RTK Labels – a Tutorial

Understanding the MSDS and RTK Labels

• How is an RTK label different from the MSDS?

• Should RTK labels cover the worst case scenario?

• What is meant by the "Health Hazards" that are shown on RTK labels?

• How do I learn more about RTK label regulations? What is the purpose behind the OSHA HazCom rules?

• Should we use Right-to-Know labels in Spanish?

• What are the physical hazards for my Right-to-Know chemical label?

Target Organ Effects, route of Entry and Personal Protective Equipment

• Does OSHA require target organ information on RTK labels?

• How do I determine which Target Organs I should select for my RTK label?

• What does the "Route of Entry" mean when I fill out an RTK label for my chemical?

• In looking at our RTK labels, how Target Organ effects determined?

• In filling out the template for RTK labels, how do I determine which Personal Protective Equipment should be shown?

How is an RTK label different from the MSDS?

Note that the Hazard Communication Standard is performance-oriented standard. As a result, you will not find specifications on the exact design for our Right-to-Know label (or even your MSDS). Thus, labels and MSDS' follow many different formats and there can be no side-by-side comparison made between the information placed on the MSDS versus a label.

To gain more insight, however, review the following excerpt from a July 25, 1991 letter from Patricia K. Clark, Director, Directorate of Compliance Programs at OSHA:"A material safety data sheet is not an "appropriate hazard warning"; the purpose of a label under the HCS is to serve as an immediate visual warning of the hazards associated with the chemical. The identity of the chemical leads to the more detailed information on the MSDS, but the hazard warning gives immediate information to employees working with the substance about the hazards associated with exposure."

Of course, an entire MSDS cannot fit onto your RTK label. Vital information can be lost in the clutter of a badly organized label. RTK labels should make searching through the MSDS easier. A label is, a just a single component of your hazardous communication system. No doubt, it is the tangible evidence of a RTK system that spans not only the chemical database, your MSDS's, emergency response protocols and protective equipment and handling training. For many of the comprehensive label designs that we offer in our custom RTK label section, each area of a label links to a particular section of the 16-part MSDS. By creating a way to connect the label and the MSDS, and adding an MSDS reference to the label, the MSDS becomes less intimidating.

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Should RTK labels cover the worst case scenario?

RTK labels are not written to cover every exposure situation. Instead, they are made for the worst-case situations. Many times that Safety Officer can decide to make the PPE requirements more flexible when a substance is handled in small enough quantities that they do not present any danger.

Here are a few examples:

• In situations when small quantities are used, a lab coat or apron is adequate enough to shield the body from contamination. However, many labels still have the full body suit symbol and are written for the worst-case exposure situations as a precaution. Full body suits are generally used to protect one from liquid a corrosives as well as other liquids and solids that can potentially harm the host human, and gases which have the ability to invade the body through absorption or form corrosive mixtures with moisture.

• It is recommended that gloves be worn at all times when handling chemicals. This is a principle rule when managing with various gases. Many gases, when placed under extreme pressure or very low temperatures turn into liquids. Should these compressed gases be released and make contact with a human, frostbite will likely occur. Gloves are greatly suggested for that reason, as well as to stop one from touching their eyes while chemicals still reside on their hands.

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What is meant by the "Health Hazards" that are shown on RTK labels?

	Toxic: A chemical falling within any of the following categories: (a) A chemical that has a median lethal dose (LD50) of more than 50 milligrams per kilogram but not more than 500 milligrams per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each; (b) A chemical that has a median lethal dose (LD50) of more than 200 milligrams per kilogram, but not more than 1,000 milligrams per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between two and three kilograms each; (c) A chemical that has a median lethal concentration (LC50) in air of more than 200 parts per million, but not more than 2,000 parts per million by volume of gas or vapor, or more than two milligrams per liter, but not more than 20 milligrams per liter of mist, fume, or dust, when administered by continuous inhalation for one hour (or less if death occurs within one hour) to albino rats weighing between 200 and 300 grams each.
	Highly Toxic (Poison): A chemical falling within any of the following categories: (a) A chemical that has a median lethal dose (LD50) of 50 milligrams or less per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each. (b) A chemical that has a median lethal dose (LD50) of 200 milligrams or less per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between two and three kilograms each. (c) A chemical that has a median lethal concentration (LC50) in air of 200 parts per million by volume or less of gas or vapor, or 2 milligrams per liter or less of mist, fume, or dust, when administered by continuous inhalation for one hour (or less if death occurs within one hour) to albino rats weighing between 200 and 300 grams each.
	Reproductive Toxin: Chemicals which affect the reproductive capabilities including chromosomal damage (mutations) and effects on fetuses (teratogenesis)
	Irritant: A chemical, which is not corrosive, but which causes a reversible inflammatory effect on living tissue by chemical action at the site of contact. A chemical is a skin irritant if, when tested on the intact skin of albino rabbits by the methods of 16 CFR 1500.41 for four hours exposure or by other appropriate techniques, results in an empirical score of five or more. A chemical is an eye irritant if so determined under the procedure listed in 16 CFR 1500.42 or other appropriate techniques.
	Corrosive: A chemical that causes visible destruction of, or irreversible alterations in, living tissue by chemical action at the site of contact. For example, a chemical is considered to be corrosive if, when tested on the intact skin of albino rabbits by the method described by the U.S. Department of Transportation in appendix A to 49 CFR part 173, destroys or changes irreversibly the structure of the tissue at the site of contact following an exposure period of four hours. This term shall not refer to action on inanimate surfaces.
	Sensitizer: A chemical that causes a substantial proportion of exposed people or animals to develop an allergic reaction in normal tissue after repeated exposure to the chemical.
	Carcinogen: A chemical is considered to be a carcinogen if: (a) It has been evaluated by the International Agency for Research on Cancer (IARC), and found to be a carcinogen or potential carcinogen; or (b) It is listed as a carcinogen or potential carcinogen in the Annual Report on Carcinogens published by the National Toxicology Program (NTP) (latest edition); or, (c) It is regulated by OSHA as a carcinogen.

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How do I learn more about RTK label regulations? What is the purpose behind the OSHA HazCom rules?

The OSHA HazCom rules are intended as way to encourage employers to provide information about the risks and proper handling of hazardous materials to their employees. The U.S. Department of Labor's official rule 1910.1200, Hazardous Communication. This states the following:

To ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training.

The HazCom rules typically reach the #1 cited ranking for OSHA violations. The label, unfortunately, is only part of the solution. Training and record keeping are critical.

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What are the physical hazards for my Right-to-Know chemical label?

• Biohazard. Is there the actual or potential presence of a biohazard (such as an infection agent that presents a risk of death, injury or illness. See OSHA 1910.1030, OSHA & Federal Regulations

• Compressed Gas. See Sections 3 and 9 of the MSDS. Is the material held in a container either at an absolute pressure greater than 276 kPa at 21degrees C, or an absolute pressure greater than 717 kPa at 54 degrees C or both, or any liquid flammable material having a Reid vapor pressure greater than 276 kPa at 38 degrees C. Also see 49 CFR 173.115

• Corrosive. Does the material destroy living tissue when contacted? Review the NFPA rating for Health Hazard. See Section 3 of the MSDS. Also determine if the material is an organic peroxide.

• Explosive. See Sections 3, 5 and 10 of the MSDS. Will the material explode when heated, shocked, or mixed with water? Consider how the material will polymerize or whether there could be explosive dust-air mixtures. You also may want to indicate, in particular, if the material is "Unstable" or "Water Reactive" or an "Oxidizer"

• Flammable. Is the material flammable and what term do you want to use (combustible liquid, flammable gas, flammable liquid/solid, or Pyrophoric? See Sections 3, 5 and 10 of your MSDS. Also consult with ANSI Z129.1-1994 for detailed explanations of Flammability. A pyrophoric material ignites spontaneously in dry or moist air at or below 54.4ºC? Also see What is a Flammable Liquid?

• Poison. Is the material highly toxic? See ANSI Z129.1-1994 for definitions of when a material is highly toxic. See Sections 3 and 11 of your MSDS.

• Radioactive. See Sections 3 and 10 of your MSDS.

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Should we use Right-to-Know labels in Spanish?

Paragraph 29 CFR 1910.1200(f)(8) states: "The employer shall ensure that labels or other forms of warning are legible, in English, prominently displayed on the container, or readily available in the work area throughout each work shift. Employers having employees who speak other languages may add the information in their language to the material presented, as long as the information is presented in English as well."

RTK labels are required to be written in English. It is allowed to write them in other languages as well, but the rule does not demand it.

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I am unclear. Does OSHA require target organ information on RTK labels?

Let's look at the excerpt from February 9, 1994 letter from H. Zettler, OSHA Compliance Programs, Deputy Director, as follows:

"As you know the HCS requires that a chemical shipping label must contain the identity of the chemical, an appropriate hazard warning, and the name and address of the responsible party. The agency's position stated in the current compliance directive (CPL 2-2.38C) is: "Precautionary statements such as "caution", "danger" or "harmful if inhaled" are not hazard warnings. The definition of hazard warning states that the hazard warning must be included on the label and must specifically convey the hazards of the chemical. OSHA has consistently maintained that this includes target organ effects."

To see the letter in it's entirety, click here: http://www.osha-slc.gov/OshDoc/Interp_data/I19940209.html

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How do I determine which Target Organs I should select for my RTK label?

Consult Section 3 of your 16-part MSDS. Also look over Sections 11 and 6 to obtain possible additional information on Target Organ effects. This should help to find out what Target Organs to select for your label

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What does the "Route of Entry" mean when I fill out an RTK label for my chemical?

	Inhalation: Chemicals may be inhaled into the lungs and then released into the bloodstream.
	Ingestion: Chemicals may invade the bloodstream after ingestion if it is absorbed through the small intestine, stomach, and the other sections of the digestive system.
	Skin Absorption: Chemicals may absorb chemicals on contact.
	Eye or Skin Contact: Chemicals on contact may affect the skin or eye.

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In looking at our RTK labels, how Target Organ effects determined?

The following is categorized into the target organ effects that may occur in the presence of specific chemicals. It also includes examples of those specific chemicals as well as some of the signs and symptoms that may come about. The examples below show the various hazards possible in the work place and are made to help employers see the danger involved in these chemicals.

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In filling out the template for RTK labels, how do I determine which Personal Protective Equipment should be shown?

Locate section 8 n your 16-part MSDS. See the recommendations here and use these choices when you click on the Personal Protective Equipment ["PPE"] options shown on the custom RTK label Wizard.

Eyes:		Use safety "Glasses" when presented with substances that cause mild irritation to the eyes.
		Use "Goggles" for liquid or solid substances that irritate, severely irritate or corrode the eyes as well as for gases that are able to cause frostbite.
Face:		Use a "Face Shield" for 'corrosive' materials.
Hand:		It is recommended that "Gloves" be worn at all times. However, one must be aware of using the correct type of glove with specific substances.
Body & Feet:		Use a "Full Suit" for "corrosive" materials that are "toxic" or "highly toxic" to the organs if one is exposed for too long.
		Use an "apron" should a full suit be unavailable.
Respirator:		Consult Section 8 of 6-part MSDS. • When using a respirator, one must judge the potential exposure level and use the appropriate respirator for each level.

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