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29 CFR 1910.1200(f)HCS 2024 employer relabel deadline · November 20, 2026

GHS Labels: shipped, workplace, and the 8 pictograms

OSHA's Hazard Communication Standard puts a full GHS label on every shipped container of a hazardous chemical — six required elements — and lets you label the containers you fill in-house with one of two workplace options. Getting the shipped-versus-workplace line right, and the eight required pictograms, is what keeps container labeling off your citation list. And the HCS 2024 update to GHS Revision 7 is reissuing labels across the supply chain now.

Verified against osha.gov · July 18, 2026

At a glance

Shipped-container label

Six elements from the manufacturer: product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and supplier name/US address/US phone

1910.1200(f)(1)

Workplace container

Two options: (i) the shipped-label elements except the supplier block, OR (ii) product identifier + words/pictures/symbols giving at least general hazard info

1910.1200(f)(6)

Pictograms

OSHA requires 8 — the environment pictogram (GHS09) is voluntary, not OSHA-required

1910.1200 App C

Immediate-use exception

A portable container filled and used by the same employee within one shift needs no label

1910.1200(f)(8)

Legible & in English

Workplace labels must be legible, in English, and prominently displayed — other languages may be added

1910.1200(f)(10)

HCS 2024 employer deadline

As necessary, update alternative workplace labeling, the program, and training for newly identified GHS Rev 7 hazards by November 20, 2026 (substances)

1910.1200(j)(2)(ii)
6
Elements on a shipped label
manufacturer's GHS label
(f)(1)
8
OSHA-required pictograms
GHS09 environment is voluntary
App C
#2
Most-cited OSHA standard
HazCom 1910.1200 · FY2025
1910.1200
$16,550
Per serious violation
2026 maximum
1903.15(d)

Hazard Communication (1910.1200) was the #2 most-cited OSHA standard in FY2025 (OSHA Top 10), and container-labeling failures are among its most common citations.

Which label does this container need?

Answer two or three questions and get the exact OSHA rule for the container in your hand — shipped, workplace, stationary process, or the immediate-use exception — plus what the label must contain. Runs on the same verified engine as our full decision tool.

What are you labeling?

Pick a container type to see which OSHA label rule applies — and what the label must contain.

Shipped label vs. workplace label

The single most common labeling confusion. The manufacturer's shipped label is fully prescribed; the workplace label you apply in-house has two allowed shortcuts. They answer to different paragraphs.

Shipped container

1910.1200(f)(1)

All six GHS elements, from the manufacturer, importer, or distributor:

  1. 1.Product identifier
  2. 2.Signal word (Danger or Warning)
  3. 3.Hazard statement(s)
  4. 4.Pictogram(s)
  5. 5.Precautionary statement(s)
  6. 6.Supplier name, U.S. address & U.S. phone

You may never deface or remove this label on an incoming container (1910.1200(f)(9)).

Workplace / secondary container

1910.1200(f)(6)

Pick one of two options:

Option 1 — full GHS elements

Reproduce (f)(1)(i) through (v): identifier, signal word, hazard statements, pictograms, precautionary statements. The supplier block, (f)(1)(vi), is not required on a workplace label.

Option 2 — identifier + general hazard info

Product identifier + words, pictures, symbols, or a combination that give at least general information about the hazards.

No size cutoff. The 100 mL / 3 mL “small container” allowances are a shipped-container accommodation ((f)(12)), not a workplace-label shortcut.

A real GHS label, annotated

The six elements are easier to hold against a real label. Below is an illustrative GHS shipped label for acetone — a common jobsite solvent — with each (f)(1) element called out. The hazard data is real and verified (ECHA harmonised classification, CAS 67-64-1); the supplier block is illustrative, not a specific manufacturer's artwork.

Acetone · CAS 67-64-1

(f)(1)(i)

Product identifier — must match the SDS and any workplace label for the same product.

🔥 Flame (GHS02) + ❗ Exclamation (GHS07)

(f)(1)(iv)

Pictogram(s) — red diamond, black symbol on white. Only the applicable ones; no empty frames.

DANGER

(f)(1)(ii)

Signal word — “Danger” (more severe) or “Warning”. One per label, the most severe.

H225 · H319 · H336

(f)(1)(iii)

Hazard statements — highly flammable liquid & vapor; causes serious eye irritation; may cause drowsiness or dizziness.

P210 · P280 · P305+P351+P338 · P304+P340

(f)(1)(v)

Precautionary statements — prevention, response, storage, disposal (representative set).

[Example Chemical Co. · 123 Main St, Anytown NY · 1-800-000-0000]

(f)(1)(vi)

Supplier name, U.S. address, and U.S. phone number of the responsible party.

Acetone signal word and H-statements per the ECHA harmonised classification (CAS 67-64-1). A workplace container you fill from this drum could instead use option (ii): the product identifier plus this general hazard information. Illustrative example for training — not a specific manufacturer's label.

The eight OSHA pictograms (and the ninth that isn't)

OSHA requires 8 pictograms on labels. The ninth, GHS09 (Environment), is part of the GHS but not OSHA-required — aquatic/environmental hazards fall under other agencies. A red diamond frame with a black symbol on a white background; an empty red frame is prohibited.

Exploding Bomb pictogram

Exploding Bomb

Explosives; self-reactives; organic peroxides; desensitized explosives

Flame pictogram

Flame

Flammables; pyrophorics; self-heating; emits flammable gas; self-reactives; organic peroxides

Flame Over Circle pictogram

Flame Over Circle

Oxidizers

Gas Cylinder pictogram

Gas Cylinder

Gases under pressure

Corrosion pictogram

Corrosion

Skin/eye corrosion; corrosive to metals

Skull & Crossbones pictogram

Skull & Crossbones

Acute toxicity (fatal or toxic)

Exclamation Mark pictogram

Exclamation Mark

Irritant (skin/eye); skin sensitizer; acute toxicity (harmful); narcotic effects; respiratory irritant

Health Hazard pictogram

Health Hazard

Carcinogen; mutagen; reproductive & target-organ toxicity; respiratory sensitizer; aspiration

Environment pictogram

Environment

not OSHA-required

Aquatic toxicity · NOT required by OSHA HCS

The edge cases that draw citations

Immediate-use containers

No label needed only while the chemical stays under the control of the worker who filled it, is used by that worker alone, and within the same shift. Break any condition and it gets an (f)(6) label.

1910.1200(f)(8)

Very small packages

Pull-out, fold-back, or tag labels come first for tiny shipped containers ((f)(12)(i)) — a reduced label only where those are infeasible, and the outer package still carries the full label. This is not a workplace-label shortcut.

1910.1200(f)(12)

Stationary process

For fixed tanks, vats, and reactors you may use signs, placards, or process sheets instead of a label on each vessel — as long as the hazard info is readily accessible in the work area. Pipes are not containers: cover the chemicals in unlabeled pipes in your written program instead (1910.1200(e)(1)(ii)).

1910.1200(f)(7)

Immediate use, on a real jobsite

OSHA's definition is narrow: the chemical stays “under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred” (1910.1200(c)).

  • No label needed. A finisher pours solvent into a cup, works from it at the station, and the cup is empty by the end of the shift.
  • Label it. The same cup left on the scaffold for the next shift. The shift of the transfer is over.
  • Label it. A foreman fills five spray bottles and hands them to the crew. Someone other than the person who filled them is using them.
  • Label it. A pail of mixed product kept in the gang box all week.

What an inspector checks on an in-house label

OSHA's HazCom inspection directive tells the compliance officer how to read the labels you make yourself. It is looser than the shipped-label rules on format, and strict on the basics.

Pictograms
“The workplace (i.e., in-house) label does not need to include the pictogram or a description of the pictogram.”
Statements
“Precautionary statements and hazard statements may be used on the in-house labels but are not required.”
Black border
“If a pictogram is used, it can be used with a black border. This is acceptable ONLY for in-house labels.”
Symbols
“If symbols are used they must not contradict the pictograms, or use of the wrong symbol for a given hazard (e.g., using the symbol for oxidizers to signify carcinogens).”
What gets cited
“The employer shall be cited for paragraph (f)(10) if the in-house labeling is not legible (e.g., font size too small), written only in a language other than English, or not prominently displayed on the container/readily available in the work area.”
The whole program
“OSHA will make a plant-specific determination of the effectiveness of the complete program when an inspection is conducted.”

OSHA CPL 02-02-079, Ch. X.F.4 (Workplace Labels), quoted from the official PDF on August 29, 2026. The product identifier still has to match the SDS and your chemical list, because OSHA defines it as the name that permits those cross-references (1910.1200(c)).

HCS 2024: the relabel timeline (GHS Rev 7)

OSHA's 2024 update aligns primarily with GHS Revision 7. Suppliers reissue labels and SDSs; employers update workplace labels, the written program, and training. On January 15, 2026 OSHA extended every HCS 2024 compliance date by four months (FR Doc 2026-00653) — the dates below are the current, extended dates. During the transition you may comply with the previous standard, the updated standard, or both:

  1. May 19, 2026

    Manufacturers — substances

    Manufacturers, importers, and distributors comply for substances: updated GHS Rev 7 labels and SDSs.

  2. November 20, 2026

    Employers — substances

    Employers update alternative workplace labels, the written program, and worker training for substances.

  3. November 19, 2027

    Manufacturers — mixtures

    The same manufacturer obligations extend to mixtures.

  4. May 19, 2028

    Employers — mixtures

    Employers finish the transition for mixtures — labels, program, and training.

Map the work with the HCS 2024 Relabel Planner and the GHS Rev 7 Transition Wizard.

The 10-point label self-audit

The interactive check above answers one container; this is the walk-the-site version — print it, carry it, tick each box. Every item is tied to the paragraph that governs it.

  • Every container shipped from a supplier carries all six GHS elements. 1910.1200(f)(1)
  • You never deface or remove a supplier's label on an incoming container. 1910.1200(f)(9)
  • Every workplace/secondary container you fill uses one of the two (f)(6) options — and includes the product identifier. 1910.1200(f)(6)
  • Labels are legible, in English, and prominently displayed (other languages may be added). 1910.1200(f)(10)
  • Pictograms are the correct eight (App C); GHS09 (environment) is not treated as required. 1910.1200 App C
  • Any NFPA/HMIS workplace label carries the product identifier + general hazard info, doesn't conflict with the GHS elements, and workers are trained (incl. the reversed scale). 1910.1200(f)(6)(ii)
  • Immediate-use containers meet ALL conditions: under the control of the worker who filled them, used by that worker only, within the same shift. 1910.1200(f)(8)
  • Tiny shipped containers use pull-out/fold-back/tag labels first; the reduced label set only where a full label is infeasible. 1910.1200(f)(12)
  • Workers are trained to read the labels and the alternative rating systems in use. 1910.1200(h)
  • Labels are updated as suppliers reissue them for GHS Rev 7 / HCS 2024 (dates extended four months, Jan 2026). 1910.1200(j)

Answer a single container interactively with the check above or the full decision tool. Any unchecked box is a labeling citation waiting to happen.

Print every label in HazComFast

Every label comes from the product record, so the name on the bottle is the name on the SDS and on your chemical list. GHS workplace labels are included on every plan, the free one too.

A whole jobsite at once

Every product on the jobsite on Avery 5160 sheets, 30 labels to a page, or as a batch of 4x2 labels for a Zebra thermal printer.

One bottle, from the phone

Filling a spray bottle? Make its label on the phone, on 2x4 Avery 5163 stock or a 4x2 Zebra or Brother label, and print or share it on the spot.

A QR code on every label

The label carries the hazards. Its QR code opens the full SDS with the phone camera, no app and no account.

Nothing prints unchecked

Hazard data the AI read from an SDS stays off the labels until someone confirms it. A product with no pictogram, signal word or hazard statement on record is flagged before you print.

Key facts

  • A shipped container from the manufacturer carries all six GHS label elements; a workplace container you fill needs only one of the two (f)(6) options.
  • OSHA requires 8 pictograms — the ninth, GHS09 (Environment), is not OSHA-required because aquatic toxicity falls under other agencies.
  • There is NO 100 mL / 3 mL small-container shortcut for workplace/secondary containers — that reduced-label accommodation is for shipped containers only (1910.1200(f)(12)).
  • A portable container is exempt from labeling only while the chemical stays under the control of the worker who transferred it, is used only by that worker, and only within the shift of the transfer (1910.1200(c), (f)(8)).
  • You may never deface or remove the supplier's label on an incoming container; workplace labels must be legible and in English (1910.1200(f)(9)–(f)(10)).
  • Hazard Communication ranked second on OSHA's FY2025 list of most-cited standards, and an unlabeled or mislabeled container is cited under 1910.1200(f), up to $16,550 per serious violation.

GHS labeling FAQ

What are the six elements of a GHS label?

On a shipped container (1910.1200(f)(1)) the manufacturer's GHS label must have: (1) product identifier, (2) signal word, (3) hazard statement(s), (4) pictogram(s), (5) precautionary statement(s), and (6) the name, U.S. address, and U.S. telephone number of the responsible party.

How do I label a secondary (workplace) container?

Under 1910.1200(f)(6) you pick one of two options: (i) reproduce the shipped-label elements of (f)(1)(i) through (v), meaning everything but the supplier block, or (ii) use the product identifier plus words, pictures, symbols, or a combination that provide at least general information about the hazards. There is no volume or size cutoff — a small bottle follows the same rule as a drum.

How many GHS pictograms does OSHA require?

Eight. The environment pictogram (GHS09) is part of the GHS but is not required by OSHA's Hazard Communication Standard, because environmental/aquatic hazards fall under other agencies such as the EPA. So an OSHA-compliant label uses only the 8 health and physical pictograms as applicable.

Do small containers get a smaller label?

Not for workplace/secondary containers — (f)(6) has no size cutoff. OSHA's 1910.1200(f)(12) expects pull-out labels, fold-back labels, or tags on very small SHIPPED containers first, and allows a reduced label only where those are not feasible. Even then the immediate outer package must carry the full label. The 100 mL / 3 mL thresholds are a shipped-container accommodation, not a workplace-label shortcut.

When can a container go unlabeled (immediate use)?

Only under 1910.1200(f)(8): a portable container filled from a labeled container for the immediate use of the employee who made the transfer. OSHA defines immediate use as the chemical being under the control of and used only by the person who transferred it, and only within the work shift in which it was transferred (1910.1200(c)). Hand it to someone else, or keep it past the shift, and it needs a label under (f)(6).

Do GHS labels have to be in English?

Yes. Workplace labels must be legible, in English, and prominently displayed (1910.1200(f)(10)). You may add other languages alongside the English for your workforce, but a non-English label cannot replace the required English.

Can I use NFPA 704 or HMIS instead of a GHS workplace label?

Yes, as a workplace label. OSHA accepts NFPA 704 and HMIS for workplace/secondary containers under 1910.1200(f)(6)(ii), provided the label also carries the product identifier, conveys at least general information about the hazards, does not conflict with the required GHS pictograms or warnings, and employees are trained on the system. Watch the reversal that trips workers up: in NFPA/HMIS a higher number means more hazardous, while in GHS a lower category number is more hazardous. These systems do not replace the full GHS label on a shipped container.

What's the difference between a DOT label and a GHS label?

They are different systems for different stages. DOT labels and placards (49 CFR) communicate hazards during transport and appear on shipping packages; the OSHA GHS label (1910.1200) communicates hazards in the workplace and stays on the container in the work area. A shipped drum often carries both. To avoid two symbols for one hazard, OSHA does not require the GHS pictogram for a hazard when the DOT transport pictogram for that same hazard already appears on the shipped container (1910.1200(f)(5)(iii)) — though you may still include it.

What does the HCS 2024 update change for labels?

OSHA's 2024 Hazard Communication update aligns primarily with GHS Revision 7. Manufacturers are reissuing shipped labels and SDSs; employers must update their alternative workplace labels, written program, and training for substances by November 20, 2026. Watch for new/changed hazard classifications that alter pictograms and statements.

Sources

Label requirements of 1910.1200(f) and the eight-pictogram rule (App C) verified against osha.gov on July 18, 2026; the workplace-label paragraphs, (c) and (f)(6) to (f)(10), re-read on the eCFR on September 26, 2026. General guidance, not legal advice; OSHA-approved State Plans may impose additional requirements.

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