Important Cylinder Labeling Announcement

Revisions to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (29 CFR Part 1910.1200) brought the United States into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). These GHS changes require our cylinder decals to be revised by June 1, 2015.

The Compressed Gas Association has just published the new guidelines for compressed gas decals to comply with GHS. The new decal guidelines are found in CGA C-7-2014, Guide To Classification And Labeling Of Compressed Gases (10th Edition). We recommend that you download CGA C-7 at http://www.cganet.com/customer/publication_detail.aspx?id=C-7. After downloading the new labeling standard, compare your existing decals to the standard and ask your decal printer to make changes, as needed. The cylinder decal producing companies need to be using the 2014 edition of C-7. Ultimately, your company will be held accountable by DOT or OSHA for any cylinder decal errors found during inspections on the road, in your facilities, or at your customer locations so be sure your cylinder decals are done correctly.

This and other CGA publications are available at no charge to GAWDA members who participate in the GAWDA/CGA subscription program. For additional information about this program, go to: http://gawda.org/Resources/CGA-Subscription-Program/CGA-Subscription-Program/. For more information about GHS and the OSHA Hazard Communication Standard, see: https://www.osha.gov/dsg/hazcom/HCSFactsheet.html.

Key Cylinder Decal Changes

The precautionary statements found on our cylinder decals are being updated to meet the new Globally Harmonized System (GHS) requirements. Most of the cylinder decal precautionary wording has changed in some fashion with either key warning words or added or modified warning statements.

Another change is that many of the decals will need to have additional GHS pictograms added to the cylinder decal. These possible extra pictograms are specified at the bottom of each precautionary statement section in C-7. The pictograms have a specified size, color and shape as outlined in section 5.2 of C-7. The pictogram shall be at least 16mm (0.63 inch) on each side inclusive of the red border and oriented as a square-on-point (diamond). If the required pictogram is already shown in the DOT label (the colored 1-1/4 inch on each side diamond), then you don’t add it onto the cylinder decal as an additional pictogram.

Deadline Dates

After June 1, 2015, cylinders that your company fills must be shipped with the updated cylinder decals. After December 1, 2015, cylinders that are filled by outside vendors will have to have the updated cylinder decals on them when shipped by your company. Of course, we will have the older decals on cylinders out at customers and will be bringing those back to our locations for many years to come.

By now, you should have already taken care of the first deadline item in the GHS program. By December 1, 2013, employers were required to train their workers on the new label elements and the Safety Data Sheet (SDS) format. Here is the OSHA website on this for more details: http://www.osha.gov/Publications/OSHA3642.pdf. This can be accomplished with a simple safety meeting talking about the new label elements and the SDS standardized 16-section format. Be sure to document the meeting.

If there are any questions on any of these items, please contact me for more details and help.

Gases and Welding Distributors Association
Michael Dodd Meet the Author
GAWDA’s DOT, Security, OSHA &EPA Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at 573-718-2887 and MLDSafety@hotmail.com.