What information must be included on the label of a secondary container of a hazardous chemical?

Why Do I Need GHS Labels?


Primary & Secondary Container Label Requirements

The globally harmonized system (GHS) of chemical identification and labeling can be a bit complicated, so here we'll try and dive in to the finer details and help make sense of it all.

Primary containers come straight from the manufacturer. They come in drums, tubs, pails, bottles, or other larger canisters that are pre-labeled with the chemical identifier. The "primary container" labels are required to include the manufacturer information. The next section is where things are a little confusing.

Often times, workplace operations require transferring chemicals from the original labeled container into a smaller secondary container (beaker, flask, or bottle). Additionally, certain manufacturing processes require hazardous materials to be transferred into larger containers (plating and finishing operations, semiconductor, and pharmaceutical manufacturing, etc.)

Secondary container labels do not require the manufacturer information. Thankfully, HCL Labels offers chemical resistant and tough adhesive vinyl GHS labels to help you with this kind of thing.

Labeling Requirements for Secondary Containers

These secondary containers are required to be labeled with a GHS chemical label, given if any of the following events occur:

-The material is not used within the work shift of the individual who makes the transfer.

-The worker who made the transfer leaves the work area.

-The container is moved to another work area and is no longer in the possession of the worker who filled the container.

-Labels on portable containers are not required if the worker who made the chemical transfer uses all of the contents during the work shift.

If you use chemicals in the workplace, chances are that you need GHS labels. These labels inform workers of chemical hazards, and keep the company compliant. HCL Labels specializes in producing secondary container GHS labels.

OSHA's Hazard Communication Standard

OSHA hazard communication federal standard [29 CFR 1910.1200(f)(1)] states the following: "Employers must ensure that no worker uses, stores, or allows any other person to use or store any hazardous substance in a laboratory if the container (including bags, barrels, bottles, boxes, cans, cylinders, drums and reaction vessels) does not meet the following labeling requirements in OSHA’s Hazard Communication standard."

-The identity of the chemical and appropriate hazard warnings must be shown on the label.

-The hazard warning must provide users with an immediate understanding of the primary health and/or physical hazard(s) of the chemical through the use of words, pictures, symbols, or any combination of these elements.
-The name and address of the manufacturer, importer or other responsible party must be included on the "primary container" label.
-The hazard label message must be legible, permanently displayed and written in English.

For more information regarding the OSHA HazCom Standard, please review the OSHA standard in it's entirety here -

www.osha.gov

Shop GHS LABELS

Sources:

OSHA QuickFacts. Laboratory Safety Labeling and Transfer of Chemicals. Web. OSHA 3410 8/2011. Occupational Safety and Health Administration. www.osha.gov. 19 April, 2017.

What is a Secondary Container?

When you transfer a chemical from its original container to another container, the container you transfer it into is called a "secondary container."

When Do Secondary Containers Have to Be Labeled?

Except for a few cases, secondary containers must be labeled. IF IN DOUBT, LABEL IT!

One common case where you do not have to label a secondary container is if the container is portable and will be used immediately by the person who transferred the chemical into that container.

For example, if you pour a concentrated disinfectant into a bucket and dilute it with water, and then immediately use it (or pour it into smaller spray bottles to be used later in the day), that mixing bucket does not have to be labeled (but the spray bottles do). Another example is turpentine in a glass jar for cleaning brushes: IF you are going to use it immediately and it will stay under your control, you don't have to label it (although writing "turpentine" on there would be a good idea). But if you are going to use it day after day until it is too dirty to re-use, then it does have to be labeled.

By the way, don't spend a lot of money on labeling the bottles. In the next year or so, OSHA may revamp the whole system of MSDSs and labeling!

What Information Must Appear on the Label?

OSHA says you have to put the PRODUCT NAME, the HAZARDOUS CHEMICALS it contains, and words or pictures that show the KEY HAZARDS (e.g. inhalation hazard, ingestion hazard, skin absorption hazard, skin irritant, eye corrosion hazard, etc). This information can be found on the chemical's original container, or on the MSDS.

Here's an example of an all-text label you could put a spray bottle of Quat-X (a quaternary ammonium disinfectant used in many places at ASU):


QUAT-X 700 GERMICIDE SPRAY
Diluted to 0.5 oz Quat per gal water [or whatever dilution rate you use]
KEEP OUT OF REACH OF CHILDREN
EYE HAZARD - Do Not Spray in Eyes.
SKIN HAZARD - Avoid Prolonged Skin Contact.
DO NOT DRINK
Contains:

  • Didecylwhatever ammoniumchloride [no need to list the percents]
  • Butylnoodle quaternary ammonium stuffate
  • And the other "hazardous ingredients" listed on the label [list them all and spell exactly as they do]

Where in OSHA does it Require All This?

The OSHA citation is 29 CFR 1910.1200(f). Except for some exceptions that will rarely apply at ASU, "the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information:

  1. Identity of the hazardous chemical(s) contained therein; and,
  2. Appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical."

For Further Questions

Contact the Industrial Hygiene Manager.

What information must be included on the label of a container?

This label must contain two key pieces of information: the identity of the hazardous chemical(s) in the container (e.g., chemical name) and the hazards present. There are many ways to communicate this hazard information. Employers should select a system that will work for each location.

What information should be on the label of a hazardous chemical?

identity and proportion of each ingredient, as per Schedule 8 to the model WHS Regulations. signal word consistent with the hazardous chemical's classification. hazard and precautionary statements consistent with the hazardous chemical's classification, and. expiry date, if available.

What is a secondary chemical container?

A secondary container is one to which a chemical or chemical product is transferred or the container in which a new chemical product/reagent is made and stored. Immediate use containers are containers which are only expected to last one work shift and are not intended to leave the control of the person who filled them.