DANGER" and "WARNING" on a GHS label?
- You pour concrete sealer into a small spray bottle for the day. Do you need to label the bottle? What are the conditions?
- Where is the SDS binder or access point for this site, and how would you find the SDS for a specific product?
Sign-Off
Foreman / Supervisor
SSM / SSC Name & License No.
Worker Attendance
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