Don't Eat It!
Eat Me! Drink Me! Consuming unknown substances usually only ends well in fairytales… and even then, it’s often a gamble.
While it may seem like a good idea at the time, in the long run, it’s probably not. There are several rules and guidelines in any shop you visit, but in mine, the number one rule is: Don’t eat it! This rule applies to anything and everything. In my experience, mixing food, drink, and scenic paint rarely ends well. Looks can be deceiving, and as tempting as that rich, silky-smooth chocolate pudding may be, it’s probably best not to sample it if it resides in your shop. To an untrained bystander, Rosco’s Burnt Umber paint and chocolate pudding look shockingly similar. To protect them, OSHA has required that all secondary containers be properly labeled. This is the surefire way to tell the difference between your paint and your lunch. Don’t Eat It!
Osha Standard: 1910.1200(f)(6)(ii)
“Product identifier and words, pictures, symbols, or a 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.”
Understanding and Simplifying Osha Labeling Regulations:
- The first thing to remember is that all secondary containers must be labeled.
- Secondly, the labels must be clear and easy to read. If a label becomes illegible or is defaced in any way, it needs to be replaced.
- Finally, certain elements are required to be included in the labeling of secondary containers.
It’s also important to note that generally, all containers must be suitable for the product that will be stored in them. In California, this means that any container intended for food may not be used for paint. While recycling old yogurt containers may seem environmentally friendly, they cannot be used due to OSHA standards, as the plastic is food-grade and not chemical-grade.
The Cal/OSHA Hazard Communication Regulation— a Guide for Employers That Use Hazardous Chemicals
Precautionary Statement:
PPE Levels
Part A.Personal protective equipment is divided into four categories based on the degree of protection afforded. (See part B of this appendix for further explanation of Levels A, B, C, and D hazards.)
Level A – To be selected when the greatest level of skin, respiratory, and eye protection is required.
The following constitute Level A equipment; it may be used as appropriate:
- Positive pressure, full face-piece self-contained breathing apparatus (SCBA), or positive pressure supplied air respirator with escape SCBA, approved by the National Institute for Occupational Safety and Health (NIOSH).
- Totally-encapsulating chemical-protective suit.
- Coveralls.
- Long underwear.
- Gloves, outer, chemical-resistant.
- Gloves, inner, chemical-resistant.
- Boots, chemical-resistant, steel toe and shank.
- Hard hat (under suit).
- Disposable protective suit, gloves, and boots (depending on suit construction, may be worn over a totally encapsulating suit).
Level B – The highest level of respiratory protection is necessary but a lesser level of skin protection is needed.
The following constitute Level B equipment; it may be used as appropriate:
- Positive pressure, full-facepiece self-contained breathing apparatus (SCBA), or positive pressure supplied air respirator with escape SCBA (NIOSH approved).
- Hooded chemical-resistant clothing.
- Coveralls.
- Gloves, outer, chemical-resistant.
- Gloves, inner, chemical-resistant.
- Boots, outer, chemical-resistant steel toe and shank.
- Boot-covers, outer, chemical-resistant.
- Hard hat.
- Face shield.
Level C – The concentration(s) and type(s) of airborne substance(s) are known and the criteria for using air-purifying respirators are met.
The following constitute Level C equipment; it may be used as appropriate:
- Full-face or half-mask, air purifying respirators (NIOSH approved).
- Hooded chemical-resistant clothing.
- Coveralls.
- Gloves, outer, chemical-resistant.
- Gloves, inner, chemical-resistant.
- Boots (outer), chemical-resistant steel toe and shank.
- Boot-covers, outer, chemical-resistant.
- Hard hat.
- Escape mask.
- Face shield.
Level D – A work uniform affording minimal protection, used for nuisance contamination only.
The following constitute Level D equipment; it may be used as appropriate:
- Coveralls.
- Gloves.
- Boots/shoes, chemical-resistant steel toe and shank.
- Boots, outer, chemical-resistant (disposable).
- Safety glasses or chemical splash goggles.
- Hard hat.
- Escape mask.
- Face shield.
Part B. The types of hazards for which level A, B, C and D protection are appropriate are described below:
Level A – Level A protection should be used when:
- The hazardous substance has been identified and requires the highest level of protection for skin, eyes, and the respiratory system based on either the measured (or potential for) high concentration of atmospheric vapors, gasses, or particulates; or the site operations and work functions involve a high potential for splash, immersion, or exposure to unexpected vapors, gasses, or particulates of materials that are harmful to skin or capable of being absorbed through the skin;
- Substances with a high degree of hazard to the skin are known or suspected to be present, and skin contact is possible; or
- Operations are being conducted in confined, poorly ventilated areas, and the absence of conditions requiring Level A has not yet been determined.
Level B – Level B protection should be used when:
- The type and atmospheric concentration of substances have been identified and require a high level of respiratory protection, but less skin protection;
- The atmosphere contains less than 19.5 percent oxygen;
The presence of incompletely identified vapors or gasses is indicated by a direct-reading organic vapor detection instrument, but vapors and gasses are not suspected of containing high levels of chemicals harmful to the skin or capable of being absorbed through the skin.
Note: This involves atmospheres with IDLH concentrations of specific substances that present severe inhalation hazards and that do not meet the criteria for the use of air-purifying respirators.
Level C – Level C protection should be used when:
- The atmospheric contaminants, liquid splashes, or other direct contact will not adversely affect or be absorbed through any exposed skin;
- The types of air contaminants have been identified, concentrations measured, and an air-purifying respirator is available that can remove the contaminants; and
- All criteria for the use of air-purifying respirators are met.
Level D – Level D protection should be used when:
- The atmosphere contains no known hazard; and
- Work functions preclude splashes, immersion, or the potential for unexpected inhalation of or contact with hazardous levels of any chemicals.
Note: As stated before, combinations of personal protective equipment other than those described for Levels A, B, C, and D protection may be more appropriate and may be used to provide the proper level of protection.
Labeling regulations have established standards, and once you understand what they require, filling in the necessary information becomes straightforward. In conclusion, there are five key pieces to this puzzle:
- Identifying your product
- Assigning a Hazard Rating
- Providing Signal Words
- Deciding on a Pictogram
- Selecting a Precautionary Statement Level
Often, the information you need can be found on the primary container label, allowing you to simply copy and paste it. We hope that this information helps unravel the complexities of labeling regulations and makes it easier to comprehend this government standard. Feel free to share this blog with your fellow Scenics to make their lives easier as well. Let us know in the comments below what else we can help simplify!
A California-born scenic artist, René Nielsen has an Associate’s Degree in Fine Arts from Allan Hancock College, and a Bachelor of Fine Arts in Theater Arts from Southern Oregon University (SOU) with an emphasis in Scenic Art. René has her Master of Fine Arts in Theater Arts from San Diego State University (SDSU) emphasizing Scenic Design and Technology, studying under Ralph Funicello. René graduated Magna Cum Laude from SOU. René has worked at Cal State University, Fresno as the Scenic Charge and Props Master since August 2017.
