GHS Labels and Blank Red Diamonds

GHS

GHS Labels and Blank Red Diamonds

Little Pro on 2018-11-02

A GHS pictogram on GHS labels should have a black symbol on a white background with a red frame. To meet this requirement, some companies purchase blank labels with pre-printed red diamonds and print GHS labels using black and white printer. This brings problems if a substance or mixture has fewer hazards on the number of blank red diamonds (usually 4). In this article, we will take a look at how different regional or national regulations treat those blank red diamonds (or red frames).

EU CLP Regulation

EU CLP regulation does not explicitly forbid blank diamonds. However, any information given in addition to the minimum mandatory labelling must not contradict or cast doubt on the mandatory label information. If empty red frames are unavoidable, it is recommended to cover them up with a solid overprint which blacks them out completely (see example below) - ref: page 29 of draft CLP labelling guidance.

EU CLP Blank Red Frames

US HCS 2012

HCS 2012 does not allow the use of blank red frames on labels. OSHA also does not permit words (e.g., "Intentionally Blank" or "No GHS Pictogram") to indicate that the red frame has been intentionally left blank (see example below). However, OSHA accepts EU CLP's approach of covering blank red frames with large black diamonds. - ref: OSHA letter

Blank Red Frame US OSHA

China GB 15258 and GB 13690

Chinese national standards GB 15258 and GB 13690 do not mention whether blank red frames on labels are accepted or not. It is generally not recommended to leave blank red diamonds on GHS labels for two reasons:

It is not consistent with sample GHS label given.
China accepts black frames for domestic use, which makes the use of pre-printed labels unecessary.

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