In this document we will breakdown the changes that have been made to the Hazard
Communication Standard of 1994 (HCS) in the new Hazard Communication Standard of 2012
(HCS 2012) which is meant to align the standard to meet the requirements of the Globally
Harmonized System. This document will only discuss changes being made to the old standard
as it relates to the Construction Industry. If it is not listed below it simply means it is still in
place but no changes have been made. We have included additional information after each of
the 3 sections where any major changes have occurred that will need to be referenced to
conduct your training by no later than December 1, 2013. These sections will be colored
purple for identification purposes and can be found at the end of the following:


Section F: Labels and other forms of warning
Section G: Safety Data Sheets
Section A: Purpose: Only terminology changes have been made within this section.
HCS 1994
HCS 2012
Required that the potential hazards of all
chemicals are “evaluated” and information
concerning any hazards and protective
measures are communicated to employees.
Requires that the potential hazards of all
chemicals are “classified” and information
concerning any hazards and protective
measures are communicated to employees.
Why is this change important?
The purpose of GHS is to bring a more consistent approach to the means and methods
used to identify the hazards of the chemicals they are handling. One of the KEY
components of this new approach is the classification of a chemical to determine if it is
hazardous or not. This process will become clearer as you review this document.
Section B: Scope & Application: No significant changes have been made to this section as it
pertains to complying with the new GHS requirements. One terminology change worth noting is
the term Material Safety Data Sheet (MSDS) will know be called Safety Data Sheets (SDS).
Section C Definitions: There have been several changes to this section. Some definitions
have been modified, but the majority of changes have come with removal of terms and the
installation of new ones. For the purpose of keeping this document user friendly, we will not
list every new definition included in the standard. The following is a complete list of the terms
that have been modified, deleted or added to the new standard.
Added the following definitions: Classification, Hazard category, Hazard class, Hazard not
otherwise classified, Hazard statement, Label elements, Pictogram, Precautionary statement,
Product identifier, Pyrophoric Gas, Safety data sheet, Signal word, Simple asphyxiant, and
Substance.
Deleted the following definitions: Combustible liquid, Compressed gas, Explosive, Flammable,
Flashpoint, Hazard warning, Identity, Material safety data sheet, Organic peroxide, Oxidizer,
Pyrophoric, Unstable (reactive), and Water-reactive.
Revised the following definitions: Chemical, Chemical name, Hazardous chemical, Health
hazard, Label, Mixture, Physical hazard, and Trade secret.
HCS 2012: The following is a list of definitions of new or modified terms that have been
selected by ORCPG to allow you to understand the changes made to this standard. Please note
for a complete listing of definitions you will need to reference the new HCS 2012. Please
contact your risk specialist for direction on where to find this information.
"Chemical" means any substance, or mixture of substances.
"Label" means an appropriate group of written, printed or graphic information elements
concerning a hazardous chemical that is affixed to, printed on, or attached to the immediate
container of a hazardous chemical, or to the outside packaging.
"Label elements" means the specified pictogram, hazard statement, signal word and
precautionary statement for each hazard class and category.
"Pictogram" means a composition that may include a symbol plus other graphic elements,
such as a border, background pattern, or color, that is intended to convey specific information
about the hazards of a chemical. Eight pictograms are designated under this standard for
application to a hazard category.
"Hazard statement" means a statement assigned to a hazard class and category that
describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of
hazard. Example: Causes damage to kidneys through prolonged or repeated
exposure when absorbed through the skin.
"Signal word" means a word used to indicate the relative level of severity of hazard and alert
the reader to a potential hazard on the label. The signal words used in this section are
"danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used
for the less severe.
"Precautionary statement” - There are four types of precautionary statements: prevention
(to minimize exposure); response (in case of accidental spillage or exposure emergency
response, and first-aid); storage; and disposal. For example, a chemical presenting a specific
target organ toxicity (repeated exposure) hazard would include the following on the label: “Do
not breathe dust/fume/gas/mist/ vapors/spray. Get medical advice/attention if you feel unwell.
Dispose of contents/ container in accordance with local/regional/ national and international
regulations.”
"Hazard category" means the division of criteria within each hazard class, e.g., oral acute
toxicity and flammable liquids include four hazard categories. These categories compare hazard
severity within a hazard class and should not be taken as a comparison of hazard categories
more generally.
"Hazard class" means the nature of the physical or health hazards, e.g., flammable solid,
carcinogen, oral acute toxicity.
"Classification" means to identify the relevant data regarding the hazards of a chemical;
review those data to ascertain the hazards associated with the chemical; and decide whether
the chemical will be classified as hazardous according to the definition of hazardous chemical in
this section. In addition, classification for health and physical hazards includes the
determination of the degree of hazard, where appropriate, by comparing the data with the
criteria for health and physical hazards.
"Hazard not otherwise classified (HNOC)" means an adverse physical or health effect
identified through evaluation of scientific evidence during the classification process that does
not meet the specified criteria for the physical and health hazard classes addressed in this
section. This does not extend coverage to adverse physical and health effects for which there
is a hazard class addressed in this section, but the effect either falls below the cut-off
value/concentration limit of the hazard class or is under a GHS hazard category that has not
been adopted by OSHA (e.g., acute toxicity Category 5).
"Hazardous chemical" means any chemical which is classified as a physical hazard or a
health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise
classified.
"Health hazard" means a chemical which is classified as posing one of the following
hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious
eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity;
carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated
exposure); or aspiration hazard. The criteria for determining whether a chemical is classified as
a health hazard are detailed in Appendix A to §1910.1200 -- Health Hazard Criteria.
"Physical hazard" means a chemical that is classified as posing one of the following
hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid,
solid or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive
to metal; gas under pressure; or in contact with water emits flammable gas. See Appendix B to
§1910.1200 -- Physical Hazard Criteria.
"Product identifier" means the name or number used for a hazardous chemical on a label or
in the SDS. It provides a unique means by which the user can identify the chemical. The
product identifier used shall permit cross-references to be made among the list of hazardous
chemicals required in the written hazard communication program, the label and the SDS.
"Pyrophoric gas" means a chemical in a gaseous state that will ignite spontaneously in air at
a temperature of 130 degrees F (54.4 degrees C) or below.
"Safety data sheet (SDS)" means written or printed material concerning a hazardous
chemical that is prepared in accordance with paragraph (g) of this section.
Section D: Hazard Classification: This section applies to chemical manufacturers and
importers and generally does not apply to the construction trades who simply purchase and use
chemicals at their workplace.
Section E: Written Program: This section remains unchanged as OSHA has retained all
components of the HCS 1994 within the new HCS 2012.
Section F: Labels and other forms of warning: This paragraph has been extensively rewritten. Under this revised paragraph; chemical manufacturers and importers must provide a
label that includes: the product identifier, supplier information which is to include name,
address and phone number of manufacturer, importer or distributor; and the signal word,
pictogram, and hazard statement for each hazard class and category. Precautionary statements
must also be provided. The HCS 1994 does not require the use of pictograms, specific signal
words, or precautionary statements.
Please note that below is a summary of the changes to the new HCS 2012 version as it pertains
to the Construction Industry. If it is not listed below, it simply does not apply or is still in place
but hasn’t changed. To see the complete list of the requirements set forth in this standard you
will need to refer to the updated HCS 2012.
HCS 1994
HCS 2012
Under the old standard the following
information was required to be on the label:
(f)(1) The chemical manufacturer, importer, or
distributor shall ensure that each container of
hazardous chemicals leaving the workplace is
labeled, tagged or marked with the following
The following is a list of the new requirements
on what must be on the label:
(f)(1) Labels on shipped containers. The
chemical manufacturer, importer, or distributor
shall ensure that each container of hazardous
chemicals leaving the workplace is labeled,
information:
(f)(1)(i) Identity of the hazardous chemical(s);
(f)(1)(ii) Appropriate hazard warnings; and
(f)(1)(iii) Name and address of the chemical
manufacturer, importer, or other responsible
party.
(f)(5) Except as provided in paragraphs (f)(6)
and (f)(7) of this section, the employer shall
ensure that each container of hazardous
chemicals in the workplace is labeled, tagged
or marked with the following information:
tagged or marked. Hazards not otherwise
classified do not have to be addressed on the
container. Where the chemical manufacturer
or importer is required to label, tag or mark
the following information shall be provided:
(f)(1)(i) Product identifier;
(f)(1)(ii) Signal word;
(f)(1)(iii) Hazard statement(s);
(f)(1)(iv) Pictogram(s);
(f)(1)(v) Precautionary statement(s); and,
(f)(5)(i) Identity of the hazardous chemical(s)
(f)(1)(vi) Name, address, and telephone
contained therein; and,
number of the chemical manufacturer,
(f)(5)(ii) Appropriate hazard warnings, or importer, or other responsible party.
alternatively, words, pictures, symbols, or
combination thereof, which provide at least (f)(2) The chemical manufacturer, importer, or
general information regarding the hazards of distributor shall ensure that the information
the chemicals, and which, in conjunction with provided under paragraphs (f)(1)(i) through
the other information immediately available to (v) of this section is in accordance with
employees under the hazard communication Appendix C to §1910.1200, for each hazard
program, will provide employees with the class and associated hazard category for the
specific information regarding the physical and hazardous chemical, prominently displayed,
and in English (other languages may also be
health hazards of the hazardous chemical.
included if appropriate).
(f)(3) The chemical manufacturer, importer, or
distributor shall ensure that the information
provided under paragraphs (f)(1)(ii) through
(iv) of this section is located together on the
tag, label or mark.
(f)(6) Workplace labeling. The employer shall
ensure that each container of hazardous
chemicals in the workplace is labeled, tagged
or marked with either:
(f)(6)(i) The information specified under
paragraphs (f)(1)(i) through (v) of this section
for labels on shipped containers; or,
(f)(6)(ii) Product identifier and words, pictures,
symbols, or combination thereof, which
provide at least general information regarding
the hazards of the chemicals, and which, in
conjunction with the other information
immediately available to employees under the
hazard communication program, will provide
employees with the specific information
regarding the physical and health hazards of
the hazardous chemical.
Employer Responsibilities
Employers are responsible for maintaining the labels on the containers, including, but not
limited to, tanks, totes, and drums. This means that labels must be maintained on chemicals in
a manner which continues to be legible and the pertinent information (such as the hazards and
directions for use) does not get defaced (i.e., fade, get washed off) or removed in any way. The
employer is not responsible for updating labels on shipped containers, even if the shipped
containers are labeled under HazCom 1994. The employer must re-label items if the labels are
removed or defaced. However, if the employer is aware of newly-identified hazards that are not
disclosed on the label, the employer must ensure that the workers are aware of the hazards as
discussed below under workplace labels.
Workplace Labels
OSHA has not changed the general requirements for workplace labeling. Employers have the
option to create their own workplace labels. They can either provide all of the required
information that is on the label from the chemical manufacturer or, the product identifier and
words, pictures, symbols or a combination thereof, which in combination with other information
immediately available to employees, provide specific information regarding the hazards of the
chemicals. If an employer has an in-plant or workplace system of labeling that meets the
requirements of HazCom 1994, the employer may continue to use this system in the workplace
as long as this system, in conjunction with other information immediately available to the
employees, provides the employees with the information on all of the health and physical
hazards of the hazardous chemical.
This workplace labeling system may include signs, placards, process sheets, batch tickets,
operating procedures, or other such written materials to identify hazardous chemicals. Any of
these labeling methods or a combination thereof may be used instead of a label from the
manufacturer, importer or distributer as long as the employees have immediate access to all of
the information about the hazards of the chemical. Workplace labels must be in English. Other
languages may be added to the label if applicable. Employers may use additional instructional
symbols that are not included in OSHA’s HCS pictograms on the workplace labels. An example
of an instructional pictogram is a person with goggles, denoting that goggles must be worn
while handling the given chemical. Including both types of pictograms on workplace labels is
acceptable. The same is true if the employer wants to list environmental pictograms or PPE
pictograms from the HMIS to identify protective measures for those handling the chemical.
Employers may continue to use rating systems such as National Fire Protection Association
(NFPA) diamonds or HMIS requirements for workplace labels as long as they are consistent with
the requirements of the Hazard Communication Standard and the employees have immediate
access to the specific hazard information as discussed above. An employer using NFPA or HMIS
labeling must, through training, ensure that its employees are fully aware of the hazards of the
chemicals used. If an employer transfers hazardous chemicals from a labeled container to a
portable container that is only intended for immediate use by the employee who performs the
transfer, no labels are required for the portable container.
Section G: Safety Data Sheets: Safety Data Sheets, previously referred to as Material
Safety Data Sheets, will now require a 16-section format that is essentially the same as the
ANSI standard for Hazardous Workplace Chemicals-Hazard Evaluation and Safety Data Sheets
and Precautionary Labeling Preparation (ANSI Z400.1 & Z129.1 - 2010), already familiar to U.S.
employers. Paragraph (g) lists the sections in the order they are to be provided on the Safety
Data Sheets.
Please note that below is a summary of the changes to the new HCS 2012 version as it pertains
to the Construction Industry. If it is not listed below, it simply does not apply or is still in place
but hasn’t changed. To see the complete list of the requirements set forth in this standard you
will need to refer to the updated HCS 2012.
HCS 1994
(g) Material safety data sheets.
(g)(1) Chemical manufacturers and importers
shall obtain or develop a material safety data
sheet for each hazardous chemical they
produce or import. Employers shall have a
material safety data sheet in the workplace for
each hazardous chemical which they use.
HCS 2012
(g) Safety data sheets.
(g)(1) Chemical manufacturers and importers
shall obtain or develop a safety data sheet for
each hazardous chemical they produce or
import. Employers shall have a safety data
sheet in the workplace for each hazardous
chemical which they use.
(g)(2) Each material safety data sheet shall be
in English (although the employer may
maintain copies in other languages as well),
and shall contain at least the following
information:
(g)(2) The chemical manufacturer or importer
preparing the safety data sheet shall ensure
that it is in English (although the employer
may maintain copies in other languages as
well), and includes at least the following
section numbers and headings, and associated
(g)(2)(i) The identity used on the label, and, information under each heading, in the order
except as provided for in paragraph (i) of this listed (See Appendix D to §1910.1200--Safety
Data Sheets, for the specific content of each
section on trade secrets:
section of the safety data sheet):
(g)(2)(i)(A) If the hazardous chemical is a
single substance, its chemical and common (i) Section 1, Identification;
name(s);
(ii) Section 2, Hazard(s) identification;
(g)(2)(i)(B) If the hazardous chemical is a
mixture which has been tested as a whole to (iii) Section 3, Composition/information on
determine its hazards, the chemical and ingredients;
common name(s) of the ingredients which
contribute to these known hazards, and the (iv) Section 4, First-aid measures;
common name(s) of the mixture itself; or,
(v) Section 5, Fire-fighting measures;
(g)(2) (i)(C) If the hazardous chemical is a
mixture which has not been tested as a whole: (vi) Section 6, Accidental release measures;
(g)(2)(i)(C)(1) The chemical and common
name(s) of all ingredients which have been
determined to be health hazards, and which
comprise 1% or greater of the composition,
except that chemicals identified as carcinogens
under paragraph (d) of this section shall be
listed if the concentrations are 0.1% or
greater; and,
(g)(2)(i)(C)(2) The chemical and common
name(s) of all ingredients which have been
determined to be health hazards, and which
comprise less than 1% (0.1% for carcinogens)
of the mixture, if there is evidence that the
ingredient(s) could be released from the
mixture in concentrations which would exceed
an established OSHA permissible exposure
limit or ACGIH Threshold Limit Value, or could
present a health risk to employees; and,
(vii) Section 7, Handling and storage;
(viii) Section 8, Exposure controls/personal
protection;
(ix) Section
properties;
9,
Physical
and
chemical
(x) Section 10, Stability and reactivity;
(xi) Section 11, Toxicological information.
(xii) Section 12, Ecological information;
(xiii) Section 13, Disposal considerations;
(xiv) Section 14, Transport information;
(xv) Section 15, Regulatory information; and
(g)(2)(i)(C)(3) The chemical and common
(xvi) Section 16, Other information, including
name(s) of all ingredients which have been
determined to present a physical hazard when date of preparation or last revision.
present in the mixture;
Note 1 to paragraph (g)(2): To be consistent
(g)(2)(ii) Physical and chemical characteristics with the GHS, an SDS must also include the
of the hazardous chemical (such as vapor headings in paragraphs (g)(2)(xii) through
pressure, flash point);
(g)(2)xv) in order.
(g)(2)(iii) The physical hazards of the Note 2 to paragraph (g)(2): OSHA will not be
hazardous chemical, including the potential for enforcing information requirements in sections
fire, explosion, and reactivity;
12 through 15, as these areas are not under
its jurisdiction.
(g)(2)(iv) The health hazards of the hazardous
chemical, including signs and symptoms of
exposure, and any medical conditions which
are generally recognized as being aggravated
by exposure to the chemical;
(g)(2)(v) The primary route(s) of entry;
(g)(2)(vi) The OSHA permissible exposure
limit, ACGIH Threshold Limit Value, and any
other exposure limit used or recommended by
the chemical manufacturer, importer, or
employer preparing the material safety data
sheet, where available;
(g)(2)(vii) Whether the hazardous chemical is
listed in the National Toxicology Program
(NTP) Annual Report on Carcinogens (latest
edition) or has been found to be a potential
carcinogen in the International Agency for
Research on Cancer (IARC) Monographs
(latest editions), or by OSHA;
(g)(2)(viii)
Any
generally
applicable
precautions for safe handling and use which
are known to the chemical manufacturer,
importer or employer preparing the material
safety data sheet, including appropriate
hygienic practices, protective measures during
repair and maintenance of contaminated
equipment, and procedures for clean-up of
spills and leaks;
(g)(2)(ix) Any generally applicable control
measures which are known to the chemical
manufacturer, importer or employer preparing
the material safety data sheet, such as
appropriate
engineering
controls,
work
practices, or personal protective equipment;
(g)(2)(x) Emergency and first aid procedures;
(g)(2)(xi) The date of preparation of the
material safety data sheet or the last change
to it; and,
(g)(2)(xii) The name, address and telephone
number of the chemical manufacturer,
importer, employer or other responsible party
preparing or distributing the material safety
data sheet, who can provide additional
information on the hazardous chemical and
appropriate
emergency
procedures,
if
necessary.
The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)), revised in 2012, requires
that the chemical manufacturer, distributor, or importer provide Safety Data Sheets (SDSs)
(formerly MSDSs or Material Safety Data Sheets) for each hazardous chemical to downstream
users to communicate information on these hazards. The information contained in the SDS is
largely the same as the MSDS, except now the SDS are required to be presented in a consistent
user-friendly, 16-section format. Sections 1 through 8 contain general information about the
chemical, identification, hazards, composition, safe handling practices, and emergency control
measures (e.g., fire fighting). This information should be helpful to those that need to get the
information quickly. Sections 9 through 11 and 16 contain other technical and scientific
information, such as physical and chemical properties, stability and reactivity information,
toxicological information, exposure control information, and other information including the date
of preparation or last revision. The SDS must also state that no applicable information was
found when the preparer does not find relevant information for any required element.
The SDS must also contain Sections 12 through 15, to be consistent with the UN Globally
Harmonized System of Classification and Labeling of Chemicals (GHS), but OSHA will not
enforce the content of these sections because they concern matters handled by other agencies.
Section H: Training Requirements: The provisions in paragraph (h) indicate that the new
label, safety data sheet formats and presentation of information must be discussed in training.
All employers will be required to conduct additional training to ensure that their employees are
familiar with the new standardized labels and safety data sheets.
provisions remain the same as the HCS 1994.
Otherwise, the training
Please note that below is a summary of the changes to the new HCS 2012 version as it pertains
to the Construction Industry. If it is not listed below, it simply does not apply or is still in place
but hasn’t changed. To see the complete list of the requirements set forth in this standard you
will need to refer to the updated HCS 2012.
HCS 1994
(h) Employee information and training.
(h)(1) Employers shall provide employees with
effective information and training on
hazardous chemicals in their work area at the
time of their initial assignment, and whenever
a new physical or health hazard the employees
have not previously been trained about is
introduced into their work area. Information
and training may be designed to cover
categories of hazards (e.g., flammability,
carcinogenicity)
or
specific
chemicals.
Chemical-specific information must always be
available through labels and material safety
data sheets.
Training shall include at least:
HCS 2012
(h) Employee information and training.
(h)(1) Employers shall provide employees with
effective information and training on hazardous
chemicals in their work area at the time of their
initial assignment, and whenever a new
chemical hazard the employees have not
previously been trained about is introduced
into their work area. Information and training
may be designed to cover categories of
hazards (e.g., flammability, carcinogenicity) or
specific
chemicals.
Chemical-specific
information must always be available through
labels and safety data sheets.
Training shall include at least:
(h)(3)(ii) The physical, health, simple
(h)(3)(ii) The physical and health hazards of asphyxiation, combustible dust and pyrophoric
the chemicals in the work area;
gas hazards, as well as hazards not otherwise
classified, of the chemicals in the work area;
(h)(3)(iv) The details of the hazard
communication program developed by the (h)(3)(iv) The details of the hazard
employer, including an explanation of the communication program developed by the
labeling system and the material safety data
employer, including an explanation of the
sheet, and how employees can obtain and use
labels received on shipped containers and the
the appropriate hazard information.
workplace labeling system used by their
employer; the safety data sheet, including the
order of information and how employees can
obtain and use the appropriate hazard
information.
The list below contains the minimum required topics for the training that must be completed by
December 1, 2013.
Training on label elements must include information on:
Type of information the employee would expect to see on the new labels, including the:
✓ Product identifier: how the hazardous chemical is identified. This can be (but is not
limited to) the chemical name, code number or batch number. The manufacturer,
importer or distributor can decide the appropriate product identifier. The same product
identifier must be both on the label and in Section 1 of the SDS (Identification).
✓ Signal word: used to indicate the relative level of severity of hazard and alert the
reader to a potential hazard on the label. There are only two signal words, “Danger” and
“Warning.” Within a specific hazard class, “Danger” is used for the more severe hazards
and “Warning” is used for the less severe hazards. There will only be one signal word on
the label no matter how many hazards a chemical may have. If one of the hazards
warrants a “Danger” signal word and another warrants the signal word “Warning,” then
only “Danger” should appear on the label.
✓ Pictogram: OSHA’s required pictograms must be in the shape of a square set at a
point and include a black hazard symbol on a white background with a red frame
sufficiently wide enough to be clearly visible. A square red frame set at a point without a
hazard symbol is not a pictogram and is not permitted on the label. OSHA has
designated eight pictograms under this standard for application to a hazard category.
✓ Hazard statement(s): describe the nature of the hazard(s) of a chemical, including,
where appropriate, the degree of hazard. For example: “Causes damage to kidneys
through prolonged or repeated exposure when absorbed through the skin.” All of the
applicable hazard statements must appear on the label. Hazard statements may be
combined where appropriate to reduce redundancies and improve readability. The
hazard statements are specific to the hazard classification categories, and chemical
users should always see the same statement for the same hazards, no matter what the
chemical is or who produces it.
✓ Precautionary statement(s): means a phrase that describes recommended measures
that should be taken to minimize or prevent adverse effects resulting from exposure to a
hazardous chemical or improper storage or handling.
✓ Name, address and phone number of the chemical manufacturer, distributor, or
importer
• How an employee might use the labels in the workplace. For example:
✓ Explain how information on the label can be used to ensure proper storage of
hazardous chemicals.
✓ Explain how the information on the label might be used to quickly locate information
on first aid when needed by employees or emergency personnel.
• General understanding of how the elements work together on a label. For example:
✓ Explain that where a chemical has multiple hazards, different pictograms are used to
identify the various hazards. The employee should expect to see the appropriate
pictogram for the corresponding hazard class.
✓ Explain that when there are similar precautionary statements, the one providing the
most protective information will be included on the label.
Training on the format of the SDS must include information on:
• Standardized 16-section format, including the type of information found in the various
sections
✓ For example, the employee should be instructed that with the new format, Section 8
(Exposure Controls/Personal Protection) will always contain information about exposure
limits, engineering controls and ways to protect yourself, including personal protective
equipment.
• How the information on the label is related to the SDS
✓ For example, explain that the precautionary statements would be the same on the
label and on the SDS.