Labels prepared under the European Union’s regulation for classification, labelling and packaging of substances and mixtures (EC/1272/2008), which adopted criteria based on the UN's Globally Harmonized System of Classification and Labeling of Chemicals (GHS), are considered to comply with OSHA's Hazard Communication Standard (HCS) requirements if the EU GHS labels comply with all of the provisions of the HCS, according to an OSHA letter of interpretation posted on the agency’s Web site Nov. 2, reports ORC Worldwide, a Washington, DC-based occupational safety, health and environmental consultantancy.

The HCS requires that labels contain the identity of the chemical; appropriate hazard warnings; and the name and addresses for the chemical manufacturer, importer, or other responsible party [29 CFR 1910.1200(f)(1)].

The letter, written by Richard Fairfax, director of OSHA’s Directorate of Enforcement Programs, states: “Classification schemes in the EU and other countries may be different from those in OSHA's HCS. These classification schemes may affect the information provided on both the safety data sheet and the label. However, as long as the EU GHS label contains the information required by the HCS, OSHA will consider the EU GHS label sufficient.”

The letter also points out that OSHA is proposing to amend the HCS to align it with the GHS. Once these changes are adopted, EU GHS labels should meet the requirements of HCS, according to ORC Worldwide.