"GHS label" tab (for generating GHS labels)
Quick start
This tab enables you to generate a GHS label from the information you have entered on the previous tabs (SDS Sections 1-16). The label appears in a word processing area, which occupies most of the space on this tab.
Steps
1. Select a language — If you plan to create a GHS label in a non-English language, select the desired language from the language drop-down menu, at upper right on the entry form. For English-language labels, skip this step.
Language selection menu, SDS entry form.
Languages listed with a trailing asterisk (*) include built-in translation support. If you select a language that does not include the asterisk, then you may also need to create a custom translation group (CTG) for that language; refer to the background help on the "Custom translation groups" tab of the Phrase browse list (File menu -> Phrase translations).
If you plan to generate a bilingual label (English plus one other language), use this menu to select the non-English language to be used.
2. Begin — Click on the Label button at the bottom of the form, and select either an English or a non-English label option in the "GHS labels" (upper) menu section. For the bilingual label, you can choose either option; the result will be the same.
A non-English label option will be available in the Label button only if you selected a non-English language in the language drop-down menu (in the previous step).
Selecting the type of GHS label to generate, Label button.
3. Overwrite existing content — If text is already present in the word processing area, the program will ask you to confirm that it can overwrite the existing content. This action will not remove any information you have entered on other SDS form locations/tabs. Click on the Continue button to proceed.
If you do not see this confirmation request, skip this step.
Confirmation to overwrite existing content, word processing area.
4. Select label generation options — Next, the program presents options for customizing both the content and the appearance of the generated label. You can experiment with different settings, or stay with the default settings (click on the Defaults button to return to the default settings).
As long as you save the SDS record following label generation, the program will remember your GHS label generation option selections.
For a description of the options, refer to Label generation options, below.
"Select label generation options" dialog.
5. Build the label — Click on the OK button to generate the label, which will appear in the word processing area.
6. Save the SDS record — Click on the [S]ave button (disk icon) or the Done button, at the lower right on the entry form, to save your work. The generated label is part of the SDS record, so saving the SDS record also saves the generated label.
If you instead click on the Cancel button, then the generated label won't be preserved; nor will any revisions or other entries you have made since you last saved the SDS record.
Save, Done, and Cancel buttons.
7. Experiment (optional) — If you would like to view the effects of selecting different generation options, click on the (Build) Label button again (the Begin step, above), and change the settings in the "Select label generation options…" dialog.
8. Print label — The word processing area has its own toolbar, located immediately above the text entry area, containing tabs, icons, and menus to perform various functions. To print the label, click on the Print icon, which is shaped like a printer, at far left on the "Home" toolbar tab. (If the toolbar appears to be disabled, first click into the word processing area, and then on the Print icon).
Print the label (from the word processing toolbar; the Print icon is at far left).
Some label graphics (e.g., company logo, NFPA diamond) may lose some of their original sharpness when printed from an external word processing program. If you encounter this issue, you may want to print directly from the word processing area.
9. Save copy to disk (optional) — If desired, you can save a copy of the label to a separate file on disk, by clicking on the Export icon in the word processing area's toolbar (shaped like an inbox, with a down arrow). You can save the document in Microsoft® Word (.docx), html, pdf, plain text, or the native (.4wp, "4D Write Pro") format.
Click on the toolbar's Export icon to save the GHS label to a file on disk. The icon includes a pop-up menu of file types; the first option is the native (.4wp, "4D Write Pro") format. Rather than clicking on the Export icon, you can instead use the [Ctrl]-[Shift]-s keystroke to save the label in Word (.docx) format.
Managing help
· To set or cancel automatic help (this window): Click on the “Auto-help is” on/off pushbutton.
· To display this help window manually (when automatic help is off): Click on the Help button on the entry form (shortcut: [Ctrl]-?) and select “Background for this section”. The direct shortcut is [Ctrl]-9.
· To get an overview:
o Take the orientation tour to see how the SDS entry form works: Click on the Help button and select “Brief tour”.
o Read the “Features common to most SDS form sections/tabs” portion of the background help for SDS Section 1 (Tab "1 Identification").
· For brief tips, hover with your mouse over the object of interest.
· To learn additional details and requirements, read the details section, immediately below.
"Label" tab (for generating GHS labels) — details
SDScribe™ GHS label implementation
Obtaining hazard items for non-English labels
UN number, Transport hazard class(es), Packing group, Proper shipping name (alphanumeric fields)
Placards ("DOT" labels) – 1,2,3 (drop-down menus)
Lot, Net wt., Exp. on, Released for shipment on (alphanumeric fields and two date fields)
About style sheets (advanced topic)
Use an alternate font (default is Arial)
Include trade secrecy info. (where available)
For information on items common to most areas of the SDS entry form, refer to the "Background for this section" item in the Guide menu when viewing Section 1 (Identification).
Purpose
The purpose of the GHS Label tab is to generate a GHS-compliant label for the product in the word processing area, using information from other tabs on the SDS entry form.
"GHS Label" tab.
Content
By providing a few, basic elements in a standard format, GHS labels provide a quick reference to handlers, users, transporters, and persons who store hazardous chemicals.
A GHS label contains the following items[1]:
· The product identifier as used on the SDS. Identifiers include the product name, manufacturer's part/SKU number(s), common chemical name (if relevant), and identification numbers like the CAS number, EC number, REACH number, etc.
· The name, address, and telephone number of the chemical manufacturer, importer, or responsible party[2]
· The signal word
· Hazard (H-) statement(s)
· Precautionary (P-) statement(s)
· Pictogram(s)
Hazard statements and precautionary statements can be combined or consolidated to reduce label text and improve readability, provided that the results convey all hazards and precautions. Because of the many possible ways of consolidating these statements, however, the program leaves that option up to you. It will generate the complete statements, and then you can combine them together as you feel is appropriate.
Supplementary information
Content in addition to the bulleted items above can be included on a GHS label, provided that the information "provides further detail and does not contradict or cast doubt on the validity of the standardized hazard information"[3]. The supplementary information should be placed on the label so that it does not interfere with the user's ability to identify the required items.
The program provides options for inclusion of supplementary information, through specific SDS fields:
· Non-GHS classified hazards, in the "Other hazards (not otherwise classified)" field near the bottom of SDS Tab "2 Hazards".
· A statement on ingredients of unknown acute toxicity, entered into the field, "For mixtures with ingredients of unknown acute toxicity…", at the bottom of Tab "2 Hazards".
· A claim of confidentiality (trade secrecy) for one or more ingredient names or concentrations. You can enter the statement of confidentiality into the field, "Trade secret statement, if a specific chemical identity or exact percentage has been withheld", directly below the Component table on Tab "3 Composition".
In the Component table itself, you should also either check the "Name w/h" box (for US-OSHA compliance) or enter an alternative/generic name for each ingredient subject to the claim (for EU/EEA and Canadian compliance)[4].
Canadian claims may also require an HMIRA date and claim submission date (Tab "1 Identification").
· One particular label, "GHS-DOT landscape", provides an option for including more detailed first aid advice, drawn from Tabs "4.1 First aid" and "4.2 First aid". The fields that become incorporated on the label include:
o If inhaled
o In case of skin contact
o In case of eye contact
o If swallowed
US-OSHA requirements
Generally, manufacturers, importers, and distributors must affix GHS-compliant labels to individual containers of product as well as the external shipping containers. When an importer receives a shipment from overseas, they must affix the same labeling prior to further shipment. Additionally, importers must use workplace labeling (a slightly more flexible standard) while the materials are still in house, prior to transshipment to a US destination.
US-OSHA regulations state that,
"The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged, or marked. Hazards not otherwise classified do not have to be addressed on the container." 29 CFR 1910.1200(f)(1)
In somewhat ambiguous fashion, however, the regulations further state that the GHS labeling should not conflict with DOT labeling requirements (29 CFR 1910.1200(f)(5)).
In a letter of interpretation from June 2016, OSHA clarified that,
"…when sealed containers of hazardous chemicals are prepared for direct shipment to a destination outside of the U.S., and are placed inside of a U.S. Department of Transportation (DOT) or other similarly-approved shipping container, the manufacturer may label the sealed product containers for the destination country, rather than with an HCS 2012 label."
Continuing, however,
"…an HCS 2012 label compliant with paragraph 1910.1200(f)(1) must be on the outside of the shipping container or attached to any accompanying shipping papers or bill of lading. This accommodation will provide basic information to downstream workers, such as warehouse or dock workers who may be exposed in case of a spill or release or other emergency. The shipping container should also be labeled in accordance with DOT and/or International Maritime Organization (IMO) labeling regulations or requirements during shipping."
For solid materials like steel beams, metal castings, wood, plastic items, and whole grain which are not exempt as Articles due to downstream uses, OSHA allows labels to be transmitted with the initial shipment, or with an SDS transmitted prior to shipment.
OSHA also requires workplace labeling for each container of hazardous chemicals in the workplace, generally with the same information as a GHS label, but with somewhat more flexible means (29 CFR 1910.1200(f)(6)). For example, the employer may use,
"…signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required…" (29 CFR 1910.1200(f)(7))
If a manufacturer ships very small items like ampoules enclosed in a larger shipping container, OSHA still requires individual container labeling plus shipping container labeling. However, in a letter of interpretation from June 2013, OSHA provided what they considered a "practical accommodation":
"…where the manufacturer can show that it is not feasible to use pull-out labels, fold back labels, or tags, containing the full HCS 2012 required information, the shipped small container (i.e., the actual container holding the hazardous chemical), at a minimum, must contain the following:
· Product identifier
· Appropriate pictograms
· Manufacturer's name and phone number
· Signal word
· A statement indicating the full label information for the chemical is provided on the outside package.
Additionally, the outside packaging, at a minimum, must comply with the following:
· All the applicable label elements, as defined in 29 CFR 1910.1200(f)(1).
· The outside package must be clearly marked to ensure the complete label elements are visible and it must clearly inform users that the small container must be stored in the outer container bearing the complete label. The complete label must be maintained on the outer package (e.g., not torn, defaced, destroyed).
· The manufacturer must ensure that any alternative labeling used does not conflict with any other standards. As such, the outside packaging must not present a hazard while the material is being stored."
EU/EEA requirements
The EU Chemical Labeling and Packaging (CLP) regulations mostly follow the same GHS label content as the US-OSHA HCS 2012 standards. However, there is more detail plus some differences,
· The CLP has a wider range of application than HCS 2012, and consequently there are some additional requirements for items sold to the general public. These additional requirements include specification of the volume of the containers, and child-resistant fastenings, and tactile warnings for certain hazard classes.
· Unlike US-OSHA, the ECHA deems it sufficient for outer (shipping) packaging to carry only labeling and/or markings in accordance with transport legislation; the CLP labeling need not appear there.
· Generally, the CLP label should include no more than six precautionary statements on a label.
· For mixtures, labels should include the "identity of all substances in the mixture that contribute to the classification of the mixture as regards acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, respiratory or skin sensitisation, specific target organ toxicity (STOT) or aspiration hazard." (CLP Article 18(3)(b))
· Rather than the accommodation that OSHA provides for smaller containers, the CLP contains specific exemptions for packages of 125 ml or less. The exemptions allow for omission of hazard and precautionary statements for specific hazard classifications; and omission of the pictogram for the corrosive-to-metals classification. (CLP Annex I, 1.5.2.1)
· There is an additional exemption from labeling "soluble packaging intended for single use" of 25 ml or less. (CLP Annex I, 1.5.2.2)
SDScribe™ GHS label implementation
Selecting a language
If you intend to generate a GHS label in a non-English language, select the language to be used for label generation using the drop-down menu in the upper right corner of the SDS entry form. If you plan to generate a bilingual label, select the non-English language to be used.
Language selection menu, SDS entry form.
This menu is the same one that governs the language to be used on the "Build SDS non-English" tab, for generating an SDS in languages other than English.
Starting label generation
Click on the (Build) Label button. The program will present the "Select label generation options…" dialog. Make appropriate selections, use previously-remembered selections, or click on the "Defaults" button to restore program defaults. Then click on the OK button to proceed.
Obtaining hazard items for non-English labels
If you have selected a language other than English for label generation, the program will use hazard classifications, hazard (H-) statements, and precautionary (P-) statements in the non-English language, if they are available within the program.
The languages that appear in the menu with a trailing asterisk (*) are most likely to have a complete set of hazard items. The order in which the program obtains hazard items is the same as for generating a non-English SDS:
1. The contents of the "Description (click translate**)" (non-English) column, in the hazard table.
2. For hazard classifications in asterisked languages: internal hazard class conversion tables for the specified language.
3. For hazard classifications in non-asterisked languages: a user-generated custom translation group (CTG) for the specified language.
4. For H-statements and P-statements: the Phrase translations section of the program (File menu -> Phrase translations -> "GHS H-P-statements and signal words" tab.
5. As a last resort, the English-language statement for the hazard, from the Hazard table in Tab "2 Hazards".
For a more complete discussion of hazard items in non-English languages, refer to the "Background for this section" item in the Help menu, when viewing the "Build SDS non-English" tab.
Entry form features
UN number, Transport hazard class(es), Packing group, Proper shipping name (alphanumeric fields)
These editable fields also appear on Tab, "14.2 Transport (EU)". They repeat here because GHS labels typically use them to identify the product; you can modify them without switching back and forth to the other tab.
Placards ("DOT" labels) – 1,2,3 (drop-down menus)
Depending on the selected label format, some generated GHS labels can incorporate DOT-style shipping diamonds as graphic elements. You can add up to three, one from each drop-down menu. The menu items represent file names on disk, which are located in the "Resources/DOT labels" folder. The specific path is:
~/SDScribe/Database/Resources/DOT_labels/
You can add your own graphics into this folder, as well. The file names will appear in the three drop-down menus.
To avoid confusion, do not place these graphic elements on the generated label next to the GHS pictograms. Avoid making them the same size as the pictograms.
Lot, Net wt., Exp. on, Released for shipment on (alphanumeric fields and two date fields)
These fields can be used to provide information about provenance: lot or batch number, net weight, and expiration and release dates. The lot number and net weight are alphanumeric rather than numeric fields, so that you may use letters in the batch number, and add units of measure after the net weight.
(Build) Label (button)
Click on this button and then select English or the non-English language, to generate the label in the word processing area.
The program will present a dialog of options ("Select label generation options"). For more information on the options in this dialog, refer to label generation options, below.
If text is already present in the word processing area, then the program will ask you to confirm that you wish to erase the existing text.
Word processing area
Word processing area, GHS Label tab.
The word processing area occupies the lower middle of the entry form. It is essentially the same as the word processing areas on the Build SDS and Build SDS non-English tabs, except that it holds the generated GHS label instead of a generated SDS. The word processing area is fully editable: you can move text, change fonts, add spaces, underlining, italics, etc., as desired.
To avoid user confusion between GHS pictograms and DOT-style hazard symbols, they should not be placed immediately adjacent to each other on the label, and should be in different sizes.
You can use the word processor area toolbar, located above the text entry area, to perform a variety of functions. To print the label, click on the Print icon (shaped like a printer) from the "Home" tab of the toolbar.
Print icon (at far left), word processing area toolbar.
To save the label as a separate document on disk, click on the Export icon (shaped like an inbox with a down arrow), from the "Home" tab of the toolbar. From the pop-up menu that appears, select the file type: Word (.docx), html, pdf, text, scaled vector graphics (SVG), etc. You can also use the keystroke, [Ctrl]-[Shift]-s to save in Word (.docx) format only.
The Export icon in the word processing toolbar (second from left, lower) displays a pop-up menu of file types.
Label generation options
As noted above, when you click on the Build label button, the program presents a dialog of options:
"Select label generation options" dialog.
Label format to use
Specifies the GHS label configuration that you would like to generate. At present there are five in the program. The number of pages required for each label will depend on various factors, including the number of hazard (H-) and precautionary (P-) statements and their length.
Bulleted descriptions below indicate the order of appearance of the printed items on the label.
GHS portrait
· Format: 8.5 x 11-inch, portrait, single column
· The chemical name or (if empty) the product name, in inverse text (white text on a black background)
· Other identifiers (where present): CAS number, EC number, UN shipping number, chemical formula, and HMIRA registration number (Canada)
· Signal word (in red)
· Pictograms
· Unique Formula Identifier (UFI) number, used by EU/EEA poison control centers.
· Hazard (H-) statements, listed in order of their appearance in the Hazard table (Tab "2 Hazards")
· Precautionary (P-) statements, grouped into 200, 400, and 500 series categories and then listed within groups in order of appearance in the Hazard table (Tab "2 Hazards"). The 300-series P-statements appear below the others, beneath a "FIRST AID" title
· Other hazards, where present in the "Other hazards (not otherwise classified)" field, below the Hazard table on Tab "2 Hazards"
· A statement of percentage(s) for ingredients of unknown acute toxicity, if the statement is present on Tab "2 Hazards".
· HMIRA registration number, where present, on Tab "1 Identification". You must also check the box: "Include trade secrecy info. (where available)" on the label generation options dialog.
· The field, "Trade secret statement, if a specific chemical identity or exact percentage has been withheld", from Tab "3 Composition". You must also check the box: " Include trade secrecy info. (where available)" on the label generation options dialog.
· The HMIS color bars and the NFPA diamond, if any ratings are present for them on Tab "15.2 Regulatory". The HMIS title block uses the chemical name or (if empty) the product name.
· Product ingredients, if selected in the label generation options dialog
· CA Prop. 65 warning, if selected in the label generation options dialog
· The supplier logo from Tab "1 Identification" or (if none) the company logo from Preferences
· The supplier name, address and telephone number from Tab "1 Identification" (address field order for Canadian and US addresses is different from other countries).
· Where available, the product lot number, weight, and expiration date
"GHS Portrait" label format, first and continuation pages. NOTE: Details are fictitious.
GHS portrait simplified
· Format: 8.5 x 11-inch, portrait, two columns.
· The product name or (if empty) the chemical name, left justified in the header. For longer labels, the name will appear on subsequent pages as well.
· Signal word (in red)
· Pictograms
· Unique Formula Identifier (UFI) number, used by EU/EEA poison control centers.
· Hazard (H-) statements, listed in order of their appearance in the Hazard table (Tab "2 Hazards")
· Precautionary (P-) statements, grouped by category (100, 200, 300, 400, 500 series) and then listed within category by order of appearance in the Hazard table (Tab "2 Hazards")
· Other hazards (where present in the "Other hazards (not otherwise classified)" field, below the hazard table on Tab "2 Hazards".
· A statement of percentage(s) for ingredients of unknown acute toxicity, if the statement is present on Tab "2 Hazards".
· HMIRA registration number, where present on Tab "1 Identification". You must also check the box: "Trade secrecy" on the label generation options dialog.
· Trade secrecy statement: the field, "Trade secret statement, if a specific chemical identity or exact percentage has been withheld", from Tab "3 Composition". You must also check the box: "Include trade secrecy info. (where available)" on the label generation options dialog.
· Product ingredients, if selected in the label generation options dialog
· CA Prop. 65 warning, if selected in the label generation options dialog
· The supplier logo from Tab "1 Identification" or (if none) the company logo from Preferences
· The supplier name, address and telephone number from Tab "1 Identification"
"GHS portrait simplified" label format. NOTE: Details are fictitious.
GHS-DOT landscape
· Format: 8.5 x 11-inch, landscape, two columns
· Supplier name, address, and telephone number
· UN shipping name, transport number, transport hazard class(es), and packing group.
· Signal word (red)
· Hazard (H-) statements, each with prefixing code, listed in order of their appearance in the Hazard table (Tab "2 hazards").
· Precautionary (P-) statements, each with prefixing code, listed in order of their appearance in the Hazard table (Tab "2 hazards").
· Pictograms
· Unique Formula Identifier (UFI) number, used by EU/EEA poison control centers.
· Where available on Tabs "4.1 First aid" and "4.2 First aid", text in the fields
o In case of skin contact
o In case of eye contact
o If inhaled
o If swallowed
· The HMIS color bars and the NFPA diamond, if ratings are present for these items on Tab "15.2 Regulatory". The HMIS title block uses the chemical name or (if empty) the product name.
· Other hazards (where present in the "Other hazards (not otherwise classified)" field, below the Hazard table on Tab "2 Hazards"
· A statement of percentage(s) for ingredients of unknown acute toxicity, where the statement is present on Tab "2 Hazards"
· HMIRA registration number, where present, on Tab "1 Identification". You must also check the box: " Include trade secrecy info. (where available)" on the label generation options dialog.
· Trade secrecy statement: the field, "Trade secret statement, if a specific chemical identity or exact percentage has been withheld", from Tab 3 (Composition). You must also check the box: "Include trade secrecy info. (where available)" on the label generation options dialog.
· Product ingredients, if selected in the label generation options dialog
· CA Prop. 65 warning, if selected in the label generation options dialog
· The product name
· Up to three DOT–style, diamond-shaped (or custom) graphic elements, from the "Shipping labels" (1, 2, 3) drop-down menus
· The supplier logo from Tab "1 Identification" or (if none) the company logo from Preferences
· When available, product lot number, weight, and expiration date
"GHS-DOT landscape" label format, first and continuation pages. NOTE: Details are fictitious.
GHS-DOT portrait
· Format: 8.5 x 11-inch, portrait, two columns
· The supplier logo from Tab "1 Identification" or (if none) the company logo from Preferences
· Product number
· Product name or (if absent) chemical name
· Lot number
· Supplier name, address, and telephone number
· UN transportation number
· Signal word (red)
· Pictograms
· Unique Formula Identifier (UFI) number, used by EU/EEA poison control centers.
· Hazard (H-) statements, listed in order of their appearance in the Hazard table (Tab "2 Hazards")
· Precautionary (P-) statements, listed in order of their appearance in the Hazard table (Tab "2 Hazards"), except that the 300-series P-statements appear separately under a "FIRST AID" title.
· The HMIS color bars and the NFPA diamond, if any ratings are present for them on Tab "15.2 Regulatory". The title block uses the chemical name or (if empty) the product name.
· Up to three DOT–style, diamond-shaped (or custom) graphic elements, from the "Shipping labels" (1, 2, 3) drop-down menus
· Other hazards (where present in the "Other hazards (not otherwise classified)" field, below the Hazard table on Tab "2 Hazards".
· A statement of percentage(s) for ingredients of unknown acute toxicity, where the statement is present on Tab "2 Hazards"
· HMIRA registration number, where present, on Tab "1 Identification". You must also check the box: "Include trade secrecy info. (where available)" on the label generation options dialog.
· Trade secrecy statement: the field, "Trade secret statement, if a specific chemical identity or exact percentage has been withheld", from Tab 3 (Composition). You must also check the box: "Include trade secrecy info. (where available)" on the label generation options dialog.
· Product ingredients, if selected in the label generation options dialog
· CA Prop. 65 warning, if selected in the label generation options dialog
"GHS-DOT Portrait" label format. NOTE: Details are fictitious.
Bilingual
· Format: 8.5 x 11-inch, portrait, three-column table with topics horizontally matched into rows (first column hidden, as a spacer from the left margin; second column English; third column non-English).
o You must select a non-English language in the language drop-down menu, upper right on the SDS entry form.
· Product number (hyphen) and product name or (if absent) chemical name
· Unique Formula Identifier (UFI) number, used by EU/EEA poison control centers.
· Pictograms
· Matching rows in second and third columns, with the third column in the non-English language:
o Signal word (red)
o Hazard (H-) statements, listed in order of their appearance in the Hazard table (Tab "2 Hazards")
o Precautionary (P-) statements, grouped by category (100, 200, 300, 400, 500 series) and then listed within each category by order of appearance in the Hazard table (Tab "2 Hazards").
o Other hazards (where present in the "Other hazards (not otherwise classified)" field, below the Hazard table on Tab "2 Hazards".
o A statement of percentage(s) for ingredients of unknown acute toxicity, where the statement is present on Tab "2 Hazards"
o HMIRA registration number, where present, on Tab "1 Identification". You must also check the box: "Include trade secrecy info. (where available)" on the label generation options dialog.
o Trade secrecy statement: the field, "Trade secret statement, if a specific chemical identity or exact percentage has been withheld", from Tab 3 (Composition). You must also check the box: "Include trade secrecy info. (where available)" on the label generation options dialog.
o Product ingredients, if selected in the label generation options dialog
o CA Prop. 65 warning, if selected in the label generation options dialog
· The supplier logo from Tab "1 Identification" or (if none) the company logo from Preferences
· Supplier name, address, and telephone number
"Bilingual" label format, first and continuation pages. NOTE: Details are fictitious.
Ingredients
Indicate whether and how you would like to include ingredients (SDS components) on the label. The menu options allow you to exclude components for which you are making a claim of trade secrecy/confidential business information.
Ingredient options, "Select label generation options" dialog.
About style sheets (advanced topic)
The SDScribe™ word processing area makes use of style sheets that are similar to those used in a standalone word processing program, like Microsoft® Word. After you generate the label, the name of each style sheet appears under the "Style sheet" toolbar tab, above the word processing area. When you click into the text, the drop-down menu will display the style sheet for the text where the cursor is located.
Style menu, "Style sheet" toolbar tab. The menu indicates "Plain left 12pt" as the style for the highlighted text.
You can take advantage of this feature to manually customize the style of the generated label. For example, you could change the text to italic by clicking on the "I" icon in the toolbar, and then clicking on the circular arrow to the right of the style name. Then all instances of that style in the label will be italicized.
Appearance of the label after clicking on the "I" icon, and then updating the style (clicking on the circular arrow to the right of the style name).
However, these manual style sheet customizations apply only to the label that you have generated, in the current SDS record. If you regenerate the label by clicking on the (Build) Label button again, the customizations you made to style sheets for the previous label will be gone.
Use an alternate font (default is Arial)
Selecting a font from the drop-down menu causes the label style sheets to incorporate the new font, rather than defaulting to Arial.
An alternate font may provide a look that is more suited to your company image. However, some fonts may require more space in larger sizes (for example, in document titles). You may need to experiment with different fonts to obtain a desired look.
Include trade secrecy info. (where available)
Check this box when you want the label to include your HMIRA registration number and your trade secrecy statement (if either are available).
CA Prop 65 (if relevant)
This setting places a California Proposition 65 ("Prop. 65") warning on the label. The label follows the "safe harbor" language that the state adopted in 2016 and implemented in 2018.
The program checks the linked Substance record for each of the product components, to determine whether one or more of them have a Prop. 65 listing with no delisting date.
Prop. 65 warning options.
Besides "Do not include", there are at present three options offered for the warning:
Label (full) warning
This option includes both the chemical name(s) of the component(s) and the type of hazard they pose ("cancer" and/or "birth defects or other reproductive harm"). The program will look for a synonym of the type "Prop. 65 name" to incorporate into the warning. If you have selected a non-English language on the entry form (top right on the form), the program will also look for a synonym in that language[5]. If the program cannot find a non-English Prop. 65 name, it will substitute the English Prop. 65 name. If it cannot find the English Prop. 65 name, it will substitute another synonym.
When chemical name substitutions are necessary (i.e., there is no "Prop. 65 name"-type synonym in the Substance record), then the program will embed an alert. An example of such an alert is:
[**alt name used; may not be Prop. 65 name**]
The presence of a bracketed alert such as this one is your signal that further investigation is warranted; you will need to adjust the wording of the Prop. 65 warning before using the label with the product.
Sample of a Prop. 65 "full" warning in Spanish and English, identifying two Prop. 65-listed components of a product. Note the presence of the bracketed alerts, "[**translation may be needed**], which indicate that the chemical names used in the Spanish portion should be verified. Delete the bracketed alerts once you have verified the chemical names.
Product (short) warning
The product warning does not include the name(s) of the components, and is significantly shorter than the "Label (full) warning" option.
Sample of a Prop. 65 "short" warning in Spanish and English, for Prop. 65-listed components of a product (which the label does not identify by name).
Product (short) warning 2024
This warning is a combination of the two earlier warnings, which like the full warning includes the name of the substance(s) for which the warning is relevant, but also is abbreviated like the other short warning. This option will be required for the short warning in the year 2028.
Final page of a bilingual GHS label, showing the 2024 Prop. 65 warning. NOTE: Details are fictitious.
Disclaimer
Because of the legal issues surrounding Prop. 65 notifications, the program always inserts a disclaimer onto the label for you to read. You should remove the disclaimer from the label before placing the label onto your product.
Logo scaling
Use this setting to scale the logo (from Tab "1 Identification") between 20 and 200 percent of its normal size. Values of zero or 100 result in no scaling.
[rev. 2.13.2025]
[1] Refer to the US-OSHA requirements at 29 CFR 1910.1200(f)(1)
[2] In 29 CFR 1910.1200 Appendix C (C.1.1), the US-OSHA regulation states, "The labels on shipped containers shall also include the name, address, and telephone number of the chemical manufacturer, importer, or responsible party."
[3] US-OSHA regulations at 29 CFR 1910.1200 Appendix C (C.3.1)
[4] Claims of confidentiality differ depending on the country or other jurisdiction. For example, Canada and the EU/EEA allow the use of "alternative" chemical names for ingredients (more generic than the specific chemical name), but the EU/EEA does not allow deviations from the actual ingredient concentration or concentration range. Both require pre-approval of the claim, whereas US-OSHA does not. For more information, refer to the Guide window and background information for Tab "3 Composition".
[5] Where a label is to be printed in a non-English language, California regulations currently require that the Prop. 65 warning appear both in the non-English language and in English.