Transition Guide to the HMIS® III for Chemical Manufacturers, Suppliers, and Distributors

1.0 Introduction

This document is intended to assist chemical manufacturers, suppliers, or distributors who are currently using an older version of the HMIS^® (First or Second Edition) in implementing the new HMIS^® Third Edition (HMIS^® III).  While there is no one “right” way to accomplish this transition, the procedures in this guide were developed by industry participants who have actually made the transition and learned from it.  Following this transitional blueprint can help make your transition error and confusion free.

Please note that a large portion of this document is directed at to the end users, or potential end users, of the HMIS^® III—your customers. Section 4.0 speaks to your (the chemical manufacturer, supplier, or distributor) transition from earlier versions of the HMIS^®.

2.0 Why Use HMIS^®?

HMIS^® has become an industry standard for hazcom labeling. In order to provide value-added service to your customers, we recommend providing HMIS^® III ratings and labels on your documentation and packaging. This will also help to reduce customer inquiries.

Every employer is responsible for providing their employees with a safe and healthy workplace. Hazard communication is an important part of this responsibility. Employers must be trained to recognize the potential hazards of diverse chemicals and properly deal with these hazards through work practice procedures and the use of personal protective equipment (PPE). Additionally, hazard communication is the law. The Occupational Safety and Health Administration’s (OSHA) standard titled “Hazard Communication” found in Title 29 (Labor) of the Code of Federal Regulations (CFR) part 1910, section 1200, requires chemical manufacturers, importers, distributors, and employers to provide hazard information to employees and customers.

HMIS^® serves as a primary means of complying with the OSHA Hazard Communication Standard (known as “the standard” or “HCS”). The HMIS^® Implementation Manual, Third Edition, may be used as the basis of a written hazard communication plan. The rating, labeling, and training portions of the implementation process satisfy many of OSHA’s requirements for hazard evaluations, workplace labeling of hazardous materials, and employee instruction, respectively.

OSHA stated in the Preamble to the 1983 HCS that “Labels prepared in accordance with NPCA’s Hazardous Materials Identification System would generally be in compliance with this standard.” OSHA re-confirmed the acceptability of HMIS^® as an in-plant hazard communication tool by stating in the Preamble to the 1994 Revised Final Hazard Communication Standard, that this type of system continues to be an acceptable means of complying with the standard, providing adequate attention is given to target organ hazards during employee training.

3.0 In What Way Has HMIS^® Changed?

The HMIS^® Implementation Manual, Third Edition, is designed to be a BETTER and more COMPREHENSIVE compliance tool for employers’ use in meeting requirements of the Occupational Safety and Health Administration (OSHA) HCS.  Significant changes in the third edition include the following:

A.      Changes in definitions provide better alignment with language found in the HCS.  The third edition HMIS® adopts OSHA’s criteria for “Flammability” rating, and adds a “Physical Hazards” category with seven subcategories:

• Water Reactive
• Organic Peroxides
• Explosives
• Compressed Gasses
• Pyrophorics
• Oxidizers
• Unstable Reactives

B.      The HMIS® label has been revised to better utilize the physical hazard ratings. On the new labels a field entitled “Physical Hazard” replaces “Reactivity.” The new Physical Hazard field is orange, to distinguish it from the yellow Reactivity field. A yellow border makes the label more visually distinctive, and the colors used on the label comply with the most recent American National Standard Safety Color Code (ANSI Z534.1-1998).

C.      New ICONS are available to identify specific health and physical hazards.  The ICONS support “at-a-glance” hazard recognition and aid employers with internal product labeling, informing employees of the specific nature of the chemical hazard as emphasized by OSHA.  ICON stickers are now available for Target Organs, Physical Hazards, and Personal Protective Equipment (PPE).

D.      Chapter 12 (Hazard Communication Training) of the Manual has been expanded to include the most current information and guidance that OSHA offers on the topic, with increased training emphasis on understanding Target Organ hazards. This chapter also explains how to effectively incorporate HMIS® into your site-specific Hazard Communication Training Program using new training aids covered in Chapter 13, Employee Training Materials.  Training aids also reflect the changes in label and ICON options.

4.0 How do I Manage the Transition from the Current Version of HMIS^® to the HMIS^® III?

The most important modifications of the HMIS^® are the new Physical Hazard rating criteria and the introduction of icons to convey the specific physical hazards and the Target Organ hazards posed by the chemical or chemical mixture.  These changes will most significantly affect training and labeling of materials within the facility.

4.1  How do I Manage this Transition for Out-Of-Plant (Downstream) Uses of the HMIS^®?

Chemical manufacturers, suppliers, or distributors who choose to provide HMIS^® III ratings and/or labels on MSDSs or who place HMIS^® III Labels on products which leave their facility are not required to provide training to downstream users of those chemicals. Including HMIS^® information on the MSDS or the label is not required. But if you do choose to include HMIS^® information on the label and/or MSDS, then we have a few recommendations on making the transition.

4.1(A)  MSDSs

As with the In-Plant transition recommendations, the new HMIS^® III ratings and labels may be placed on MSDSs that are due for revision first.  The other MSDSs may be scheduled over a predetermined period of time, dictated by the number of MSDSs involved.

We recommend that explanatory text be placed in close proximity to the New HMIS^® III ratings or labels indicating that they reflect new ratings criteria and directing the reader to a part of the MSDS with a more detailed explanation.  As an example, the following may be considered for use:

And, Section III may contain the following “explanation”

HMIS^® III:  The HMIS^® III ratings displayed on the front of this MSDS are from the HMIS^® Third Edition.  There have been significant changes made to the system.  “PH” stands for “Physical Hazard” as defined in the OSHA Hazcom Standard and replaces the former code “R” for “Reactivity.”   For a more detailed explanation of the system and the ratings, please contact our Health, Safety, and Environmental Staff at [your phone number or address]

As before, preparers of MSDSs should not place HMIS^® personal protection equipment (PPE) designation codes on the MSDSs or labels that leave the facility, as they do not know the conditions under which their customers use those products.

4.1(B) Product Labels

Container label stock often represents a significant monetary investment for many companies.  If HMIS^® labels are to be placed on product containers leaving the facility, either as part of the label or as an independent stick-on, we recommend the following:

For new container label stock, containing the new HMIS^® III labels, replace the old ones initially on products which are due for label revisions and then on the products whose labels are relatively static or established.  This may be accomplished as resources permit in a predetermined, metered fashion.  We also recommend that either a statement be added to the label immediately below the HMIS^® III label identifying it as “new” and providing a short explanation, or a brochure explaining the details of the new HMIS^® III program be provided with the product. 

Another recommendation for those companies that are undecided whether to convert to the new HMIS^® III would be to remove the HMIS^® from the product labels as revisions occur now and reinstate at a later date.

In all cases, please remember that including HMIS^® on your product labels is voluntary.   There are no Federal/State/Local regulations mandating HMIS^® inclusion on product labeling.

5.0 HMIS^® Chemical Ratings Guide

New for the Third Edition of the HMIS^® is the publication of a companion document entitled “HMIS^® Chemical Ratings Guide.” One feature lacking in older versions was a reference containing HMIS^® ratings for commonly used chemicals. Employers were expected to develop their own ratings or obtain recommended ratings from suppliers. As a result, ratings of common chemicals often varied from user to user depending on how the person developing the rating interpreted the HMIS^® ratings guidance.  To address this problem and make the system more comprehensive, HMIS^® now features an “HMIS^® Chemical Ratings Guide”. While users will have to develop ratings for chemicals or chemical mixtures that are not addressed in the new Guide, HMIS^® users will now be able to rely on the guide for well-documented ratings for a large number of commodity chemicals.

The guide contains an explanation of how to develop HMIS^® ratings, a table of chemicals with their HMIS^® ratings, and finally an Appendix with an HMIS^® Rating Classification Data Sheet for each chemical listed in the table.

6.0 Where can I get the HMIS^® III Implementation Manual and all of the Support Materials?

The exclusive licensee for ALL HMIS^® materials is J. J. Keller and Associates, Inc.  They may be reached at:

JJ Keller & Associates, Inc.
3003 W. Breezewood Lane
P.O. Box 368
Neenah, WI  54957-0368
Toll Free: 800-327-6868
FAX:  800-727-7516
www.jjkeller.com