Contract No. GS-10-F-0125P 

Phone Log

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. 0193.15.089.002

ERG Task No. 0193.19.016.001

Date: April 28, 2010

Table of Contents

  TOC \h \z \t "Heading 1,1"    HYPERLINK \l "_Toc260049801"  Company A	
 PAGEREF _Toc260049801 \h  1  

  HYPERLINK \l "_Toc260049802"  Company B	  PAGEREF _Toc260049802 \h  2 


  HYPERLINK \l "_Toc260049803"  Company C	  PAGEREF _Toc260049803 \h  4 


  HYPERLINK \l "_Toc260049804"  Company D	  PAGEREF _Toc260049804 \h  5 


  HYPERLINK \l "_Toc260049805"  Company E	  PAGEREF _Toc260049805 \h  6 


  HYPERLINK \l "_Toc260049806"  Company F	  PAGEREF _Toc260049806 \h  7 


  HYPERLINK \l "_Toc260049807"  Company G	  PAGEREF _Toc260049807 \h  8 


  HYPERLINK \l "_Toc260049808"  Company H	  PAGEREF _Toc260049808 \h  9 


  HYPERLINK \l "_Toc260049809"  Company I	  PAGEREF _Toc260049809 \h  10
 

  HYPERLINK \l "_Toc260049810"  Company J	  PAGEREF _Toc260049810 \h  11
 

  HYPERLINK \l "_Toc260049811"  Company K	  PAGEREF _Toc260049811 \h  12
 

  HYPERLINK \l "_Toc260049812"  Company L	  PAGEREF _Toc260049812 \h  13
 

  HYPERLINK \l "_Toc260049813"  Company M	  PAGEREF _Toc260049813 \h  14
 

  HYPERLINK \l "_Toc260049814"  Consultant A	  PAGEREF _Toc260049814 \h 
15  

  HYPERLINK \l "_Toc260049815"  Consultant B	  PAGEREF _Toc260049815 \h 
16  

  HYPERLINK \l "_Toc260049816"  Distributor A	  PAGEREF _Toc260049816 \h
 17  

  HYPERLINK \l "_Toc260049817"  Printer A	  PAGEREF _Toc260049817 \h  18
 

  HYPERLINK \l "_Toc260049818"  Vendor A	  PAGEREF _Toc260049818 \h  19 


  HYPERLINK \l "_Toc260049819"  Vendor B	  PAGEREF _Toc260049819 \h  21 


  HYPERLINK \l "_Toc260049820"  Vendor C	  PAGEREF _Toc260049820 \h  25 


  HYPERLINK \l "_Toc260049821"  Vendor D	  PAGEREF _Toc260049821 \h  27 


  HYPERLINK \l "_Toc260049822"  Vendor E	  PAGEREF _Toc260049822 \h  28 


  HYPERLINK \l "_Toc260049823"  Vendor F	  PAGEREF _Toc260049823 \h  30 


  HYPERLINK \l "_Toc260049824"  Vendor/Printer A	  PAGEREF _Toc260049824
\h  32  

  HYPERLINK \l "_Toc260049825"  Vendor/Printer A	  PAGEREF _Toc260049825
\h  32  

  HYPERLINK \l "_Toc260049826"  Vendor/Printer B	  PAGEREF _Toc260049826
\h  34  

 

Company A

Phone Call with ERG, 3/25/10

Working to comply with GHS implementation in Europe end of 2010, Brazil,
China

Use SAP to store classification (CAS #s) in separate places for
different regions

End up with different classifications for different countries even
though all GHS—so going from region-specific to country-specific
(i.e., getting more complicated)

7-8,000 chemicals/CAS #s have to be reclassified

Starting to buy color printers-now they print OSHA and transport labels
together, and buy pre-printed stock that they print on in B&W. They are
switching to separate labels

They do have some facilities that ship only domestically

If have things in a pallet/box, have transport label on outside

Some divisions print in color

Design labels in Word template that pulls data from SAP

Some divisions (consumer) buy pre-printed

Meet for OSHA and Consumer Products Safety standards for labeling

U.S. proposed rule is “purple book-ish” and relatively
straightforward (as is Brazil, and probably rest of the Americas);
Europe more complicated

The color printers have smaller format than current B&W

Current labels on 55 gal. drum are 9” x 16”

Email from Company A to ERG, 3/25/10

From: [Company A]

 To: [ERG]

Date: 3/25/2010 4:04 PM

Subject: Re: Request for brief conversation regarding costs of GHS
labels

I spoke with [redacted] (the EH&S label owner), and she told me that we
print 250,000 labels per month. The old black and white printers are
approx. $5,000 each and the new color printers are $1500 - 1700. She
does not know what the stock runs. I have copied her on this email; if
you'd like to chat with her, perhaps you can set something up.

Regards,

[Company A]

Company B

Call with ERG 4/1/10

There is no option to print in B&W under EU’s CLP, that Company B is
aware of

CLP is a regulation so all member countries have to do the same thing,
but interpretation can be different

In the EU, already had an orange box system. For that, they use
pre-printed stock and print in B&W

They use a thermal transfer printer now

They are planning on doing the same for GHS, assuming that having empty
diamonds is okay (since to hard to have varieties of stock with
different numbers of diamonds)—they don’t know if it will be
allowed, but are going to do it and wait for the first court case

Australia doesn’t accept empty diamonds

Some countries (e.g., Poland) get revenue from fines, so they might not
be very flexible

Other alternative is to buy color printers, which are expensive

They do international shipping so have to use British Standard 5609 (?)
for seawater submersion and abrasion, so limited to choice of printers

Ink and label stock are the problem

The only printer Company B knows that is compliant is the OKI printer,
which is ₤3,000 and limited to A3 sheets (as opposed to the roll they
use now)

Label stock is 20-35% more expensive than they use now (which costs ~
₤0.22 ea)

Color thermal transfer printers run ₤25-30k

Ribbon >₤100 each, and ribbons are constantly moving (so getting used
up even if not actually printing)

₤12-15k for digital printer, ~ ₤100 for ink cartridges (which are
small so you have to buy a lot)

₤100 for ink cartridges, which are small so you have to buy a lot

They have 14 sites globally and a total of 28-30 printers

2x2 diamond stickers are not practical for them—right now their
(combined CLP and transport) labels are all automated, to reduce
operator error, and having someone have to choose which stickers to
affix would introduce operator error

OKI is only one Company B knows of making a compliant printer, and Epson
is working on it

It’s not just the issue of buying a color printer, it’s finding one
that is compliant

They do primarily drum labels

They print 100,000 labels per month, maybe more (varies from month to
month)

12 label designs for different markets, with different sizes

Lumped into regulatory budget, so no line item Company B can separate
out

Roll of 1,000 labels is ₤150 to 200 for blank pre-printed stock

Resin ribbons are ₤40 ea for ~500 labels

Labeling is a small part of total costs

Fairly easy to line up the pictogram inside a pre-printed diamond if you
have a good printer, they have experience doing it with EU orange
diamonds (cheap printers are not so good)

They use top range Zebra printers, which they installed in the last 4-5
years so they are practically brand new

Running cost includes ribbons and label stock (plus some labor, but
those guys do other things also)

Use EU labels in rest of world except US, Mexico and WHMIS for Canada

Use easy peel label in UK and Germany for shipping within company/to
warehouses, then they add on other label at warehouse—if not going
over water can do that.

Someone has to physically stick the label on the drum or “easy pack”

All ribbons turn together so could use up color even if not printing in
that color

Print on polypropylene

Company C

Call with ERG, 4/6/10

Company C is planning on being fully GHS compliant by the end of the
calendar  year

The company uses a customized system to print the labels. They use Order
Management System. The operating system used is AS 4000, a software that
formats labels in desired ways. The software pulls information from the
database and then prints them.

Labels:

The company prints approximately 300,000 to 400,000 labels/year

While going from B&W to red frame the cost might go up by about 4 cents
per label.  

This  might increase the total printing cost by approx $20,000 per year
for the company

Printers:

They currently have 6 printers. They have facilities in 3 locations and
each has 2 printers.

They use HP laser jet (he wasn’t sure of the model number) ( They only
print B&W as of now

They are looking to move to thermal label printers which will print in
color and are also faster 

HP laser jet use sheets of label (one sheet has many labels on them) but
the new thermal label printer will use roll of labels. 

They plan to get at least 6 of these thermal printers

Toners:

Approximately $40/cartridge for B&W

Use couple of hundred of them annually (He was not absolutely positive)

Pre-printing:

They do pre-printing to get the blue color border (company logo) on the
label

They do not print color in-house. Only print the product information on
the label in B&W

Cost Comparisons (approximation):

Label Size	% of Labels Printed per year by Size	Cost to print GHS Label
w/ Black frame	Cost to print GHS Label w/ Red frame

Small (Regular): 1"x3"	50%	5 cents	10-11 cents

Medium: 2"x3"	35%	8 cents	15 cents

Large: 6"x8"	15%	15 cents	25-30 cents



Company D

Call with ERG, 4/8/10

Labels:

They print around 100 labels/week. 

The cost ranges from 25 cents to 75 cents per piece. The expensive one
are made of weather proof polyester material while the cheaper ones are
not. 

The label size they produce are 8.5"x11". 

They are currently printing only B&W. 

She mentioned that the company is not switching to color printing any
time soon but she estimated that the cost my almost double per label. 

Printer: 

They use only 1 laser printer at the company at the moment (Model No: HP
2015). They do not preprint labels.  

Company E

Call with ERG, 4/9/10

North American affiliate of Company M

GHS Compliance:

Only their exports are GHS compliant domestic labels still in B&W

They have not officially started but are in the testing phase and hence
conducting long-term stability study

Printers:

Cost $10,000 to $25,000 each

$100 per cartridge (not sure which one)

They have 10-12 printers in US across all sites. They include both
thermal and laser jet.

Labels:

B&W label costs about 9 cents while color labels cost approximately 15
cents.

Company F

Call with ERG, 4/9/10

Labels:

Most labels supplied by customers

Print approximately 200-250 labels per month

Labels are printed on vinyl; Size: 8.5 in by 11 in. size

90 percent of the labels printed are B&W

Printing B&W label is no more than 10 cents per labels. Colored labels
will be a couple of cents more

10 percent( color printing on labels for company logos etc.

Printers:

They use 3 laser printers

They already have color printers in place so no additional cost from
switching to color printing

Cartridges:

B&W cartridge cost approximately $45-$50

Color cartridge cost a couple dollars more but not significant increase
in cost

Cost from switching to GHS:

Worst case scenario: $300 increase in overall cost 

Encouraged by the idea to GHS Labeling

Other companies complaining about high costs is “hard to swallow”

Company G

Call with ERG, 4/12/10

A laser printer printing generic labels could cost only a few hundred
dollars.  

A Thermal transfer printer could cost upwards of $1000- $5000, but you
get far greater flexibility in printing a wide variety of product
labels, are extremely durable, and basically last forever. They have
printers at the site that have been printing several hundred labels
daily for 12 years + , and are still going strong

 

Company H

Call with ERG, 4/2/10

Company H has multiple business units

Currently do not comply with GHS 

Labels:

Only print B&W labels 

Adding another color to the label will increase the cost by 10-20% at
least

This particular plant in MA sends 50 bulk shipments annually and per
shipment uses upto 10 labels; The containers used hold about a kilo of
pharmaceutical chemicals

No idea of how much they spend on labeling

   Printers:

They have both B&W printers and color laser printers but they try not to
use the color printers that much

If producing MSDS they use the color laser if colors are required

They try to send most of their MSDSs electronically so that they don’t
have to print as many

But they will have to use color laser printers if they are required to
and follow GHS in the future

No idea how much the B&W and color printers cost

B&W cartridge cost around $70 each

Color cartridge cost around $70 x 5 (expensive)

Company I

Phone call and Email to ERG, 4/14/10

This company manufactures industrial and agricultural cleaners, high
concentrate bleach, and such, mostly for private label customers. 

They have 80 employees.

For industrial products, they go by HMIS codes and DOT descriptions and
OSHA requirements. 

Product labels and hazard labels are separate. 

He uses stickers for the hazard labels. 

Some product labels they get preprinted from their customers (like the
one below), so no cost to them. 

When they print product labels, they use computer generated labels
printed on a black office LaserJet machine. 

Durability is not an issue. He prefers that the labels biodegrade within
a year. 

They don't print their own hazard labels.  

 For the hazard warning, they mostly use black and white 4 1/4
in.-square DOT-type stickers with the word "corrosive" and the standard
pictogram. (Some products use "flammable" sticker.) 

As he indicated, he buys the labels from vendors. 

He estimates they use 40,000 such labels a year. 

Size of containers varies from 5 gal. to 55 gal, with a few 1 gal. and a
few 275 gallon. 

Asked what the hazard stickers cost, he said "Peanuts--maybe 4 cents
each."  

Asked about the impact of GHS red diamond requirement, he said "I dunno,
 maybe a couple of cents more per label." 

Sample of label provided by customer to Company I to be applied to
container. 

Company I produces chemical, bottles chemical, applies this label, and
also applies HMIS hazard pictogram sticker, which they supply.

Company J

Call with ERG, 4/20/10

Spoke with Contact in Regulatory Affairs. 

In US, Company J has three facilities with 120 employees total.

Switching to red diamonds will “definitely have an impact.”

They have 10,000 different labels (products).

They use a Zebra thermal transfer printer to print black onto labels
preprinted with company logo (color) and color HMIS boxes. 

Have had “good success” printing in register, printing numbers
inside boxes.

Label sizes:

In 2009, ordered 1 million 3.67” by 7.5” preprinted labels [referred
to them as “shell” labels] and c. 700,000 2.5” by 5” labels. 

Cost about 5 cents each.

Container sizes:

500 ml to 20 l are most common, more than 95 percent of containers.

4 oz or smaller are less than 5%.

They use Avery labels for very small containers (50 ml). 

Other:

Commented that they don’t use hazard symbols now except to ship to
Canada, and then they use black printing only. 

Preference would be to have all black labels (i.e., black borders around
pictograms).

Company K

Call with ERG, 4/19/10

Sizes of containers: 50 ml, 100 ml, 250 ml, 500 ml, up to 55 gal.

40,000 to 50,000 labels per year

10% of containers are < 100 ml

20% of containers are < 500 ml

Problem with smaller containers: how attach new labels? (apparently not
now a problem). Said they would cost “3 times as much”.

Other labels: They use preprinted and print all black onto color labels.
Intend to use same strategy for GHS labels when rule changes, so no
printing cost increase.

(Said big increase would come from paying a designer to redesign all the
labels, estimated full time for a year.)

Biggest people in their business: Mallinkrodt, EMD, Fisher Scientific,
VWR, and Ricca.

# of employees: 30

Containers:

They use bottles as small as 100 ml

Below are some of the containers Company K  uses:

 

 

 

 

 

 

Hed-Pak



Company L

Call with ERG, 4/23/10

Cost from GHS Labeling Compliance:

“Trivial”, “not an issue”

They print small number of labels hence it is not a problem for them

Labels:

They print color labels

They print 20 labels per day, i.e. 20x365 = 7,300 labels per year

Label sizes range from 2 in. wide all the way to a drum labels that are
a foot wide

They print “as you need”

They do not use border stickers

Label Cost:

No idea of cost per label

More labels you print the less per label cost will be

Printer:

They use a standard color laser printer 

2 printers especially dedicated to label printing but have many other
printers too

Major issue with GHS Compliance:

They print a lot of small labels for chemicals that are sold in small
amounts

Very hard to get all the information required by GHS on to the small
labels 

Many companies print label size 2 in. by ½ in. (3/4 in.) labels for
containers as high as 1 ½ in. with 1 g of material which might require
as many as 3 pictograms. Very difficult to fit all the information
considering the tiny label sizes

Company M

Call with ERG, 4/23/10

GHS Compliance:

They are switching to GHS Labeling

For substances: By end of November, 2010

For mixtures: By middle of 2015

Labels:

They print color labels

Difficult to give label costs

Costs increase by several million dollars to switch to GHS (includes
training costs, labeling costs, redesigning MSDSs, etc.)

They used to preprint labels before but after 2008 printed color labels
in-houses

Can’t give how many labels they print

Label sizes:

They print the following label sizes.

Label Sizes Used for Different Chemical Categories by Weight

Weight of Packed Products	Hazardous Chemical	Non-Hazardous Chemical    

Above 500 kg/l	200x143 mm	205x85 mm

5 kg to 500 kg	285x100 mm	205x85 mm

500 g to 5 kg	230x85 mm	205x85 mm

500 g	170x70 mm	170x70 mm

250 g to 500 g	150x52 mm	150x52 mm

125 g to 250 g	120x30 mm	120x30 mm

50 g to 125 g	90x30 mm	90x30 mm

10 g to 50 g	65x23 mm	65x23 mm

Less than 10 g	55x23 mm	55x23mm



Consultant A

Call with ERG 3/30/10

Consultant A primarily works on MSDS authoring

Most of Consultant A’s clients are large multinational biotech and
pharma companies

Consultant A’s clients are already doing it for the EU and already
pretty far along in MSDSs and labeling

Most already printing in color

They don’t care if black or red—the expense is trivial

Biotech and pharma have well-funded EHS and big margins, so not as much
of an issue for them as some other industries

If in final package size to end user doesn’t need GHS labeling; they
do OSHA labeling when shipping something like a drum between facilities

They do whatever standard is the most stringent, so they will probably
do EU GHS labeling and that will exceed current OSHA standards

Consultant A does have one client that only ships domestically;
Consultant A doubts they would want to do black diamonds

Software will come out and price of color printers and bulk labels is
reasonable

As demand goes up in reaction to rule, printers will react and find ways
to meet demand competitively

Most of the companies Consultant A works with probably contract out
labeling

Pharma companies that deal in large quantities contract out the whole
packaging part and ship out tablets in 55 gal. drum to someone who does
all of the packaging

Lots of companies (small and medium sized) don’t have a clue it’s
happening or are dragging their feet—they’ll ship it to the EU and
it’ll get hung up in customs and then they’ll realize it.  Big
companies have floors full of people working on it

Consultant A’s company does wording and selection of pictogram, but
the company has an existing relationship with a printer

In the EU, challenge Consultant A sees is that research samples aren’t
exempt from GHS labeling, and that is small packages that can’t fit
GHS label

Consultant B

Call with ERG 3/30/10

Some do own printing, some contract out

One client Consultant B just talked to is the only one Consultant B
knows of doing B&W. They’re a large plastic company, most products
going to other companies so no consumer, don’t care if logo is B&W

That company orders corrugated boxes pre-printed in B&W (but they do
print individual labels with lot number, etc.)

Companies Consultant B works with range from very small to large (e.g.,
Prestone)

The vast majority are already printing in color (logos)

Larger companies doing EU/CLP labeling already

Some do 1 panel EU/CLP, 1 panel WHMIS, and 1 US

Once you’ve done the labeling sheet (SDS?) label is done

Cost probably < $50-100 for labeling (whole labeling process?)

Incremental cost would either be buying the equipment or sending to the
printers

People contract out because want level of durability they can’t do
themselves; chemical companies might have chemicals that will smudge or
disintegrate the label, so get top coating

If do same product all the time can do off site, but some companies want
flexibility and quick turnover

Off site costs probably similar to printing in-house—cost  is not the
deciding issue

A lot of people do SAP/just in time printing to minimize stockpiles,
able to add lot #

Will have some additional costs if doing B&W, but gets blown out of
proportion

Some of Consultant B’s clients do DOT and OSHA label together

HMIS and NFPA labeling is voluntary and designed for emergency
responders; some companies like to use it for in plant labeling so like
it to come that way. However the numerical scheme for the degree of
hazard is opposite of GHS, so they might abandon it. Probably 30% do
either NFPA or HMIS, and those are in color

People often buy those pre-printed

Could also buy the pre-printed 2x2 pictograms, but if they have tons of
products they don’t want to spend the manpower to affix them

Distributor A

Call with ERG, 4/1/10

They are basically importers and distributors of chemical products and
the products that they get already come labeled that with OSHA/GHS
compliant labels. No idea or estimate of how much the increase in cost
would be. 

They print DOT labels, which requires the label to be printed in
different colors

They have a software/program to print the DOT labels but they would need
to get a new module installed in their program to make it GHS compliant

No idea of how much the new module would cost

Mentioned they have minimal involvement in printing labels so they did
not have any information 

Printer A

Call with ERG, 3/23/10

2 in. by 2 in. on matte vinyl, adhesive back

100 labels per roll @ $18.00 per roll.

Orders of 250 rolls or more get small discount.

Larger and smaller versions are custom jobs.

She said she’s never sold them without the red borders.

Call with ERG, 2/25/10

They haven’t done larger labels with company names and other
information.

(Seems like they really just distribute these rolls of 2 by 2 labels).

Call with ERG, 4/22/10

Contact has seen an increase in GHS stickers and labels ordered, but
people are not ordering for everything they’re doing. 

About 30% of their customers use them  

2700 customers total, but not all ship hazmat.

Vendor A

Phone Call with ERG, 3/30/10, First Contact Person 

They do not offer color printers

They offer color ribbons

6 rolls in 1 case

Color( for a 2.5” (width), $6.5/roll on average; for a 4.33”
(width), $11.27/roll

Regular (Black) ( for a 2.5” (width), $2.36/roll on average; for a
4.33” (width) $4.87/roll

When asked about an estimate of these rolls that companies of different
sizes order/buy on an annual basis she mentioned the information was
confidential

Phone Call with ERG, 3/30/10, Second Contact Person

How many of these rolls do companies buy on annual basis?

Depends on whether they are buying for themselves or buying to send it
to other companies who then send labels to end user customers.

Depends on the type of printer model that the companies are using

Ribbons

Table top printer ribbon costs approximately $36/box to $67/box

A B&W ribbon costs $13.96/roll (2.5” width); $24.04/roll (4.3”
width)

A color ribbon costs approx. $20 extra i.e. $13.96+$20 = $33.96/roll;
$67.64/roll (4.3” width)

Price of ribbons depends on what types of printers are being used in
companies eg. Table top printers (regular), industrial printers (used in
factories), mobile printers (use in retail environment)

Label Materials

They offer various type of label materials e.g. paper label, acrylic,
UV, chemical and weather resistant

Companies get discount on buying bulk

Hence pricing depends on how much the companies are buying

Labels for tabletop printers, there are approx 5570 labels/roll (  in 1
carton there are 4 rolls 

Prices are different and goes up to $61 per carton

The company usually sends the products to mass distributors who then
ship them to different companies

NOTE 1: They said that their distributors (who will most likely have
information about how much ribbons they are selling to different
companies) will not be able to give information if we are not purchasing
from them.

NOTE 2: Although the information received from the two contact persons
indicated a higher cost associated with color ribbons vs black ribbons,
the estimates given were drastically different.

Vendor B

Call with ERG, 4/1/10

In order to comply with the GHS Labeling, companies have 2 possible
options:

 

Preprint all labels (for color)

20% more than blank labels

Then use one of the following two printers to print the information in
B&W

Thermal printer or B&W laser printer ( costs around $700 each

Thermal printers are very fast but cannot print color

Chemical companies cannot use inkjet printer because its ink fades away
in weather. They have to use weather resistant labels.

Use Color Laser printer

Costs around $1200 (twice as expensive as B&W printer)

Regular Industrial B&W Ink cartridge costs $370 each ( prints around
10,000 to 20,000 pages

Color cartridge for Color Laser printer costs $378 each, but need to use
4 cartridges so it costs $378*4 = $1512 ( prints around 6,000 pages

Labels:

Chemical companies have to use vinyl labels (no choice on label
material)

Average price about 500 of regular (8.5 x 11) label is $150-$200;
200/500 = 0.4 cent per label

4x6 roll of label ( has about 250 labels ( costs $3.50 

Preprinting the same label costs around $50 per 1000 labels or $12.50
per 250 labels (she mentioned $17 per 250 labels = almost 4 times the
cost of blank label)

Per roll has label numbers ranging from 250 to >1000

Printers:

Thermal printer

Very fast, cannot print color

2 types of thermal printer

Direct thermal ( heats up the paper

Thermal transfer( heats up the ribbon and then pasted on to the label
material

Ribbon for color 4 or 5 times more expensive than the B&W ribbon

Color Laser printer

Slow, can print color

It needs 3 laser printers to do the job of 1 thermal printer

Color Laser printer prints about 22 pages/min( when the same printer
print B&W it prints around 30 pages/min

Thermal printer prints 3 times faster than laser printer

Ribbon in a B&W (thermal) printer prints twice as many as the toner in
the color laser printer

Black toner in a color laser printer prints about the same as the color
toner in the color laser printer

Laser printer uses “toner”; Thermal printer uses “ribbon”;
Inkjet printer uses “ink” (chemical companies cannot use this as it
is not weather resistant). 

What companies are doing:

Moving from preprinting labels to “shell labeling”

That’s where their software comes in ( Costs $25,300 to $1 mill. 

Software( pulls data from the company database and then prints them on
the label. Hence unlike in case of preprinting where it if there is any
change in label then there is no way to change the label leading to huge
waste of labels and loss of money, these software allows data to be
changed and corrected thereby only printing the correct labels. 

Preprinting label is good when it is known exactly what needs to be on
the label and that is not going to change. Eg. She mentioned when
exporting to Europe they use preprinting as they have “premade
phrasing” 

With the new GHS Labeling, it is not sure where exactly the pictogram
goes so its not the best to preprint labels. Depending on the
chemicals/mixtures the placement of the red frame is going to change. 

From the new GHS Labeling requirement, cost will at least increase at
least 20 – 30%.

Small Companies:

Spend from $10,000/year to $100,000/year on labeling (not including
printer costs)

With the new GHS Labeling requirement, cost will increase at least 20
– 30%

They are either preprinting or printing in color

Large Companies:

Spend at least $100,000/year on labeling (not including printer costs)(
large companies don’t share all their labeling costs with the vendor

With the new GHS Labeling requirement, cost will increase at least 20
– 30%

Cost also depends on

How many products they are producing/shipping

How much is shipped internationally

Other Issues:

Some companies do not have the capacity to send color printing signals
with their database software to the printers. In such case they will
have to update their database system so that the system can do this for
them (i.e. take information from their database and import it onto a
software that can send the color printing signals).

Other points:

She mentioned one of the big companies that they were working with
currently had 8 thermal printers and printed 30,000 labels/monthly

The labels need to go on every container that is being shipped

Customers include chemical companies such as: 

GE

Ashland and Hercules

Shell Canada (only company not based in U.S.)

Oxy Chemical

Independent Chemical

Air Products and Chemicals

Lonza

Follow-up Call, 4/1/10

Label Costs

Vinyl labels size 8.5 x 11 ( costs around 20-23 cents per label (for the
material cost)

Label costs vary by sizes as labels such as 8.5 x 14 or 8.5 x 17 would
cost more. Also if special dyes are used the cost will increase still

Number of Labels

Hard to tell how many labels companies would produce. Depends on their
size and operation

Small companies can print from 10,000 to 30,000/month while big
companies could print 10 times as many

Printer

Buying a color printer alone will increase costs by 20 – 30%

Color printers start from $1200/$1300 and will increase depending on its
capacity/capabilities

Toner

Set of 4 runs approx $1200 and gives around 6,000 pages (labels)

B&W laser toner costs around $200 each and gives around 20,000 labels

Color laser toner costs around $300 each and gives around 6,000 labels

Set of 4 color toners hence costs $1,200 ($300 x 4)

Issues with color printers

The tray in color printers (that cost around $1200/$1300) can hold
250-300 regular paper which means that they can only hold around 100-200
of the vinyl stock as they are thicker and heavier

So even companies that produce labels as few as 500 would have to have
labor designated to continuously put paper in the printer. Hence,
additional labor costs are involved in such cases.

Issues for small companies

If they only use thermal printers (cannot print in color) at the moment,
additional costs will involve : 

Buying new equipment (printers)

Redesigning label to go into laser printer: In thermal printers there is
no margin on the labels printed but certain margin has to be maintained
in case of labels printed in laser printer so they have to design the
labels so that they fit in the label used in the laser printer

Notes:

What % of small or large firms were GHS compliant at the moment ( even
1% would be surprising

None of the companies they are working with (companies listed above:
mentioned in the first conversation) have the capacity to print in color

Vendor C

Call with ERG, 3/26/10

Some of their customers are chemical producers (big oil and gas
companies)

Only sells printing equipments but don’t use labeling services

Small printer (+software) ( $900

Larger printer (+software) ( $3000

Materials Sent Subsequently:

Printers already compliant with GHS requirements. They include a full
set of GHS complaint symbols and can print labels and signs formatted to
meet GHS requirements. 

This includes:

DLP PRO / DLP PRO 300 ( ½” to 4” tape widths

DLP PRO

Printer price: $1,499

DLP PRO 300

Printer price: $1,745

DLP 7000 ( 4” to 7” tape widths

Following information are from the website 

Printer price: $3,495

Supplies:

4”x140’ Red 3.0 Mil Vinyl Tape ( $219.95 but so did the other colors
including black for the tape of similar dimensions

6”x70’ Red 3.0 Mil ( $182.95 and so did the other colors including
black and white of similar dimensions

7”x70’ Red Vinyl 3.0 Mil( $215.95 and so did the other colors of
similar dimensions

DLP 7”x492’ Red Resin Ribbon ( $299.95; on the other hand DLP
7”x492’ Black Resin Ribbon( $249.95 and white cost $269.95 for
similar dimensions

Kits:

DLP 7000 Hazmat Kit( $6,849.45

DLP 7000 OSHA Kit( $5,495

DLP 9000 printers( 4” to 9” tape widths

Following information are from the website 

Printer price: $3,995

Supplies:

DLP 8.66”x492’ Premium Red Ribbon( $349.95 whereas DLP
8.66”x492’ Black Resin Ribbon( $275.95

Kits:

DLP 9000 & DLP pro OSHA Duo Kit( $8,991

DLP 9000 Hazmat Kit( $11,840

DLP 9000 OSHA Kit( $5,995

DLP features (Software Package included)

prints up to 3 inches per second

chemical resistant vinyl and ribbon for harsh environments

Vinyl size ½” to 4” 

DLP (thermal transfer printer)( OSHA compliant signs and labels

DLP supplies include

Adhesive-backed vinyl( chemical resistant, lasts for years (indoors and
out); continuous rolls range from ½” wide to 4” wide and come in
wide variety of colors

Ribbon( chemical resistant to withstand harsh environments; These
thermal transfer ribbons are 4”and are available in eight colors 

Vendor D

Call with ERG, 3/25/10

Company makes Black and White-only label printers.

2 in. by 2 in. is not a standard size. Closest is 25/16  in. by 4 in. 

Label printers start at $109.00. 

Thermographic process, no ink costs, no cartridge costs. 

2 5/16 in.  by 4 in. paper labels, adhesive back: Roll of 300 blank
white labels @ .0733 ea. = $22.00 per 300. (per thousand = $73.33)

2 5/16 in.  by 4 in. paper labels, adhesive back: Roll of 300 blank
white labels with red border @ .0867 ea. = $26.00 per 300. (per thousand
= $86.67)

Vendor E

Email to ERG, 4/12/10

Ok, after hours of pushing numbers around and examining adhesive labeled
printing offers on the net, they want some serious $$ bucks per each
sticker 6"x10". The internet printers claim that there is no difference
with 2 colors or 20 colors because of the process, but at the prices
they quote upwards of $3.75 to as high as $5:35 depending in quantity it
seems its best to use your office printer unless the media stock is out
of touch It appears that the cost difference of b&w and color only
differs bigger on office machines that are color laser since the price
is so much less in lower cost machines and not the expensive printing
presses. Old process color on old machines are not desirable.

As I mentioned outside of the stock being used, the larger, faster, and
more pricey the machine , the less it is to print and the closer the gap
of b&w against color.

Red uses Magenta,Yellow in addition to Black so the cost on printing
this sticker on a printer 12 years of age like your old Hp is still far
less than the Printing Press.

Color usually averages to no more than 25 cents per sticker with more
red than you have based on 5% coverage. Every model is different.

 Not including paper stock cost of operation:

The cost of printing the label in ALL BLACK ink on a medium-priced black
and white printer: no more than 6- 15  cents each depending on
make/model/process where as HP cheaper would be closer to 12- 15 cents
using cartridges

The cost of printing the label in ALL BLACK ink on a medium priced new
or late model color printer. No more than 2 -8cents each 50 PAGE PER
MINUTE HIGH SPEED would be closer to 2 cents and slower smaller models
up to 8 cents for more expensive cartridges. The higher the yield
cartridge, the less per click cost.

The cost of printing the label with RED BORDERS around the hazard
symbols on the same new or late model color printer as #2. No more than
9-12  cents each. (Process black machines will have usually one drum so
the paper passes 4 xs to make one copy where each color is applied via
one laser to charge drum.

The cost of printing the label in ALL BLACK on an older color printer
that uses the "process black" technology: no more than 25-30 cents each
(process black wastes all 3 inks to combine black that looks like a
dried up black sharpie marker.

The cost of printing the label with RED BORDERS around the hazard
symbols on the same older color printer as #4. No more than 30 cents
each (not much more because your utilizing the many colors for process
black anyway and the colors are slightly more.

 

Note: those are only estimates but accurate as keeping in mind the
smaller the machine the more costly. The lower the size of cartridge
means the less clicks or more cost per print both b&w and color. Process
color does not differ too much in cost difference but its the most
expensive and the least attractive.

 Hope I've been some help!!

Email to ERG 4/22/2010

The only technology that's new is a cheaper inkjet made by [redacted].
It uses a master plate that's good for the same image over and over and
it can produce speed up to 150/minute I believe. The quality is not as
crisp as laser, but it costs pennies per image in color (UNDER 3 CENTS)
if you utilize thousands on the master drum provided by [redacted].

[Redacted] and [redacted] are identical brands. You can look them up on
the web. Churches use them for their weekly church bulletins and the
color is acceptable now with a newer improvement to the engine. The
machines are pricey supporting the theory "the more expensive the
machine the cheaper it is to run it". 

Vendor F

Vendor F manufactures and sells inkjet and LaserJet label printing
machines. The inkjet machines employ a new technology permitting higher
print speeds and greater resolution suitable for small to medium
businesses. Phone contact with sales was followed by e-mail exchange:

Email to Vendor F, 4/23/2010

Dear [Vendor F];

 

What we would like to know is how much more it would cost to print a
label like the one below:

 

 

with red borders instead of black around the pictograms:

 

 

The usual size of this label is 6" by 10", but for this estimate let's
assume we are using your high gloss 8" by 6" stock (#074813) For our
purpose we can assume that both labels will be printed the same size on
the same stock. 

We just want to know if it would cost more, and if so approximately how
much more, to print the black-and-red label than the black-only label,
all else being equal, on the LX900. I don't know how your inkjets print
black (do they use the color cartridges to print black?), so it's hard
for us to figure out how much faster the label with the red would use
up cartridges compared to the black only. 

 

Also, for this simple label in red, would the rate of output be faster
than 4.5" per second? A yes or no is fine on that.

 

Thanks very much, hope to hear from you soon! Best regards, [ERG]

Email to ERG 4/23/10

Hi [ERG],

Thank you for send these over to me. Do you by chance have them as an
attachment form in a jpeg, bitmap, or pdf? The images that came across
were small and extremely blurry, so I know the print quality on them
would not be very good, so I don’t think we would be able to give you
a good estimate on cost per printed label.

Yes, they would print faster than the 5 seconds. I can have the
technician who prints them up on the LX900 also let you know how long it
took to print them.

For the question you had about printing with the black cartridge, it all
depends on what you have set in the printer driver settings. You can
have it print using the black cartridge only, color + black, or the
color cartridges only. If you have it set to color + black, it will use
all the colors and the black cartridge to put down the black ink, as
well as the red cartridge for your red stripe. They will probably print
it up both ways since you have an all black label as well as the black
and red label.

Email to ERG 4/26/10

Here are the answers to your questions:

From what you've told me so far, is it fair to say that the cost to
print all-black labels is about the same as printing the same label with
the red boxes? Based on your image below, I would think that it would
not cost much more to add the red in. Since most of the image is black
it would not require much coloring at all.

You mentioned a red cartridge. Is a red ink cartridge available for
printing spot color? Is it fair to say that it would last a long time if
it were used just to print the red boxes? I believe that printing spot
color is more for like a digital press. Our LX series printers are just
standard inkjet printers, so they will print whatever color you have on
your image. It is a CMYK printer, so it will not work with choosing
pantone colors. Yes, I would think that the red cartridge would last a
long time based on your label below, as there is little red in it. 

I hope this all helps. I will get your labels printed up as soon as
possible and get you your answers.

Email to ERG, 4/28/10

Label with black diamonds

Print Quality 3 in photo mode:  $.165 per label

Print Quality 2 in photo mode:  $.161 per label

Label with red diamonds

Print Quality 3 in photo mode:  $.145 per label

Print Quality 2 in photo mode:  $.144 per label

Please let me know if you have any additional questions.

Thank you,

[Vendor F]

Vendor/Printer A

Call with ERG, 3/24/10

In-house printing:

They have several machines

High speed machine costs c. $18k

Entry level full color about $3k. That one prints about 200 labels per
day. 

Most customers want to print the whole label, not just the little GHS
pictograms. 

In-house use is going to be more expensive anyway and is used for
flexibility. 

Most labels are color now. Maybe drum labels are single color.

 

Costs:

Minimum order is $100.

Short-run digital printing: 

For red border and black pictogram on white background, 2 in. by 2 in.
on gloss paper, adhesive back, 1,000 labels per roll: 2,000 labels @ .06
ea. = $120

2 in. by 2 in. on vinyl, adhesive back, 1,000 labels per roll: 2,000
labels @ .0865 ea. = $173.08.

For black border, black pictogram on white background: 2 in. by 2 in. on
gloss paper, adhesive back, 1,000 labels per roll: 2,000 labels @ .05
ea. = $100

2 in. by 2 in. on vinyl, adhesive back, 1,000 labels per roll: 2,000
labels @ .068 ea. = $136.19.

Traditional printing for large quantities: For red border and black
pictogram on white background:

Minimum run = 100,000

2,000 labels @ .0115 ea. = $23.12  ($11.56 per thousand)

Call with ERG, 03/26/10

She gave prices on blank labels for use in their printers:

6" by 10" blank labels : 

gloss paper @ .215 ea. = $215.12 per 1,000                    

matte paper @.0868 ea. = $86.84 per 1,000

2” by 2” blank labels:

Gloss, @ .01723 ea. = $17.23 per thousand

Matte, @ .00696 ea. = $6.96 per thousand

Referred me to two other contacts.

Call with ERG, 3/26/10:

First Referred Contact: 

Said Zeo inkjet printer would produce c. 100 6 in. by 10 in. GHS labels
per cartridge. 

Said color cartridges are needed even to print black only labels. 

Said cost per label would be about half that or less on bigger machine
(Vivo).

Call with ERG, 3/26/10:

Second Referred Contact:

Red thermal ribbon is $64.80 for a roll 6 in. wide by 300 m. long. She
did not want to quote prices.

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“There’s going to be a lot more categories.”

Ref. to purple book for different categories.

Call with ERG, 3/25/10

Spoke to Contact in sales. Asked about GHS “personalized” labels
(see below)

6 in. by 10 in. labels, information printed to customer specs. 1 to 3
pictograms included (see example below). 

Cost per: 	

250 = 1.81 ea. = $452

500 = 0.95 ea. = $475

750 = 0.68 ea. = $510

1,000 = 0.55 ea. = $550

 

 

She said to get it all black or just the red diamonds in black would
cost the same.

 PAGE   

 PAGE   i 

 

