Contract No. GS-10-F-0125P

Final Report

Harmonization of Hazard Communication: Labeling Costs

Submitted to:

Office of Regulatory Analysis

Occupational Safety and Health Administration

 Department of Labor

200 Constitution Ave. NW

Washington, DC 20210

Submitted by:

Eastern Research Group, Inc.

110 Hartwell Avenue

Lexington, MA 02421

  HYPERLINK "http://www.erg.com"  www.erg.com

ERG Task No. 0<IP_ADDRESS>

ERG Task No. 0<IP_ADDRESS>

April 28, 2010

TABLE OF CONTENTS

  TOC \o "2-2" \h \z \t "Heading 1,1,Heading 5,1,Heading 7,1,Heading
8,1,Heading 9,2"    HYPERLINK \l "_Toc260213294"  EXECUTIVE SUMMARY
PAGEREF _Toc260213294 \h  E-1

  HYPERLINK \l "_Toc260213295"  E.1	Introduction	  PAGEREF _Toc260213295
\h  E-1

  HYPERLINK \l "_Toc260213296"  E.2	Methodology	  PAGEREF _Toc260213296
\h  E-2

  HYPERLINK \l "_Toc260213297"  E.3	Estimate of Labels Used per Year
PAGEREF _Toc260213297 \h  E-2

  HYPERLINK \l "_Toc260213298"  E.4	Label Printing Technologies
PAGEREF _Toc260213298 \h  E-3

  HYPERLINK \l "_Toc260213299"  E.5	Labeling Compliance Strategies
PAGEREF _Toc260213299 \h  E-5

  HYPERLINK \l "_Toc260213300"  E.6	Current Labeling Practices and Cost
Estimates	  PAGEREF _Toc260213300 \h  E-6

  HYPERLINK \l "_Toc260213301"  1.	Labels Printed Per Year	  PAGEREF
_Toc260213301 \h  1-1

  HYPERLINK \l "_Toc260213302"  1.1	Company and Vendor Estimates
PAGEREF _Toc260213302 \h  1-1

  HYPERLINK \l "_Toc260213303"  1.2	ERG Estimate	  PAGEREF _Toc260213303
\h  1-1

  HYPERLINK \l "_Toc260213304"  2.	Label Printing TechnologIES	  PAGEREF
_Toc260213304 \h  2-1

  HYPERLINK \l "_Toc260213305"  2.1	Inkjet Printers	  PAGEREF
_Toc260213305 \h  2-1

  HYPERLINK \l "_Toc260213306"  2.2	Direct Thermal Printers	  PAGEREF
_Toc260213306 \h  2-1

  HYPERLINK \l "_Toc260213307"  2.3	Thermal Transfer Printers	  PAGEREF
_Toc260213307 \h  2-2

  HYPERLINK \l "_Toc260213308"  2.4	Laser Printers	  PAGEREF
_Toc260213308 \h  2-3

  HYPERLINK \l "_Toc260213309"  3.	Current Printing Practices and
Compliance Strategies	  PAGEREF _Toc260213309 \h  3-1

  HYPERLINK \l "_Toc260213310"  3.1	Number of Printers Used	  PAGEREF
_Toc260213310 \h  3-4

  HYPERLINK \l "_Toc260213311"  3.2	Current Printers	  PAGEREF
_Toc260213311 \h  3-4

  HYPERLINK \l "_Toc260213312"  3.3	Current Printing Practices	  PAGEREF
_Toc260213312 \h  3-4

  HYPERLINK \l "_Toc260213313"  3.4	Compliance Strategies	  PAGEREF
_Toc260213313 \h  3-6

  HYPERLINK \l "_Toc260213314"  3.5	Pictogram Stickers	  PAGEREF
_Toc260213314 \h  3-7

  HYPERLINK \l "_Toc260213315"  3.6	Option to Print Black Borders
PAGEREF _Toc260213315 \h  3-7

  HYPERLINK \l "_Toc260213316"  4.	Cost Estimates	  PAGEREF
_Toc260213316 \h  4-1

  HYPERLINK \l "_Toc260213317"  4.1	Printing In-House vs. Off-Site
PAGEREF _Toc260213317 \h  4-1

  HYPERLINK \l "_Toc260213318"  4.2	Current Label Printing Cost and
Anticipated Increase	  PAGEREF _Toc260213318 \h  4-1

  HYPERLINK \l "_Toc260213319"  4.3	Annual Label Printing Cost	  PAGEREF
_Toc260213319 \h  4-3

  HYPERLINK \l "_Toc260213320"  4.4	Cost of Blank Label Stock	  PAGEREF
_Toc260213320 \h  4-3

  HYPERLINK \l "_Toc260213321"  4.5	Preprinted Stock Cost	  PAGEREF
_Toc260213321 \h  4-4

  HYPERLINK \l "_Toc260213322"  4.6	Preprinted Label Cost	  PAGEREF
_Toc260213322 \h  4-4

  HYPERLINK \l "_Toc260213323"  4.7	Cost of Pictogram Stickers	  PAGEREF
_Toc260213323 \h  4-4

  HYPERLINK \l "_Toc260213324"  4.8	Printer Cost	  PAGEREF _Toc260213324
\h  4-7

  HYPERLINK \l "_Toc260213325"  4.9	Cartridge Cost	  PAGEREF
_Toc260213325 \h  4-9

  HYPERLINK \l "_Toc260213326"  4.10	Ink Ribbon Cost for Thermal
Transfer	  PAGEREF _Toc260213326 \h  4-10

  HYPERLINK \l "_Toc260213327"  REFERENCES	  PAGEREF _Toc260213327 \h
R-1

tables & Figures

  TOC \h \z \c "Table_ES"    HYPERLINK \l "_Toc260213328"  Table E-1.
Comparison of current label printing technologies.	  PAGEREF
_Toc260213328 \h  E-4

  HYPERLINK \l "_Toc260213329"  Table E-2. Adapting current labeling
methods to the GHS requirement.	  PAGEREF _Toc260213329 \h  E-6     TOC
\h \z \c "Table"

  HYPERLINK \l "_Toc260213330"  Table 1-1. Company and Vendor Estimates
of Labels per Year	  PAGEREF _Toc260213330 \h  1-1

  HYPERLINK \l "_Toc260213331"  Table 1-2. Shipments of Commodities in
Categories that may be Hazardous by Shipment Weighta	  PAGEREF
_Toc260213331 \h  1-3

  HYPERLINK \l "_Toc260213332"  Table 1-3. Typical Chemical Shipping
Container Capacity and Weight	  PAGEREF _Toc260213332 \h  1-4

  HYPERLINK \l "_Toc260213333"  Table 1-4. Typical Product Weights
PAGEREF _Toc260213333 \h  1-5

  HYPERLINK \l "_Toc260213334"  Table 1-5. Chemical Container Estimated
Typical Shipment Weights	  PAGEREF _Toc260213334 \h  1-6

  HYPERLINK \l "_Toc260213335"  Table 1-6. Chemical Container by
Shipment Weight Category	  PAGEREF _Toc260213335 \h  1-6

  HYPERLINK \l "_Toc260213336"  Table 1-7. Estimated Containers and
Labels Required for Shipping Hazardous Commodities	  PAGEREF
_Toc260213336 \h  1-8

  HYPERLINK \l "_Toc260213337"  Table 1-8. Shipment Characteristics by
Commodity by Export Mode, 2007	  PAGEREF _Toc260213337 \h  1-9

  HYPERLINK \l "_Toc260213338"  Table 3-1. Summary of Companies and
Current Printing Practices	  PAGEREF _Toc260213338 \h  3-2

  HYPERLINK \l "_Toc260213339"  Table 3-2. Printers Currently Used
PAGEREF _Toc260213339 \h  3-4

  HYPERLINK \l "_Toc260213340"  Table 3-3. Current Printing Practices
PAGEREF _Toc260213340 \h  3-6

  HYPERLINK \l "_Toc260213341"  Table 4-1. Company C: Estimated Increase
in Costs	  PAGEREF _Toc260213341 \h  4-1

  HYPERLINK \l "_Toc260213342"  Table 4-2. Estimated Incremental Cost of
Printing Red Pictogram Borders	  PAGEREF _Toc260213342 \h  4-3

  HYPERLINK \l "_Toc260213343"  Table 4-3. Vendor E Estimated Increase
in Costs with Red Borders for a 6” by 10” Label	  PAGEREF
_Toc260213343 \h  4-4

  HYPERLINK \l "_Toc260213344"  Table 4-4. Label Costs	  PAGEREF
_Toc260213344 \h  4-5

  HYPERLINK \l "_Toc260213345"  Table 4-5. Printer Cost	  PAGEREF
_Toc260213345 \h  4-8

  HYPERLINK \l "_Toc260213346"  Table 4-6. Amortized, per Label Printer
Cost Scenarios	  PAGEREF _Toc260213346 \h  4-9

  HYPERLINK \l "_Toc260213347"  Table 4-7. Cartridge and Ribbon Costs
PAGEREF _Toc260213347 \h  4-11

  HYPERLINK \l "_Toc260213348"  Table 4-8. Summary of Cost Estimates
PAGEREF _Toc260213348 \h  4-12

  TOC \h \z \c "Figure"    HYPERLINK \l "_Toc260213349"  Figure E-1.
Typical GHS-Compliant Label—Black Borders	  PAGEREF _Toc260213349 \h
E-1

  HYPERLINK \l "_Toc260213350"  Figure E-2. Typical GHS-Compliant
Label—Red Borders	  PAGEREF _Toc260213350 \h  E-2

Introduction

Under the proposed rule on Hazard Communication (29 CFR 1910, 1915, and
1926), the Occupational Safety and Health Administration (OSHA) would
modify its existing Hazard Communication Standard (HCS) to conform with
the United Nations’ (UN) Globally Harmonized System of Classification
and Labeling of Chemicals (GHS).

Like the current requirements for hazard communication, the proposed
rule would apply to hazardous chemicals, with the following exceptions:

Consumer products, which are labeled in accordance with Consumer Product
Safety Commission requirements.

Containers that are labeled in accordance with Environmental Protection
Agency requirements.

Pesticides subject to the Federal Insecticide, Fungicide, and
Rodenticide Act.

Foods, drugs, and cosmetics subject to the Federal Food, Drug, and
Cosmetic Act.

Substances intended for use as fuels when stored in containers and used
in the heating, cooking, or refrigeration system of a house.

Tobacco and tobacco products.

Source material, special nuclear material, or byproduct material as
defined in the Atomic Energy Act of 1954.

Aircraft, aircraft engines, propellers, or appliances.

This report specifically addresses one aspect of the proposed rule,
namely the potential incremental costs to industry of implementing
certain requirements of GHS hazard label warnings. The incremental cost
under consideration is that of printing a GHS-compliant label with the
GHS hazard pictograms within a red border (as required by the rule), as
compared to the costs of printing the same label, but with black borders
around the pictograms. An example is presented in   REF _Ref259698946 \h
 Figure E-1  and   REF _Ref259698953 \h  Figure E-2 .

Figure   STYLEREF 8 \s  E -  SEQ Figure \* ARABIC \s 8  1 . Typical
GHS-Compliant Label—Black Borders

Figure   STYLEREF 8 \s  E -  SEQ Figure \* ARABIC \s 8  2 . Typical
GHS-Compliant Label—Red Borders

To this point, ERG has found two major factors that affect the
incremental cost of applying the GHS-compliant red diamonds around the
pictograms:

If a company prints its own labels, what printing technology is being
employed?

If a company does not print its own labels, does it order personalized
labels from a supplier or printer, or order partially preprinted labels,
and then print personalized data onto them?

Methodology

In order to estimate this incremental cost, ERG has contacted
representatives at various establishments: label printing machine
manufacturers, distributors of preprinted labels, and printing
establishments that supply personalized GHS labels to customers’
specifications (such as the one depicted above). ERG also consulted an
expert in printing technology, and contacted knowledgeable
representatives of several companies that currently apply hazard labels
to their containers and who will be affected by a change to
GHS-compliant labeling.

Estimate of Labels Used per Year

Several companies with whom ERG spoke estimated the number of hazard
labels they use per year. These estimates ranged from 5,200 to
3,000,000. In order to estimate the number of hazard labels used per
year in the U.S. by all companies affected by the proposed rule, ERG
used the U.S. Census Bureau and the Department of Transportation’s
(DOT’s) jointly-produced Commodity Flow Survey (CFS) data on Shipment
Characteristics by Commodity by Shipment Weight (U.S. Census Bureau,
2007a). We performed our analysis based on six two-digit commodities.

Gasoline including Aviation (Commodity code 17)

Fuel Oils (Commodity code 18)

Other Coal and Petroleum Products (Commodity code 19)

Basic Chemicals (Commodity code 20)

Fertilizers (Commodity code 22)

Other Chemical Products & Preparations (Commodity code 23)

With some exceptions, the commodities listed under these codes appear to
be subject to OSHA Hazard Communication requirements. Important
subgroups within these categories that would not be subject to OSHA
requirements include: pesticides, products subject to the Consumer
Product Safety Act, and products such as packaged fertilizers and
lubricants sold directly to consumers.

The U.S. Census (2007a) data presents shipments of basic chemicals by
shipment weight. In order to establish the types of shipments that might
fall into each weight class, ERG conducted preliminary research on the
weight and capacity of various shipping container units (where a single
“unit” might consist of multiple containers, e.g., a shipment of 4
gallons of a chemical might consist of 4 one-gallon containers sold as a
single unit), and the weight per gallon of various chemicals. From these
data we calculated shipment weight by multiplying the product weight per
gallon by container capacity, and added the container weight to the
total. We then estimated a minimum, maximum, and simple average weight
per container for the different commodities used in this test case.
Based on these calculations, we were able to estimate the number of each
type of container that would fall into each of the U.S. Census (2007a)
weight classes. Assuming one label per container, and that all products
shipped by this industry require hazard labels, ERG’s initial rough
calculation shows that for the six major commodity types included in
this analysis, a total of approximately 2.64 billion hazard labels are
applied annually to containers of all sizes. Using the data available,
this estimate might be further refined

Label Printing Technologies

To this point, ERG has discerned two technologies (thermal transfer and
LaserJet) that companies printing their own hazard labels are likely to
use, and two others that might be in use by smaller companies with
minimal requirements for label durability or size (inkjet and direct
thermal, although recent advances in inkjet printing may be making this
technology plausible for small to medium companies in the affected
sector. These and their associated cost factors appear in   REF
_Ref259168254 \h  Table E-1  below.

The technologies in   REF _Ref259168254 \h  \* MERGEFORMAT  Table E-1
are described in more detail in Section   REF _Ref259173888 \r \h  \*
MERGEFORMAT  2 . Data presented in the table are from information gained
from company websites, and from interviews with print consultants, label
vendors, printers, and printer manufacturers.

Table   STYLEREF 8 \s  E -  SEQ Table_ES \* ARABIC \s 8  1 . Comparison
of current label printing technologies.

Label printing technology	Description	Ink costs: black-only v. two-color

Thermal transfer	Uses rolls of black and color ink “ribbons” (of
various widths) to apply ink to label.

Length of label, not amount of coverage, determines length of ribbon
used.

Adding a color requires using an equal length of ink ribbon in that
color.

Durable and fade resistant.

Will print on many different substrates.	To add red to a previously
all-black label costs at least 100% more.

Any red on a label will require a red ribbon equal in length to the
black ribbon already being used.

Example: 4.33 in. wide by 984 ft long black resin ribbon = $18.52; 4.33
in. wide by 984 ft red ribbon = $30.28.

LaserJet printing	Uses dry ink cartridges to print color and black on
most surfaces.

	Newer LaserJet	Printing black-only labels can be done without depleting
color toner.	Ink costs approx 20% to 100% more to print red diamonds
instead of black, depending on machine

Example: black cartridge for HP LaserJet 3700 = $148;

output = 6,000 pp.

cost per page, black ink = 2.47¢

Color cartridges = $189 ea.

output = 6,000 pp.

cost per page, color = 3.15¢

27.5% higher cost for red diamonds instead of black.

Older LaserJet	Printing black-only labels on color printer also uses up
cyan, magenta, and yellow toners	Ink costs are approximately equal to
print black or red diamonds.

Direct thermal printing	Uses heat to activate pretreated paper or other
material.

No ink costs involved.

Black printing only.	Cannot be practically adapted to print
GHS-compliant red diamonds.

Inkjet printing	Printing black-only labels also uses up cyan, magenta,
and yellow toners.

Mainly a non-industrial technology common with inexpensive home
printers.

Low durability, high per label costs.

Recent innovative inkjet technology has been incorporated into label
printers appropriate for light to medium industrial use.	Ink costs are
approximately equal to print black or red diamonds.

More rapid cartridge depletion means generally higher per label costs.

Ink costs of black or red diamonds with new inkjet color label printers
also approximately equal.

Labeling Compliance Strategies

Compliance costs for an establishment will also depend on the specific
labeling strategy currently being employed and how it can be adapted to
the GHS requirement.   REF _Ref259434931 \h  Table E-2  presents a
summary of current label production approaches and the incremental costs
of different strategies that would enable compliance.

Essentially, there are 4 methods currently used by companies to obtain
warning labels:

Printing in-house on blank label stock.

Printing in-house on preprinted “template” labels.

Ordering personalized labels from a vendor or printer.

Ordering stick-on hazard labels from a vendor or printer.

Some companies may use a combination of these methods. In general, if a
company is already printing color on their labels, or if they are
ordering preprinted labels that include color, they will experience
minimal incremental cost to comply with the GHS requirement.

Table   STYLEREF 8 \s  E -  SEQ Table_ES \* ARABIC \s 8  2 . Adapting
current labeling methods to the GHS requirement.

Current labeling method	Strategy to comply with GHS requirement
Incremental printing costs

In house, thermal transfer printing, black only.	Purchase two-color
printer and continue printing in-house on blank label stock.	Color ink
ribbon costs minimum 100% more, plus cost of new printer. See   REF
_Ref259168254 \h  Table E-1 .

	Purchase labels with preprinted red diamonds and print all-black label
(including pictograms) in register.	Cost increase for preprinted label
stock (approx. $0.01 per label).

In-house LaserJet printing, black only.	Purchase color LaserJet printer
and continue printing in-house on blank label stock.	Ink costs approx.
20% to 100% more to print red diamonds instead of black, plus cost of
new machine.

	Purchase labels with preprinted red diamonds and print all-black label
(including pictograms) in register.	Cost increase for preprinted label
stock (approx. $0.01 per label).

In-house inkjet printing, printing black with color printer.	Print label
with red diamonds instead of all black.	Approx. equal costs to print all
black or black with red diamonds.

Purchasing printed all-black hazard stickers.	Purchase printed pictogram
hazard stickers with red diamond border.	Approx 20% higher cost for red
diamond labels of same size.

Purchasing personalized labels (printed with product name, company name,
CAS #, hazards, first aid steps, etc.), all black.	Purchasing
personalized labels with red diamonds.	Not provided.

Current Labeling Practices and Cost Estimates

ERG interviewed 13 chemical companies, one distributor/importer, and two
health and safety consultants regarding current labeling practices and
costs and how these might change as a result of the proposed rule.
Companies interviewed ranged in size from small (30 employees) to very
large (more than 30,000 employees), and manufacture chemicals for a
variety of industries, including the biotechnology, pharmaceutical,
aerospace, food, cosmetics, cleaning products, and other industries.

There was no clear pattern in companies’ current printing practices
based on size or industry. Of the 13 companies we contacted, nine of the
12 that provided information on their current printing practices
currently print in black and white, with five of them using preprinted
label stock when color was required for a logo or to comply with DOT
regulations. Only one of these nine companies reported printing in color
at all, and that was 10 percent of the time. Only one company, a very
large multinational, reported that they were printing all labels in
color. Companies reported using both thermal transfer and laser
printers, with several planning on buying new printers as part of the
shift to GHS-compliant labeling. Some larger companies felt that
applying separate, red-bordered pictogram stickers to comply with GHS
would be impractical, or created too great a risk for error. One small
company, however, whose entire product line required just one or two
hazard pictograms, reported using (black and white) pictogram stickers.
The companies we contacted also presented a range of estimates for the
costs of labels, printers, and printing supplies. These cost estimates
are presented in Section 4 below.

ERG also contacted eight label printers and suppliers of label printing
equipment (see References). As with the chemical companies, ERG received
varied responses from the vendors and label printers. While some vendors
expected an increase in cost of 20 to 30 percent, some vendors did not
expect the cost to increase by much or at all, and one vendor reported
that it would actually be less expensive to print labels with red
pictogram borders than with black borders.. Regardless of the vendors’
expectation of the impact on cost, the estimates showed higher prices
for color cartridges and ribbons compared to black cartridges and
ribbons, although prices vary based on volume. The increase in the cost
of printing in red also depends on the label material used, for example,
gloss paper versus vinyl. For companies who will have to buy a new color
printer, prices range from $1,200 for a color laser printer to many
thousands for an industrial thermal printer. A full list of estimates
obtained from the various vendors and label printers are also presented
in Section 4.

	Labels Printed Per Year

Company and Vendor Estimates

The companies ERG contacted range from very large to very small, and
print corresponding numbers of labels. All companies are described in
Table 3-1, below. Company A (2010b) estimates that it prints 250,000
labels per month, or approximately 3,000,000 per year. Company B (2010)
estimates that it prints at least 100,000 labels per month, or over
1,200,000 per year. Company C (2010), a subsidiary of Company B, itself
prints approximately 300,000 to 400,000 labels per year. Company K
(2010) prints 40,000 to 50,000 labels per year. Company I (2010) uses
approximately 40,000 labels per year. Company F prints 200 to 250 labels
per month, or 2,400 to 3,000 labels per year (with additional labels
supplied by their customers). Company D (2010) prints 100 labels per
week, or 5,200 labels per year. Company L (2010) prints 90,000 labels
per year. (See   REF _Ref259186960 \h  Table 1-1 .)

According to Vendor B, small companies print from 10,000 to 30,000
labels per month, or 120,000 to 360,000 per year. Large companies were
estimated to print at least 100,000 per month, or at least 1,200,000
labels per year. (See   REF _Ref259186960 \h  Table 1-1 .)

Note that these estimates include labels for products shipped abroad,
which would not be affected under the proposed rule.

Table   STYLEREF 1 \s  1 -  SEQ Table \* ARABIC \s 1  1 . Company and
Vendor Estimates of Labels per Year

Source	Labels per Year

Company A (2010a,b)	3,000,000

Company B (2010)	1,200,000

Company C (2010)	300,000-400,000

Company D (2010)	5,200

Company F (2010)	2,400-3,000

Company H (2010)	500

Company I (2010)	40,000

Company K (2010)	40,000-50,000

Company L (2010)	90,000

Vendor B (2010a)	A large company they work with prints 360,000.

Vendor B (2010b)	Small Companies use 10,000 to 30,000 per month, Large
Companies > 100,000 per month.

ERG Estimate

In order to estimate the potential number of labels needed per year in
the U.S, ERG utilized the U.S. Census Bureau and the DOT’s
jointly-produced Commodity Flow Survey (CFS) (U.S. Census Bureau,
2007a), particularly data on Shipment Characteristics by Commodity by
Shipment Weight. In these data:

Commodities are defined at the 2-digit commodity code level

Other data tabulations (or cross-tabulations) include:

Distance shipped

Transportation mode

State of origin/destination

Hazardous material characteristics (based on DOT regulations)

Exports

ERG undertook a trial calculation to see if the number of labels on
shipping packages in the U.S. can reasonably be estimated using the CFS.
This section outlines an initial trial developed for the following
two-digit commodity codes:

Gasoline, including Aviation (Commodity code 17)

Fuel Oils (Commodity code 18)

Other Coal and Petroleum Products (Commodity code 19)

Basic Chemicals (Commodity code 20)

Fertilizers (Commodity code 22)

Other Chemical Products & Preparations (Commodity code 23)

Packages and containers containing chemicals listed under these
commodity codes appear to cover all those that require OSHA labeling.
Packaging for some chemicals within these categories, however, would not
be subject to OSHA requirements, such as packaging for pesticides and
products subject to the Consumer Product Safety Act (e.g., packaged
fertilizers and lubricants sold directly to consumers).

  REF _Ref259167451 \h  \* MERGEFORMAT  Table 1-2  presents CFS
estimates of tons shipped by shipment weight for the six commodities
listed above:

Table   STYLEREF 1 \s  1 -  SEQ Table \* ARABIC \s 1  2 . Shipments of
Commodities in Categories that may be Hazardous by Shipment Weighta

Shipment Weight Categories	Shipments in Tons (thous) by Commodity

	Gasoline including Aviation (Cmdty 17)	Fuel Oils (Cmdty 18)	Other Coal
and Petroleum Products (Cmdty 19)	Basic Chemicals (Cmdty 20)	Fertilizers
(Cmdty 22)	Other Chemical Products & Preps (Cmdty 23)	Total

Less than 50 lbs	19	22	259	172	2	860	1,334

50 - 99 lbs	68	55	325	220	7	553	1,228

100 - 499 lbs	329	1,513	4,768	2,347	88	2,925	11,970

500 - 749 lbs	238	2,655	2,914	1,297	55	1,499	8,658

750 - 999 lbs	216	3,626	4,003	919	50	1,268	10,082

1,000 - 9,999 lbs	16,212	52,726	28,665	17,362	5,182	18,557	138,704

10,000 - 49,999 lbs	162,904	109,446	206,608	147,991	54,560	83,159
764,668

50,000 - 99,999 lbs	361,660	163,686	81,617	24,354	31,720	4,335	667,372

More than 100,000 lbs	417,516	308,164	249,029	217,921	57,937	10,382
1,260,949

Total	959,162	641,893	578,188	412,583	149,601	123,538	2,864,965

a The products listed in these commodity categories generally appear to
be subject to OSHA Hazard Communication requirements; however these
estimates might be further verified and refined with further analysis of
the data.

Using commodity shipments by shipment weight helps put some bounds on
possible shipment types. For example, shipments of less than 50 pounds
(lbs) presumably cannot be in 55 gallon drums, because the drum itself
may weigh 25 lbs or more, the product shipped in the drum must weigh
less than 0.5 lbs per gallon, or the shipment would exceed 50 lbs.

To determine what these limits might be, we performed some preliminary
research on typical shipping containers used by the chemical industry,
as well as the empty weight of those containers. This search was not
intended to be exhaustive, but merely indicative of the types of
containers commonly used by the industry. A summary is provided in   REF
_Ref259167589 \h  Table 1-3 :

Table   STYLEREF 1 \s  1 -  SEQ Table \* ARABIC \s 1  3 . Typical
Chemical Shipping Container Capacity and Weight

Container	Container Capacity

(gallons)	Container Weight

by Type (lbs):	Ships in Outer Packagea

Poly	Steel

	250 milliliter jug	0.07	0.09	--	Y

500 milliliter jug	0.13	0.1	--	Y

1 liter jug	0.26	0.2	--	Y

2 liter jug	0.53	0.3	--	Y

1 gallon jugs	1.0	0.6	--	Y

2.5 gallon jugs	2.55	2.5	--	Y

5 gallon drum	5	3.3	4.6	N

30 gallon drum	30	14	18	N

55 gallon drum	55	24	36	N

275 gallon tote	275	125	--	N

330 gallon tote	330	150	--	N

Tank Truck	5,500	NA	NA	NA

	7,000	NA	NA	NA

Rail Car	20,000	NA	NA	NA

	30,000	NA	NA	NA

Barge	430,000	NA	NA	NA

a Y indicates the product at least sometimes ships in an outer package,
often containing multiple units, and that outer package might also
require a label. Thus, we exclude containers such as pallets containing
four 55 gallon drums, a frequent shipping configuration. In such cases,
the pallet would not require a label.

NA: Not Applicable

A similar search of products shipped in these containers found examples
of product weights per gallon, as shown in   REF _Ref259167765 \h  Table
1-4 .

Table   STYLEREF 1 \s  1 -  SEQ Table \* ARABIC \s 1  4 . Typical
Product Weights

Product	Weight per gal.

Water	8.4

Antifreeze	9.3

Diesel Fuel	7.2

Paint	10.0

Gas	6.2

Oil	6.8

Sulfuric Acid (conc)	15.0

Sulfuric Acid (dilute)	8.5

Bioban Preservative	9.1

Fungi-Block Fungicide	10.2

Cleaning Chemicals	8.6

Acetone	6.5

Oxaban Disinfectant	7.7

MDI-based products	9.1

Using these example products, ERG estimated the shipment weight for one
container of each size as:

Shipment Weight = (Product Weight per gallon * Container Capacity) +
Container Weight

Because we do not know the percentage of products shipped by container
type, we performed the calculation as described above for each product
and container type, and used best professional judgment to select a
“typical” weight for each container type.   REF _Ref259167863 \h
Table 1-5  presents the minimum, simple average, and maximum weights
calculated for the products included in this test case, and the number
of shipping labels each container would require. In the calculations
below we selected the simple average estimate to represent the
“typical” shipping weight for each container type.

Table   STYLEREF 1 \s  1 -  SEQ Table \* ARABIC \s 1  5 . Chemical
Container Estimated Typical Shipment Weights

Container	Estimated Shipment Weight (lbs)	Number of Labels per Container

	Minimum	Typical	Maximum

	250 milliliter jug	0.5	0.7	1.1	1.13a

500 milliliter jug	0.9	1.3	2.1	1.13 a

1 liter jug	1.8	2.5	4.2	1.25 a

2 liter jug	3.6	4.9	8.2	1.25 a

1 gallon jug	7	9	16	1.25 a

2.5 gallon jug	18	24	40	1.5 a

5 gallon drum	34	48	80	1

30 gallon drum	200	280	470	1

55 gallon drum	360	510	860	1

275 gallon tote	1,800	2,500	4,200	1

330 gallon tote	2,200	3,000	5,100	1

Tank Truck	5,500 gal.	34,000	48,000	82,000	0

	7,000 gal.	43,000	61,000	105,000	0

Rail Car	20,000 gal.	129,000	182,000	311,000	0

	30,000 gal.	186,000	260,000	450,000	0

Barge	2,700,000	3,800,000	6,500,000	0

a Assumes 8 units per package for containers smaller than 1 liter, 4
units per package for containers from 1 liter to 1 gallon, and 2 units
per package for 2.5 gallon containers.

Based on the calculations presented in   REF _Ref259167863 \h  Table 1-5
, ERG determined the types of containers that might be shipped within
each size category included in the CFS, as shown in   REF _Ref259168017
\h  Table 1-6 .

Table   STYLEREF 1 \s  1 -  SEQ Table \* ARABIC \s 1  6 . Chemical
Container by Shipment Weight Category

Container	< 50 lbs	50 - 99 lbs	100 - 499 lbs	500 - 749 lbs	750 - 999 lbs
1,000 - 9,999 lbs	10,000 - 49,999 lbs	50,000 - 99,999 lbs	> 100,000 lbs

All containers of 5 gallons or less	X	X	X	X	X	X	X	X	X

30 gallon drum

	X	X	X	X	X	X	X

55 gallon drum

X	X	X	X	X	X

275 gallon tote

X	X	X	X

330 gallon tote

X	X	X	X

Tank Truck	5,500 gal.

	X	X	X

	7,000 gal.

X	X

Rail Car	20,000 gal.

	X

	30,000 gal.

	X

Barge

	X

X indicates that a full container could be included in that shipping
category; a blank cell indicates that a full “typical” container
would exceed the maximum weight of that category.

Thus, the results in   REF _Ref259168017 \h  Table 1-6  indicate, for
example, that:

Only containers of 5 gallons or less are likely to be used in shipments
up to 99 lbs.

Relatively few 55 gallon drums would be found among shipments in the 100
to 499 lb category (“typical” weight of 510 lbs, although a few
specific products have calculated shipping weights below 500 lbs).

Totes (at least those holding 275 gallons or more) are highly unlikely
to be found in shipment categories below 1,000 lbs.

Bulk shipments by tank, rail, or barge are likely to consist of at least
10,000 lbs of product.

Two other pieces of information were used in estimating the shipping
containers that might be found within a shipment weight category:

A 2007 article in Inbound Logistics cited a number of purchasing
managers who estimated 70 to 80 percent of their intermediate bulk
shipments consisted of 55 gallon drums, with the remainder accounted for
by totes;

The statutory weight limit for a truck on the interstate is 80,000 lbs
gross vehicle weight. If the average tractor-trailer weighs 30,000 to
35,000 lbs, then the payload is unlikely to exceed 50,000 lbs. Thus,
shipments exceeding 50,000 lbs are likely to consist of bulk shipments
via railroad or ship.

Applying all the above information, ERG made a rough initial estimate of
the number of shipping containers that might require OSHA labels. To
generate this estimate, we assumed:

All shipments less than 100 lbs are approximately evenly divided between
containers of:

250 milliliters (5 percent);

500 ml to 2.5 gallons (5 container types; 15 percent each),

5 gallon drums (20 percent)

Shipments of 100 lbs or more, but not exceeding 499 lbs are split
between:

5 gallon drums (20 percent)

30 gallon drums (70 percent)

55 gallon drums (10 percent)

Shipments of 500 lbs or more, but not exceeding 9,999 lbs are split
between:

55 gallon drums (75 percent)

275 and 330 gallon totes (12.5 percent each)

All shipments of 10,000 lbs or more consist of bulk shipments by truck,
rail, or barge.

Using these assumptions, ERG’s initial rough calculation shows that
for the six major commodity types included in this analysis, a total of
approximately 2.64 billion labels would be required to ship 2.26 billion
containers, as shown in   REF _Ref259168192 \h  Table 1-7 .

Table   STYLEREF 1 \s  1 -  SEQ Table \* ARABIC \s 1  7 . Estimated
Containers and Labels Required for Shipping Hazardous Commodities

Weight	Tons (thou)	Estimated Number of Containers (millions)	Estimated
Number of Labels

(millions)

Less than 50 lbs	1,334	830	1,026

50 - 99 lbs	1,228	764	944

100 - 499 lbs	11,970	165	165

500 - 749 lbs	8,658	34	34

750 - 999 lbs	10,082	39	39

1,000 - 9,999 lbs	138,704	432	432

10,000 - 49,999 lbs	764,668	0	0

50,000 - 99,999 lbs	667,372	0	0

More than 100,000 lbs	1,260,949	0	0

Total	2,864,965	2,264	2,641

It cannot be sufficiently emphasized that this is a
“proof-of-concept” test calculation only. It is clear that further
refinement of these estimates could be made along the following
dimensions:

The percentage of products in each commodity class that will require
OSHA labels. Some products in commodity 23: Other Chemical Products and
Preparations clearly fall outside the purview of OSHA, viz.:

pesticides

products regulated under the Consumer Product Safety Act

products regulated by FDA and USDA

The products within these commodity classes can be examined more closely
to determine those not subject to OSHA regulation. ERG has developed a
spreadsheet to estimate the number of labels subject to this regulation
in which we have included a parameter to adjust commodity groups for the
percent not regulated by OSHA. We have also found that the U.S. Census
Bureau’s (2007b) Economic Census incorporates less aggregated product
data, which might be used to delineate further the products in each
commodity class. The Bureau of Economic Analysis’s (2002) Benchmark
Input Output Accounts could be used to estimate the percentage of
shipments to final consumers, which presumably are regulated under the
Consumer Product Safety Act.

The types of commodities transported.

This analysis was based on a convenience sample of products likely to be
subject to OSHA labeling requirements. However, within commodity
classes, products shipped could vary systematically in a way that could
affect patterns of container use, and thus the number of containers
requiring labels. For example, gasoline, diesel fuel, and lubricating
oil are all lighter than water; hence, an equivalent tonnage of these
products would likely require more containers than heavier products,
such as concentrated sulfuric acid. The spreadsheet model has been
developed so that the types of products shipped in each commodity class
can be readily adjusted to determine the typical weight of each
container.

The percentage of products shipped in each type of container.

Our industry contacts indicate that some chemicals, such as reagents,
are frequently shipped in small containers (e.g., less than 1 gallon).
It seems doubtful, however, that products such as fuel oil intended for
non-consumer use are frequently shipped in very small containers.
Furthermore, closely related to the previous bullet point, a 55 gallon
drum of oil is likely to weigh less than 500 lbs, thus affecting the
weight classes in which it might be included, and thus the estimate of
containers requiring labels. The spreadsheet model has been developed so
that the percentage of commodities shipped in each packaging type can be
readily adjusted for each commodity class. In addition, it is possible
to adjust the number and percentage of containers shipped in outer
packages.

Finally, it is possible to estimate the number of containers that are
exported. This is useful both for estimating the percentage of products
that will be complying with European or other regulations, as well as
estimating the percentage of products shipped that are shipped across
water and thus subject to more stringent labeling requirements.

The CFS’ Exports Series: Shipment Characteristics by Commodity by
Export Mode can be used to estimate this number (see   REF _Ref260042089
\h  Table 1-8 ).These data can be used to calculate the percentage of
products (by weight) in a commodity class that are exported by shipment
mode. Thus, it could be assumed, for example, that exports via truck or
rail will not cross water, but exports via air or water will be subject
to the requirements. Again, these estimates can be refined, and
appropriate parameters have been built into the spreadsheet model to
perform these calculations.

Table   STYLEREF 1 \s  1 -  SEQ Table \* ARABIC \s 1  8 . Shipment
Characteristics by Commodity by Export Mode, 2007

Export Mode	Shipments in Tons (thous) by Commodity

	Gasoline including Aviation (Cmdty 17)a	Fuel Oils (Cmdty 18)a	Other
Coal and Petroleum Products (Cmdty 19)	Basic Chemicals (Cmdty 20)
Fertilizers (Cmdty 22)	Other Chemical Products & Preps (Cmdty 23)

Total Shipments	959,162	641,893	578,188	412,583	149,601	123,538

Export Shipments by Mode

All modes	S	S	28,430	24,335	7,220	7,298

Single modes	S	S	27,974	23,437	7,095	6,844

Truck	S	S	1,660	2,474	S	2,023

Rail	--	S	6,061	5,814	S	488

Water	S	S	20,225	15,039	S	4,138

Air (incl truck and air)	S	--	7	110	Z	195

Pipeline	S	--	S	--	--	--

Multiple modes	--	--	Z	6	S	14

Parcel, USPS. or courier	--	--	Z	6	S	14

Other/unknown modes	S	S	456	892	125	441

Percentage of Shipments Exported	NA	NA	4.9%	5.9%	4.8%	5.9%

Of shipments exported, Exported by Water or Air	NA	NA	71.2%	62.3%	0.0%
59.4%

NA: Not Applicable.

S: Withheld by the U.S. Census Bureau because estimate did not meet
publication standards.

Z: An estimate that is between zero and half the unit shown, thus, has
rounded down to zero

a Based on CFS data, only nominal quantities of these commodities are
exported.

In summary, we believe this approach to estimating shipping containers
and number of required labels is sound, but these estimates could be
refined with further analysis of the data.Label Printing TechnologIES

The following summary of available label printing technologies was
compiled from our phone conversations with printers and printer vendors,
unless otherwise noted.

Inkjet Printers

Characteristics:

Printers use ink cartridges.

Printers release a jet stream of wet ink that is absorbed by the paper.

Older technology that may be used by a few companies that don’t
require durable labels.

Color inkjet printers use “process black” technology (i.e. printing
black also uses up the color ink), like that used by most low-priced
home printers.

Recent inkjet label-printing technology enables faster production,
greater resolution, and printing on more versatile substrates than
previously.

Often used in homes or home offices.

Advantages:

Printers are often cheaper than other advanced printers or printing
technologies.

Disadvantages:

Ink fades away easily, so not appropriate for transport by water or long
distance transport in harsh weather conditions.

Many inkjet printers cannot be used by chemical companies, as their
labels may have to be weather resistant.

Higher per-copy costs than LaserJet due to greater cartridge
consumption.

Costs:

Printing red instead of black would cost about the same, because
printing black uses up the color ink too.

Direct Thermal Printers

Because this type of printer cannot print in color, it has limited use
for printing GHS-compliant hazard labels. However some companies may be
using direct thermal printers now, or may use them in conjunction with
pictogram stickers in the future in order to comply with the proposed
rule.

Characteristics:

Label material is heat sensitive; image is produced by differential
application of heat.

Advantages:

The printers are very fast. A thermal printer prints three times faster
than a laser printer.

No ink is used.

Direct thermal printers are durable and easy to use with less
operational cost compared to thermal transfer, inkjet, or laser
printers.

Disadvantages:

Direct thermal printers cannot print in color.

Labels printed with direct thermal printers are more sensitive to light,
heat and abrasion, which reduces the life of the printed material.

Thermal printers are often very limited in the width of the label they
can handle.

Costs:

Direct thermal printers are relatively inexpensive. One well-known
Industrial Label Printer lists at $169.

Thermal Transfer Printers

These printers can be further divided by size and usage:

Light to medium industrial thermal printers: print size is usually 2
in., 4 in., or 6 in. wide labels. They normally use rolls of labels. The
outside diameter of the label roll cannot be more than 4 in.

Medium to heavy duty industrial thermal printers: label sizes are
usually 4 in. to 8.5 in. wide for these printers. They take label rolls
with an outside diameter of up to 8 in.

Characteristics:

Applies heat to an ink ribbon and then prints onto the label material.
Different ribbon materials are used depending on the type of label
substrate and the application.

Advantages:

The printers are very fast. A thermal printer prints three times faster
than a laser printer.

Thermal transfer printers can print on more label materials than direct
thermal printers (including paper, polyester, and polypropylene
materials).

Thermal transfer printers create extremely durable labels to withstand
extreme temperatures, ultraviolet exposure, chemicals, sterilization,
etc.

Disadvantages:

Label width is limited by ribbon width.

Requires proper matching of stock and ribbon material.

Costs:

Printing red borders using the thermal transfer will be the cost of red
ribbon – at least double the ribbon cost of printing one color.

Costs can range from $3,000 for an entry level printer, to $18,000 for a
high speed machine (Vendor/Printer A, 2010a).

Laser Printers

Characteristics:

Printers use toner cartridges.

Two types of laser printers (TPGTEX, 2010):

Office Laser Printers

Industrial Laser Printers

Office Laser Printers

Designed to work fast, so drawers/trays are designed to handle light
paper. The manual tray is designed to handle the occasional unusual
stock.

Regular office laser printers use very high heat.

Industrial Laser Printers:

Used to handle heavier stock of label material (e.g. vinyl labels) for
industrial use.

Can also handle the special adhesive used on most industrial label
stock. If wrong printer is used for the adhesive label, it may melt.

Tray designed to handle heavier stock.

Advantages:

Some laser printers have the capacity to print in color.

Disadvantages:

More expensive and slower than thermal printers.

Need three laser printers to do the job of one thermal printer.

Current Printing Practices and Compliance Strategies

ERG contacted 13 companies to interview them about current labeling
practices and costs and how these might change as a result of the
proposed rule. Data on these companies (their industry, number of
employees, labels printed per year, number of printers, current printer,
and current approach to hazard label printing) are summarized in   REF
_Ref259709400 \h  Table 3-1  below and described in more detail in the
sections that follow.

ERG also spoke with one distributor/importer, and two health and safety
consultants.

Distributor A has offices in 10 countries and provides chemicals to the
pharmaceutical, agricultural, color, surface coating/ink, and other
industries.

Consultant A works primarily with large multinational biotechnology and
pharmaceutical companies.

Consultant B works with a wide range of companies, from the very small
to very large multi-nationals.

ERG also contacted several printers and vendors of label printing
equipment in order to solicit estimates of the cost of equipment and
supplies used in label printing, such as printers, ribbons, cartridges,
label materials, and software.

Vendor A offers printers, blank label stock, ribbons, and printing
software and hardware solutions.

Vendor B offers labeling software solutions, as well as printers,
ribbons, and blank label stock.

Vendor C offers label printers, preprinted signs, ribbons, software,
etc.

Vendor D offers various products for the office, warehouse, worksite,
and home, including label printers and manual label makers.

Vendor E services printers and sells printing supplies.

Vendor F is a manufacturer of inkjet and LaserJet color label printers.
They have introduced new inkjet technology that permits higher quality
and faster output. They also manufacture and sell cartridges and label
stock for use with their machines.

Printer A is a manufacturer of custom, preprinted labels, which include
GHS labels and blank label stock for industrial manufacturing,
specializing in chemical labels and labels designed to withstand high
temperatures and weather exposure.

Vendor/Printer A offers digital color label printers, label printing
supplies, and label printing services to manufacturers, processors, and
retailers.

Vendor/Printer B is a manufacturer of DOT placards and hazmat labels,
and also creates custom labels and signs.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  1 . Summary of
Companies and Current Printing Practices

Name	Industry	Employees	Labels per Year	# of Printers	Current Printer
Current Approach

Company A	Chemicals, plastics, lubricants, etc.	    14,700 	3,000,000
28-30	B&W Zebra thermal transfer	Preprinted stock w/ DOT diamond, prints
OSHA and DOT in B&W

Company B	Specialty chemicals for automotive, pharmaceutical, precious
metal, and other industries	 >8,000 	1,200,000	6	HP LaserJet	Preprinted
stock with (EU) orange square, prints in B&W

Company C	Subsidiary of Company B, research chemicals	 NP
300,000-400,000	1	HP 2015 LaserJet	Preprinted stock with logo, prints in
B&W

Company D	Specialty chemicals for pharmaceutical and fine chemical
industries	 NP 	5,200	10-12	Thermal and LaserJet	Prints B&W

Company E	Chemicals for pharmaceutical, biotechnology, cosmetics, food,
plastics, and other industries	 > 30,000 	NP	3	Color laser	NP

Company F	Private label chemical products	 NP 	2,400-3,000	NP	NP	90%
B&W, 10% Color (if printing logo)

Company G	Chemicals and blends for electronics and aerospace industries
150-200 	NP	NP	B&W and color laser printers	NP

Company H	Subsidiary of Company B, pharmaceutical and specialty
chemicals	 NP 	500	NP	Buy B&W hazard warning labels from vendor	B&W, use
color for MSDS

Company I	Industrial and agricultural cleaners, mostly private label
      80 	40,000	NP	Zebra thermal transfer	Vendor, typically B&W

Company J	Chemicals	        120 	1,500,000	NP	Unspecified B&W	Preprinted
stock with logo and HMIS in color, print in B&W

Company K	Laboratory chemicals and solutions for hospitals and various
industries	          30 	40,000-50,000	NP	NP	Preprinted stock, prints in
B&W

Company L

	Specialty chemicals for R&D laboratories,  pharmaceutical,
microelectronic and chemical / petrochemical industries	“Medium”
size	90,000	2	B&W	Print as they need

Company M	Pharmaceuticals	>50,000	NP	NP	Color	Used to preprint labels
before but since 2008 print color labels in-house

NP: Not Provided

Number of Printers Used

Company B (2010) uses a total of 28 to 30 printers at their 14 sites
around the world. Company C (2010) has six printers (two at each of
their three locations). Company D has 10 to 12 printers, both thermal
and laser. Company F (2010) has three printers. Company L (2010) has two
printers that it uses for printing labels. Vendor B (2010) works with
one large chemical company that uses approximately eight thermal
printers.

Current Printers

Company B (2010) uses a thermal transfer printer manufactured by Zebra.
Company C (2010) uses a black and white HP laser printer. Company D uses
one HP 2015 black and white laser printer. Company H (2010) has both a
black and white and a color laser printer. Company F uses laser
printers. Company J (2010) uses a Zebra thermal printer to print in
black on preprinted stock. Company K (2010) uses an unspecified black
and white printer to print in black on preprinted stock. Company L
(2010) uses color laser printers. Company M (2010) uses an unspecified
color printer.

According to Vendor B (2010), none of Vendor B’s clients were using
thermal transfer printers and none of them had the capacity to print in
color.

Vendor/Printer A (2010) noted that most of the labels printed are now in
color and that only drum labels might be in a single color.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  2 . Printers
Currently Used

Source	# Printers	Printer Type

Company B (2010)	28-30	B&W Zebra thermal transfer

Company C (2010)	6	HP LaserJet

Company D (2010)	1	HP 2015 LaserJet

Company E (2010)	10-12	Thermal transfer and LaserJet

Company F (2010)	3	Color laser

Company H (2010)	NP

	B&W and color laser printers

Company I (2010)	NP

	Buys B&W hazard warning stickers from vendor

Company J (2010)	NP	Zebra thermal transfer

Company K (2010)	NP	B&W

Company L (2010)	2	B&W

Vendor B (2010a)	A large company Vendor B  works with has 8 thermal
transfer printers	None of the companies they work with at the moment
print in color. Vendor B works with seven of the largest affected
companies.

NP: Not Provided

Current Printing Practices

Company A (2010a) typically buys preprinted label stock with the DOT
diamond printed on it, and then prints both OSHA and DOT labeling on one
label in black. Some of their divisions buy labels printed off-site, and
some consumer products have labels printed in color. They typically
print 9 in. by 16 in. drum labels.

Company B (2010) uses preprinted polypropylene stock with orange squares
and then prints both transport and safety information on one label in
black.

Company C (2010) buys preprinted stock with their logo, and then prints
label information in black and white. Company C (2010) plans on being
fully GHS-compliant by the end of 2010 and anticipates buying at least
six color thermal printers.

Company D (2010) prints black and white 8.5 in. by 11 in. labels. They
do not anticipate switching to color printing any time soon.

Company F (2010) prints 90 percent of their labels in black and white
and the remaining 10 percent in color (when they are printing their
logo).

Company H (2010) currently only prints black and white labels, usually
on bulk shipments. While Company H (2010) owns a color printer, they
currently use it sparingly and only for some MSDS.

Company I (2010) purchases hazard labels from a vendor. These are
typically black and white 4.25 in. square labels, and they are used on a
variety of containers, from 1 gallon to 275 gallons.

Company J (2010) receives stock preprinted with their logo and Hazardous
Materials Identification System (HMIS) information printed in color.
They only use hazard symbols when they ship to Canada, and those are
printed in black. For containers smaller than 50 ml, they use Avery
labels.

Company K (2010) prints in black ink on preprinted label stock.

Company L (2010) prints their own labels in black and white as they need
them. They print many small labels. Because they distribute products in
Europe, they are complying with CLP regulations by the end of this year.

Company M (2010) used to order preprinted labels, but since 2008 have
been printing their own color labels in-house.

Distributor A (2010) reported that while the products they receive
already come with OSHA labeling, they do print DOT labels in color.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  3 . Current
Printing Practices

Name	Current Approach

Company A	Preprinted stock w/ DOT diamond, prints OSHA and DOT in B&W

Company B	Preprinted stock with (EU) orange square, prints in B&W

Company C	Preprinted stock with logo, prints in B&W

Company D	Prints B&W

Company E	NP

Company F	90% B&W, 10% Color (if printing company logo)

Company G	NP

Company H	B&W, use color for MSDS

Company I	Vendor, typically B&W

Company J	Preprinted stock with logo and HMIS in color, print in B&W

Company K	Preprinted stock, prints in B&W

Company L	Print as you need, B&W

Company M	Previously used preprinted labels, since 2008 print color
labels in-house

NP: Not Provided

Compliance Strategies

In order to comply with GHS implementation in the U.S. and abroad,
Company A (2010) is planning to buy color printers. Because more
information will be required on OSHA’s GHS-compliant labels, they
anticipate printing separate labels for OSHA and DOT in the future.
Their color printers also have a smaller format for printing labels.
Company A (2010a) is currently working to comply with GHS implementation
in Europe, Brazil, and China, and thus shifting from its current black
and white printers to color printers.

Company B (2010) plans to continue printing in black on preprinted
stock, under the assumption that EU regulations will allow them to leave
some of the red pictogram borders blank if not all are needed for a
particular product.

Company E’s (2010) exports are GHS compliant and that they are
beginning to test GHS labels for the anticipated adoption in the U.S.
They are currently in the testing phase and are conducting long-term
stability studies. According to the company’s website, the company is
“well-prepared for GHS.” The company claims to implement GHS
labeling of chemicals “step by step at the same time as the GHS
Regulation goes into force in Europe.” They also claim to place GHS
labels on all of the company’s substances by December 1, 2010 while
all mixtures will feature the required GHS labels by June 1, 2015.

In order to comply with GHS, Company H will use the color printer they
currently own only to print some MSDS and to print labels.

Company K (2010) intends to continue printing in black ink on preprinted
stock, and thus does not anticipate any printing cost increase.

Company L (2010) foresees difficulties fitting the pictograms and
information required for GHS onto small labels, such as 2 in. by ½ in.
labels for containers as high as 1 ½ in. containing 1 g of material and
1 ½ in. by 3 ½ in labels. Because they distribute products in Europe
they will be complying with CLP regulations by the end of 2010.

Company M (2010) anticipates switching to GHS labeling by the end of
November, 2010 for substances, and by the middle of 2015 for mixtures.

Consultant A (2010) reported that most clients were already making the
shift to printing in color for shipments to the EU. Most of the
biotechnology and pharmaceutical companies with whom Consultant A (2010)
works have large and well-funded environmental health and safety
departments and so were already anticipating the changes needed to
comply with GHS. However, Consultant A reported that many small and
medium size companies were much less likely to be moving toward GHS.

Consultant B (2010) felt that the vast majority of the companies she
works with are already printing in color. One exception was one of
Consultant B’s (2010) clients, a large plastic company. Because they
sell their products to other companies, printing their logo in color was
less of a concern.

Pictogram Stickers

Some vendors produce stickers with the pictogram and red diamond border.
Using these stickers in conjunction with a black and white label
containing text is one possible compliance strategy, although the
companies we spoke with were doubtful that it would be widely adopted.

Company B (2010) did not see using 2 in. by 2 in. pictogram stickers as
a realistic option for them, as that would require manual application of
the stickers and introduce the possibility of human error.

Consultant B (2010) granted that 2 in. by 2 in. pictograms were one
option for compliance, but pointed out that companies with large
production wouldn’t want to use the manpower required to affix them.

According to Vendor/Printer A (2010), most customers want to print the
whole label instead of just the GHS pictogram.

Company I (2010) buys 4.25 in. square black and white hazard stickers
from a label vendor and applies them to containers varying in size from
1 gallon to 275 gallon. Thus, switching to red-bordered pictogram
stickers would require no change in production procedures.

Option to Print Black Borders

The European Union’s (EU) Classification, Labeling, and Packaging
(CLP) Regulation (ECHA, 2009) specifies how GHS will be applied in the
EU. Section <IP_ADDRESS> specifically requires that hazard pictograms
“shall have a black symbol on a white background with a red frame
sufficiently wide to be clearly visible.” Company B (2010) operates in
several EU member countries, and was not aware of anyone in the EU
proposing the option of printing black borders. They were hopeful that
preprinted stock with red pictogram borders, some of which might remain
empty, would be an option.

Consultant A (2010) had only one client that did not ship abroad, and
felt that given the option that client would not choose to print black
pictogram borders.

Company J (2010) would prefer to be able to print labels all in black,
including black pictogram borders.Cost Estimates

The estimates we received for the costs of labels, printers, and printer
supplies are summarized in   REF _Ref259713325 \h  Table 4-8  and
discussed in more detail in the sections that follow.

Printing In-House vs. Off-Site

Consultant B (2010) reported that the cost of printing labels off-site
(i.e., purchasing labels from a vendor or printer) was similar to
printing in-house, and that cost was not the deciding issue. Rather, a
company’s need for flexibility was the deciding factor. Companies that
manufacture a largely unchanging set of products would be more likely to
print off site, while those who are frequently changing the products
they produce are more likely to do just-in-time printing, which also
allows them to minimize stockpiles and add a lot number.

Vendor/Printer A (2010), on the other hand, said that in-house printing
was more expensive than getting the labels printed off-site.

Current Label Printing Cost and Anticipated Increase

Company C (2010) anticipates that adding red pictogram borders will
increase cost variably depending on the label size, as shown in   REF
_Ref259165854 \h  Table 4-1

Table   STYLEREF 1 \s  4 -  SEQ Table \* ARABIC \s 1  1 . Company C:
Estimated Increase in Costs

with Red Border Pictograms

Label Size	% of Labels Printed per Year 	Cost to Print with Black Frame
Cost to Print with Red Frame

Small (1"x3")	50%	$0.05 	$0.10-$0.11

Medium (2"x3")	35%	$0.08 	$0.15

Large (6"x8")	15%	$0.15 	$0.25-$0.30

Source: Company C (2010)

Company D (2010) estimates that their current black and white labels
cost between $0.25 and $0.75 each (the latter being for waterproof
polyester labels).Company D (2010) thought that switching to color
printing might almost double their label printing costs.

Company E (2010) reports that black and white labels cost around $0.09
each, and that color labels cost about $0.15 each.

Because they already have a color printer, Company F (2010) reports that
black and white labels cost approximately $0.10 each, and anticipates
that the cost of printing red borders will be negligible, at most $300
per year.

Company H (2010) forecasts that adding color to the label will increase
the cost of the label by at least 10 to 20 percent.

Company I (2010) reported that the overall cost of hazard stickers was
negligible, perhaps $0.04 each, and that the requirement to buy stickers
with a red pictogram border would add “a couple more cents” per
label.

Company J (2010) forecasts that the requirement to incorporate red
pictogram borders “will definitely have an impact.”

Company K (2010) intends to continue printing with black ink on
preprinted stock, and thus anticipates no increase in printing costs for
most labels. The only increase in costs would come from labels on their
smallest (50 ml) containers, which make up approximately 5 percent of
their products. Because the labels they currently use on these
containers would not be able to accommodate all the GHS information,
they anticipate having to find some other solution (such as a tag) which
might cost up to three times as much as their current labeling for small
containers.

Company L’s (2010) current black and white labels cost an average of
$0.02 per label. They anticipate a cost increase due to printing in
color. Because the proposed GHS labeling will take up more room, they
will also incur a cost because they have to use larger label stock.

Company M (2010) thinks that switching to GHS will cost millions of
dollars overall, but this includes training, MSDS redesign, and labeling
changes.

Consultant B (2010) felt that while some companies would have additional
costs from the requirement to print in color, the increase in costs was
often “blown out of proportion.”

Vendor B (2010) estimated that in order to comply with the new GHS
labeling regulation, companies will have to buy color printers, which
alone will increase the cost by 20 to 30 percent.

Vendor F (2010) said that with their inkjet printer, printing the labels
with red pictogram borders would cost the same or even as much as 12
percent less than printing the labels in black, due to the different
costs of black and color ink cartridges.

According to Vendor/Printer A (2010) the cost difference between all
black versus two-color using a color printer was negligible, since both
black and color cartridges are used in printing even black-only labels.
In a color inkjet printer, however, color cartridges are replaced two to
three times more often than black cartridges, but black cartridges
cannot be used alone.

Vendor/Printer B (2010), who offers personalized, GHS-compliant labels
to order, reported that personalized labels printed in all black would
cost the same as those with a red pictogram border.

  REF _Ref259187166 \h  Table 4-2  summarizes the various estimates we
received comparing the cost of printing red pictogram borders to the
cost of black pictogram borders.

Table   STYLEREF 1 \s  4 -  SEQ Table \* ARABIC \s 1  2 . Estimated
Incremental Cost of Printing Red Pictogram Borders

Source	Estimated Change

Company C (2010)	Black border $0.05-$0.15, red border $0.10-$0.30 (See
REF _Ref259165854 \h  Table 4-1 )

Company D (2010)	Cost would “double”

Company F (2010)	Couple of cents more per label, $300/year

Company H (2010)	10-20% more

Company I (2010)	$0.04 more per label

Company J (2010)	“Will definitely have an impact”

Company K (2010)	No printing cost increase except for small container
labels

Company L (2010)	Cost increase due to color and increased label size

Company M (2010)	Several million dollars to switch to GHS (training,
labeling, redesigning MSDS, etc.)

Vendor B (2010a)	At least 20-30%

Vendor F (2010)	Same or up to 12% less for red

Vendor/Printer A (2010a)	For pictogram stickers: Short run digital
printing ~30% more, no increase for traditional printing for large
quantities

Vendor/Printer A (2010b)	“Negligible”

Vendor/Printer B (2010b)	“No increase”

Annual Label Printing Cost

According to Vendor B (2010), small companies spend approximately
$10,000 to $100,000 annually on label printing, not including printer
costs. Large companies were estimated to spend at least $100,000
annually on label printing, not including printer costs. Total label
printing costs were said to depend on the number of products produced
and shipped, and also on the number of products shipped internationally
(as the companies will have to comply with the regulations in the
countries they are doing business with). Using preprinted labels would
increase the cost by 20 percent more than printing all black on blank
labels.

Cost of Blank Label Stock

Vendor A estimated that a roll of labels for a table-top printer would
print approximately 5,570 labels. There are 4 rolls per carton and a
carton costs up to $61, for an approximate per-label cost of $0.003.

Vendor B (2010) estimated that the average price of 500 blank 8.5 in. by
11 in. labels ranges from $150 to $200, or $0.30 to $0.40 per label.
Vendor B (2010) also said that a 4 in. by 6 in. roll of labels would
print from 250 to more than 1,000 labels. Vinyl labels of size 8.5 in.
by 11 in. were said to cost around $0.20 to $0.23 per label just for the
label material.

 Vendor D (2010) estimated the cost of blank label stock to be $73.33
per 1,000 labels, or $0.07 each. However, the company only printed black
on stock size labels of up to 2 5/16 in. by 4 in. The thermal printers
sold by the company use pretreated paper to react with heat to produce
images on labels and would likely not be suitable for printing
pictograms with red borders.

Vendor/Printer A (2010) estimated that 6 in. by 10 in. blank labels on
gloss paper cost $0.22 each. A similar label on matte paper would cost
$0.09 each.

Preprinted Stock Cost

₤150 to 200 ($228 to $304, or $0.23 to $0.30 per label).

Company J (2010) orders 3.67 in. by 7.5 in and 2.5 in. by 5 in. labels
preprinted with their logo and HMIS labeling printed in color at a cost
of approximately $0.05 per label.

Vendor B (2010) estimated the cost of 1,000 preprinted labels to be $50
(or $0.05 per label).

Vendor D (2010) estimated that white labels preprinted with a red border
would cost approximately $0.0867 each. With the red border preprinted on
labels, the company estimated the cost to go up by approximately 18
percent. However, this company’s label stock is suitable for direct
thermal printing only.

Preprinted Label Cost

Vendor D (2010) estimated that printing black on 1,000 white labels of
stock size of up to 2 5/16 in. by 4 in. would cost around $73.33 (or
$0.073 per label).

Vendor E (2010) estimated the following costs for printing labels on
laser printers of various types:

≤$0.30

Source: Vendor E (2010); NA: Not Applicable

Cost of Pictogram Stickers

Printer A (2010) estimated that a roll of 100, 2 in. by 2 in. pictogram
stickers on matte vinyl would cost $18. The company had discounts
available for customers with orders of more than 250 rolls.

Vendor/Printer A (2010) gave separate estimates for short run digital
printing versus traditional offset printing in large quantities. For
short-run digital printing, printing stickers with red border and black
pictogram on white background on a 2 in. by 2 in., gloss paper,
adhesive-backed roll of 1,000 labels costs approximately $0.06 per
sticker. A black pictogram border would cost approximately $0.05 per
sticker. Thus, changing the diamond from black to red increases the cost
by 20 percent. Similarly, a red border and black pictogram on white
background on a 2 in. by 2 in. roll of 1,000 adhesive-backed vinyl
stickers costs approximately $0.09 per label. A black pictogram borders
would cost approximately $0.07 per sticker. Vendor/Printer A also
mentioned that in case of traditional, large-quantity offset printing,
100,000 or more stickers with red border and black pictogram on white
background would cost approximately $0.01 per label. The vendor
estimated no cost difference between all black and two-color while using
the traditional high-volume printing.

Vendor/Printer B (2010) estimated that a roll of 100 paper, 2 in. by 2
in. GHS stickers would cost $18. Orders of 10 rolls or more would drop
the per roll cost to $12 per roll. According to the vendor, 6 in. by 10
in. personalized GHS label with GHS compliant content and one to three
pictograms would cost $1.81 each for 250 labels, $0.95 each for 500
labels, $0.68 each for 750 labels and $0.55 each (or $550 in total) for
1,000 labels (see   REF _Ref259718919 \h  Table 4-4 ) The company
mentioned no cost difference between printing all black and two-color on
the personalized labels as the company already supplies labels with red
border pictograms.

  REF _Ref259188295 \h  Table 4-4  summarizes the estimates we received
for the cost of blank labels, preprinted stock, printed labels, and
pictogram stickers.

Table   STYLEREF 1 \s  4 -  SEQ Table \* ARABIC \s 1  4 . Label Costs

Source	Blank	Preprinted Stock	Printed Label	Pictogram Stickers

Company B (2010)	NP	₤0.22 ($0.33) each for preprinted stock with
orange diamonds; roll of 1,000 is ₤150-200 ($228.30-304.40)	NP	NP

Company C (2010)	NP	NP	Black frame: Small (1 in. by 3 in.): $0.05;
Medium (2 in. by 3 in.): $0.08; Large (6 in. by 8 in.): $0.15 	NP

Company D (2010)	$0.25 (less durable) to $0.75 (weatherproof polyester)
per 8.5 in. by 11 in. label	NP	NP	NP

Company E (2010)	NP	NP	B&W $0.09, color $0.15	NP

Company F (2010)	NP	NP	B&W < $0.10	NP

Company I (2010)	NP	NP	NP	4 ¼ sq. in. stickers; estimated to cost $0.02
more for color

Company J (2010)	NP	$0.05 per label for 3.67 in. by 7.5 in. and 2.5 in.
by 5 in.	NP	NP

Company L (2010)	NP	NP	$0.02 per label for 1 ½ in. by 3 ½ in.	NP

Vendor B (2010a)	$150-$200 for 200-500 8.5 in.x11 in. vinyl labels
($0.30-$1.00 per label); $3.50 for 250 4 in.x6 in. labels ($0.01 each)
20% more than blank labels; $50 per 1,000 labels ($0.05 per label) or
$12-$17 per 250 labels ($0.05-$0.07 per label)	Small companies spend
$10,000 - $100,000 annually not including printer costs

Large companies spend at least $100,000 annually on printing labels, not
including printer costs	NP

Vendor B (2010b)	8.5 in.x11 in. vinyl labels size 8.5x11 $0.20-$0.23 per
label	NP	NP	NP

Vendor D (2010)	Blank,  2 5/26 in. by 4 in. label costs $73.33 per 1,000
labels ($0.07 per label)	$86.67 for 1,000 white labels with red border
($0.09 per label); Cost increases 18.2%	NP	NP

Vendor E (2010)	NP	NP	For a GHS 6 in. by 10 in. label: $0.02-$0.30 for
black pictogram border, $0.09-$0.30 for red pictogram border (See   REF
_Ref259188900 \h  Table 4-3 )	NP

Vendor F	NP	NP	For a 6 in by 8 in. GHS label, $0.165 for black pictogram
border, $0.145 for red border	NP

Vendor/Printer A (2010a)	NP	NP	NP	Using short run digital printing to
print 2 in. by 2 in. pictogram with all black print on gloss paper costs
$0.05 each, red border on paper $0.06 per label, on vinyl $0.09 per
label; short run digital printing black on paper $0.05 per label, on
vinyl $0.07 per label; traditional offset printing for large quantities,
red border = $0.01 per label

Vendor/Printer A (2010b)	6 in.x10 in. for Inkjet: $215.12 per 1,000 for
gloss ($0.22 each), $86.84 per 1,000 for matte ($0.0868) each	NP	NP	NP

Vendor/Printer B (2010a)	NP	NP	NP	$18 for roll of 100 2 in. by 2 in.
labels pictogram stickers ($0.18 per sticker); $12 per roll for orders
of ≥ 10 rolls ($0.12 per sticker)

Vendor/Printer B (2010b)	NP	NP	6 in. by 10 in. personalized GHS labels
with 1-3 pictograms: 250 labels $1.81 each; 500 labels $0.95 each;750
labels $0.68 each;

1,000 labels $0.55 each	NP

NP: Not Provided

Printer Cost

Company A’s (2010b) black and white printers cost approximately $5,000
each at the time they were purchased. Company A (2010b) estimates that
the color printers they plan to buy cost $1,500 to $1,700 each.

Company B (2010) is only aware of one Oki printer that will print in
color and comply with British Standard BS 5609, a standard that requires
labels shipped by water to survive three months of salt water immersion,
among other requirements. This printer costs ₤3,000 (approximately
$4,566). This printer requires different label stock, which is 20 to 35
percent more expensive than the stock they use now (approximately $0.67
to $1.05 instead of the current ₤0.22, or $0.33). Company B (2010)
estimates that color thermal transfer printers cost ₤25,000 to
₤30,000 ($38,050 to $45,660), and that digital printers cost ₤12,000
to ₤15,000 ($18,264 to $22,830),

Company E (2010) estimates that printers cost from $10,000 to $25,000
each.

Company G (2010) estimates that a laser printer printing generic labels
could cost only a few hundred dollars, while a more durable and flexible
thermal transfer printer could cost $1000 to $5000, or more.

Vendor B (2010) estimates thermal printers and black and white laser
printers to cost approximately $700, while color laser printers were
estimated to cost $1200 each. Vendor B (2010) mentioned that a color
printer would be almost twice as expensive as the black and white
printer.

Vendor C (2010) sells color printers that are capable of producing
labels that meet GHS requirements. The printers include software with a
full set of GHS pictograms and can print labels and signs formatted to
meet GHS requirements. The cost for available printers ranges from
$1,499 to $3,995.

Vendor F’s (2010) most expensive inkjet label printer costs $2995, and
their top of the line LaserJet label printer costs $18,000.

Vendor/Printer A (2010) estimates high speed color printers to cost
$18,000, while an entry level full color printer would cost $3,000 and
prints about 200 labels per day.

  REF _Ref259188489 \h  Table 4-5  summarizes the estimates we received
for the cost of buying a printer.

₤12-15k ($18,264-$22,830) for digital, ₤25-30k ($38,050-$45,660) for
color thermal transfer

Company E (2010)	NP	$10,000-$25,000

Company G (2010)	Laser a few hundred, thermal transfer upwards of
$1,000- $5,000 	Laser a few hundred, thermal transfer upwards of $1000-
$5000

Vendor B (2010a)	$700 for thermal or laser	$1,200 for color laser

Vendor F (2010)	NP	Most expensive inkjet label printer $2,995, top of
the line LaserJet label printer $18,000

Vendor/Printer A (2010a)	NP	Entry level (200 labels per day) $3,000,
High speed machine costs $18,000

NP: Not Provided

While the cost of buying a new printer (or several new printers) can be
many thousands of dollars, the cost is minimized when it is amortized
over the life of the printer and divided into a per-label cost. This is
illustrated with three hypothetical scenarios in   REF _Ref259711028 \h
Table 4-6 . Note that these examples are in the range of parameters
provided by our contacts, but may not represent any given company’s
actual costs. We also assume that the more expensive printer will have a
longer lifetime.

Table   STYLEREF 1 \s  4 -  SEQ Table \* ARABIC \s 1  6 . Amortized, per
Label Printer Cost Scenarios

 	Scenario

	1	2	3

Initial Printer Cost	$1,000	$5,000	$10,000

Real Discount Rate	7%	7%	7%

Expected Printer Life (Years)	5	5	10

Amortized Annual Printer Capital Cost a 	$244 	$1,219 	$1,424

Annual Printer Maintenance Cost as % of Initial Cost	10%	10%	10%

Amortized Annual Printer Capital Cost a	$268 	$1,341 	$1,566

Labels per Day	500	1,000	1,500

Printing Days per Year	250	250	250

Annual Total Labels	125,000	250,000	375,000

Printer Cost per Label	$0.0021 	$0.0054 	$0.0042

a  Calculated using Microsoft Excel PMT Function

Cartridge Cost

Company B estimates that cartridges cost about ₤100 ($152) each.
Company C (2010) estimates that black ink cartridges cost approximately
$40 each and they use a couple hundred of them annually.

Company H (2010) estimates that a black cartridge costs approximately
$70, while color ink cartridges also cost $70, but several of them must
be purchased.

Company F (2010) estimates that black ink cartridges cost $45 to $50,
and that color cartridges cost more but not significantly more.

Vendor B (2010) estimates that a black cartridge costs $370 and prints
between 10,000 and 20,000 pages. This means that companies will spend
$0.02 to $0.04 per page on the cartridge. Vendor B (2010) estimates that
a color cartridge will cost $378 per cartridge. However, 4 cartridges
are required to print color, which brings the cost up to $1,512 ($378 x
4). These 4 cartridges will give an output of about 6,000 pages, which
means that companies spend $0.25 per page on cartridges.

According to Vendor/Printer A (2010), a black cartridge for Inkjet
printer costs approximately $39.94 each if bought in a set of 10, while
a color cartridge for a similar printer would cost $44.59 each if bought
in a set of 10. The website for the vendor showed that a black ink
cartridge for one of their inkjet printers costs $42.95 and the color
ink cartridge was $47.95. The cost decreases if bought in bulk, e.g. the
black cartridge and color cartridge costs $42.09 and $46.99 respectively
if bought in sets of 3 or more, $41.66 and $46.51 respectively if bought
in sets of 5 or more, $40.80 and $45.55 respectively if bought in sets
of 7 or more, and $39.94 and $44.59 respectively if bought in sets of 10
or more.

	  REF _Ref259187969 \h  Table 4-7  summarizes the estimates we received
for the cost of toner cartridges.

Ink Ribbon Cost for Thermal Transfer

Company B (2010) estimates that ribbons cost approximately ₤40 ($60)
each and last for approximately 500 labels (about $0.12 per label).

One contact person at Vendor A (2010a) estimated black ribbons of 2.5
in. wide and 4.33 in. wide to cost $2.36 and $4.87 per roll,
respectively. Ribbons come in cases of 6 rolls. The 2.5 in. wide roll
was estimated to cost $6.50 per roll, while the 4.33 in. ribbon was
estimated to cost $11.27 per roll. Upon talking to a second contact
person at Vendor A (2010b), drastically different estimates were
obtained. Our second contact person estimated that a 2.5 in. black
ribbon cost $13.96, while a 4.33 in. ribbon cost $24.04. According to
our second contact person, color ribbons were $20 extra, which would
mean that color ribbons cost $33.96 per 2.5 in. roll and $67.64 per 4.33
in. roll.

Vendor B (2010) said that the ribbons in a black and white thermal
printer will print twice as many labels as the toner or cartridge in a
color laser printer. According to Vendor B (2010), black toner in a
color laser printer prints about the same number of labels as the color
toner in the color laser printer, but color ribbons are four to five
times more expensive than the black ribbon.

Vendor C’s website lists the cost for a 7 in. by 492 ft black resin
ribbon as $249.95, while the red resin ribbon of the same size was
listed as $299.95. These resin ribbons produce labels that are chemical
resistant and durable in harsh environments.

Vendor/Printer A (2010) estimated that 6.25 in. by 300 m red premium
resin ribbon for a thermal transfer printer will cost $64.18 and print
about 1,180 6 in. by 10 in. labels, at an average cost of about $0.05
per label. A similar size black resin ribbon was estimated to cost the
same, i.e. $64.18. On the other hand, similar size, wax ribbon was
estimated to be $40.05 for color and $10.27 for black. Furthermore,
similar size, wax/resin ribbon was estimated to be $36.45 for color and
$$32.81 for black.

  REF _Ref259187969 \h  Table 4-7  below summarizes the estimates we
received for the cost of ribbons.

₤100 ($152)	₤40 ($60.88) each, last for ~500 labels	₤40 ($60.88)
each, last for ~500 labels

Company C (2010)	$40 	NP	NP	NP

Company F (2010)	$45-$50	Couple of $ more for color but not significant
NP	NP

Company H (2010)	$70 	$350 (5 times more expensive than black cartridge)
NP	NP

Vendor B (2010a)	$370 each, prints 10,000 - 20,000 labels ($0.02-$0.04
per label)	Set of 4 costs $1,512 (4 * $378), prints 6,000 labels ($0.25
per label)	Ribbons in a B&W thermal printer print twice as many as
cartridge in the color laser printer	4 or 5 times more expensive than
B&W.

Vendor B (2010b)	$200, prints 20,000 labels ($0.01 per label)	Set of 4
$1,200, prints 6,000 labels ($0.20 per label)	NP	NP

Vendor C (2010)	NP	NP	$249.95 for 7 in. by 492 ft resin ribbon	$299.95
for 7 in. by 492 ft red resin ribbon

Vendor/Printer A (2010a)	Inkjet label printer: Black ink cartridge =
$42.95 each; $42.09 if more than or equal to 3; $41.66 if more than or
equal to 5; $40.80 if more than or equal to 7; $39.94 if more than or
equal to 10	Inkjet label printer: Color ink cartridge = $47.95 each;
$46.99 if more than or equal to 3; $46.52 if more than or equal to 5;
$45.55 if more than or equal to 7; $44.59 if more than or equal to 10
For thermal transfer printer, black resin ribbon i.e. 6.25 in. by 300 m
costs $64.18 (same as the color ribbon). A similar size wax color ribbon
and wax/resin color ribbon costs $10.27 and $32.81 respectively.	For
thermal transfer printer, red premium resin ribbon i.e. 6.25 in. by 300
m costs $64.18, gives approximately 1,180 labels that are 6 in. by 10
in. and costs $54.31 to print 1,000 labels. A similar size wax color
ribbon and wax/resin color ribbon costs $40.05 and $36.45 respectively.

Vendor/Printer A (2010b)	Inkjet $39.94	Inkjet $44.59 each	NP

	NP: Not Provided

₤12-15k ($18,264-$22,830) for digital, ₤25-30k ($38,050-$45,660) for
color thermal transfer	NP	₤100 ($152)	₤40 ($60.88) each, last for
~500 labels	₤40 ($60.88) each, last for ~500 labels	NP	₤0.22 ($0.33)
each for preprinted stock with orange diamonds; roll of 1,000 is
₤150-200 ($228.30-304.40)	NP	Not feasible for them (operator error)

Company C (2010)	Black border $0.05-$0.15, red Border $0.10-$0.30 (See
REF _Ref259713503 \h  \* MERGEFORMAT  Table 4-1 )	NP	NP	$40 	NP	NP	NP	NP
NP	Black frame: Small (1 in.x3 in.): $0.05; Medium (2 in.x3 in.):$0.08;
Large (6 in.x8 in.): $0.15	NP

Company D (2010)	Double	NP	NP	NP	NP	NP	NP	$0.25 (less durable) to $0.75
(weatherproof polyester) per 8.5 in.x11 in. label	NP	NP	NP

Company E (2010)	NP	NP	$10,000-$25,000	NP	NP	NP	NP	NP	NP	B&W $0.09,
color $0.15	NP

Company F (2010)	Couple of cents more per label, $300/year	NP	NP	$45-$50
Couple of $ more for color but not significant	NP	NP	NP	NP	B&W < $0.10
NP

Company G (2010)	NP	Laser a few hundred, thermal transfer upwards of
$1,000- $5,000 	Laser a few hundred, thermal transfer upwards of $1000-
$5000 	NP	NP	NP	NP	NP	NP	NP	NP

Company H (2010)	10-20%	NP	NP	$70 	$350 (5 times more expensive than
black cartridge)	NP	NP	NP	NP	NP	NP

Company I (2010)	$0.04 per label	NP	NP	NP	NP	NP	NP	NP	NP	NP	4 ¼ sq. in.
stickers estimated to cost $0.02 more for color

Company J (2010)	"Will definitely have an impact"	NP	NP	NP	NP	NP	NP	NP
$0.05 per label for 3.67 in. by 7.5 in. and 2.5 in. by 5 in.	NP	NP

Company K (2010)	None	NP	NP	NP	NP	NP	NP	NP	NP	NP	NP

Company L (2010)	Cost increase due to color and increased label size	NP
NP	NP	NP	NP	NP	NP	NP	$0.02 per label	NP

Company M (2010)	Several million dollars to switch to GHS (training,
labeling, redesigning MSDS, etc.)	NP	NP	NP	NP	NP	NP	NP	NP	NP	NP

Distributor A (2010)	NP	NP	NP	NP	NP	NP	NP	NP	NP	NP	NP

Vendor B (2010a)	At least 20-30%	$700 for thermal or laser	$1,200 for
color laser	$370 each, prints 10,000 - 20,000 labels ($0.02-$0.04 per
label)	Set of 4 costs $1,512 (4 * $378), prints 6,000 labels ($0.25 per
label)	Ribbons in a B&W thermal printer print twice as many as cartridge
in the color laser printer	4 or 5 times more expensive than B&W.
$150-$200 for 200-500 8.5 in.x11 in. vinyl labels ($0.30-$1.00 per
label); $3.50 for 250 4 in.x6 in. labels ($0.01 each)	20% more than
blank labels; $50 per 1,000 labels ($.05 per label) or $12-$17 per 250
labels ($0.05-$0.07 per label)	NP	NP

Vendor B (2010b)	NP	NP	NP	$200, prints 20,000 labels ($0.01 per label)
Set of 4 $1,200, prints 6,000 labels ($0.20 per label)	NP	NP	8.5 in.x11
in. vinyl labels size 8.5x11 $0.20-$0.23 per label	NP	NP	NP

Vendor C (2010)	NP	NP	PRO $1,499, PRO 300 $1,745, PRO 7000 $3,495, PRO
9000 $3,995	NP	NP	$249.95 for 7 in. by 492 ft resin ribbon	$299.95 for 7
in. by 492 ft red resin ribbon	NP	NP	NP	NP

Vendor D (2010)	NP	NP	NP	NP	NP	NP	NP	Blank,  2 5/26 in. by 4 in. label
costs $73.33 per 1,000 labels ($0.07 per label)	$86.67 for 1,000 white
labels with red border ($0.09 per label); Cost increases 18.2%	NP	NP

Vendor E (2010)	NP	NP	NP	NP	NP	NP	NP	NP	NP	For a GHS 6 in. by 10 in.
label: $0.02-$0.30 for black pictogram border, $0.09-$0.30 for red
pictogram border (See   REF _Ref259713546 \h  \* MERGEFORMAT  Table 4-3
)	NP

Vendor F (2010)	With ink jet, would not cost much more to add red	NP
Most expensive inkjet label printer $2,995, top of the line LaserJet
label printer $18,000.	NP	NP	NP	NP	NP	NP	For a 6 in by 8 in. GHS label,
$0.165 for black pictogram border, $0.145 for red border	NP

Vendor/ Printer A (2010a)	Short run digital printing ~30% more, no
increase for traditional printing for large quantities	NP	Entry level
(200 labels per day) $3,000, High speed machine costs $18,000	Inkjet
label printer: Black ink cartridge = $42.95 each; $42.09 if more than or
equal to 3; $41.66 if more than or equal to 5; $40.80 if more than or
equal to 7; $39.94 if more than or equal to 10	Inkjet label printer:
Color ink cartridge = $47.95 each; $46.99 if more than or equal to 3;
$46.52 if more than or equal to 5; $45.55 if more than or equal to 7;
$44.59 if more than or equal to 10	For thermal transfer printer, black
resin ribbon i.e. 6.25 in. by 300 m costs $64.18 (same as the color
ribbon). A similar size wax color ribbon and wax/resin color ribbon
costs $10.27 and $32.81 respectively.	For thermal transfer printer, red
premium resin ribbon i.e. 6.25 in. by 300 m costs $64.18, gives
approximately 1,180 labels that are 6 in. by 10 in. and costs $54.31 to
print 1,000 labels. A similar size wax color ribbon and wax/resin color
ribbon costs $40.05 and $36.45 respectively.	NP	NP	NP	Using short run
digital printing to print 2 in. by 2 in. pictogram with all black print
on gloss paper costs $.05 each, red border on paper $0.06 per label, on
vinyl $0.09 per label; short run digital printing black on paper $0.05
per label, on vinyl $0.07 per label; traditional offset printing for
large quantities, red border = $0.01 per label

Vendor/ Printer A (2010b)	Negligible	NP	NP	Inkjet $39.94	Inkjet $44.59
each	NP	NP	6 in.x10 in. for Inkjet: $215.12 per 1,000 for gloss ($0.22
each), $86.84 per 1,000 for matte ($0.0868) each	NP	NP	NP

Vendor/Printer B (2010a)	NP	NP	NP	NP	NP	NP	NP	NP	NP	NP	$18 for roll of
100 2 in. by 2 in. labels pictogram stickers ($0.18 per sticker); $12
per roll for orders of ≥ 10 rolls ($0.12 per sticker)

Vendor/Printer B (2010b)	No increase	NP	NP	NP	NP	NP	NP	NP	NP	6 in. by 10
in. personalized GHS labels with 1-3 pictograms: 250 labels $1.81 each;
500 labels $0.95 each;750 labels $0.68 each;

1,000 labels $0.55 each	NP

NP: Not Provided

Bureau of Economic Analysis. 2002. Benchmark Input-Output Accounts.
Available at http://www.bea.gov/industry/index.htm#annual.

Company A, 2010a. Telephone Conversation between Company A and Eastern
Research Group, March 25, 2010.

Company A, 2010b. Email between Company A and Eastern Research Group,
March 25, 2010.

Company B, 2010. Telephone Conversation between Company B and Eastern
Research Group, April 1, 2010.

Company C, 2010. Telephone Conversation between Company C and Eastern
Research Group, April 6, 2010.

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Ѐ.摧㟧ßᴀCompany F, 2010. Telephone Conversation between Company F
and Eastern Research Group, April 9, 2010.

Company G, 2010. Telephone Conversation between Company G and Eastern
Research Group, April 12, 2010.

Company H, 2010. Telephone Conversation between Company H and Eastern
Research Group, April 2, 2010.

Company I, 2010. Email between Company I and Eastern Research Group,
April 14, 2010.

Company J, 2010. Telephone Conversation between Company J and Eastern
Research Group, April 20, 2010.

Company K, 2010. Telephone Conversation between Company K and Eastern
Research Group, April 19, 2010.

Company L, 2010. Email between Company L and Eastern Research Group,
April 27, 2010.

Company M, 2010. Telephone Conversation between Company M and Eastern
Research Group, April 23, 2010.

Consultant A, 2010. Telephone Conversation between Consultant A and
Eastern Research Group, March 30, 2010.

Consultant B, 2010. Telephone Conversation between Consultant B and
Eastern Research Group, March 30, 2010.

Distributor A, 2010. Telephone Conversation between Distributor A and
Eastern Research Group, April 1, 2010.

DYMO. 2010. Rhino 5200 Industrial Label Printer. Available at
http://sites.dymo.com/Solutions/Pages/Product_Details.aspx?prod=1755749(
DYMO).

European Chemicals Agency (ECHA). 2009. CLP-Regulation (EC) No
1272/2008. Available at
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:353:0001
:1355:en:PDF.

Morris, G. 2007. Drum Beaters. Inbound Logistics. Available at
http://www.inboundlogistics.com/articles/features/1007_feature03.shtml.

Printer A, 2010. Telephone Conversation between Printer A and Eastern
Research Group, March 23, 2010.

TPGTEX Label Solutions. 2010. Choosing a Printer. Available at
http://www.tpgtex.com/choosing_printers.html.

U.S. Census Bureau 2007a. American Fact Finder: Commodity Flow Survey.
Downloaded March 31, 2010. Available at
http://www.census.gov/econ/census07/index.html.

U.S. Census Bureau 2007b. Economic Census. Available at
http://www.census.gov/econ/census07/index.html.

Vendor A, 2010a. Telephone Conversation between Vendor A and Eastern
Research Group, March 30, 2010.

Vendor A, 2010b. Telephone Conversation between Vendor A and Eastern
Research Group, March 30, 2010.

Vendor B, 2010a. Telephone Conversation between Vendor B and Eastern
Research Group, March 26, 2010.

Vendor B, 2010b. Telephone Conversation between Vendor B and Eastern
Research Group, April 1, 2010.

Vendor C, 2010. Telephone Conversation between Vendor C and Eastern
Research Group, March 26, 2010.

Vendor D, 2010. Telephone Conversation between Vendor D and Eastern
Research Group, April 1, 2010.

Vendor E, 2010. Email between Vendor E and Eastern Research Group, April
12, 2010.

Vendor F, 2010. Email between Vendor F and Eastern Research Group, April
26, 2010 and April 27, 2010.

Vendor/Printer A, 2010a. Telephone Conversation between Vendor/Printer A
and Eastern Research Group, March 24, 2010.

Vendor/Printer A, 2010b. Telephone Conversation between Vendor/Printer A
and Eastern Research Group, April 1, 2010.

Vendor/Printer B, 2010a. Telephone Conversation between Vendor/Printer B
and Eastern Research Group, March 23, 2010.

Vendor/Printer B, 2010b. Telephone Conversation between Vendor/Printer B
and Eastern Research Group, March 25, 2010.

  CFS also provides value of shipment, ton-miles, and average miles
shipped. At this time we expect such data to be of secondary importance.

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