Labeling secondary containers for in-house use

For ease of use in the work area, an employee transfers a chemical from a larger, labeled container into a smaller one. Does OSHA’s Hazard Communication (HazCom) Standard require a label on the secondary container?

It depends

HazCom says, in part, “the employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer.”

“Immediate use” means that “the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred.”

If the situation is such that the definition of immediate use is met, no HazCom label is needed. If this isn’t the case – maybe the employee leaves work for the day and there’s chemical left in the secondary container, or another employee asks to use that container – it must be labeled.

Quality control samples taken in a plant must be labeled, tagged, or marked unless the person taking the sample is also going to perform the analysis, as the sample would then fall under the “immediate use” exemption.

What information must be on the label?

HazCom allows two workplace labeling options. The label can contain:

• The elements required on shipped containers of hazardous chemicals, with the exception of contact information: product identifier, signal word, hazard statement(s), pictogram(s), and precautionary statement(s), or
• The product identifier and words, pictures, symbols, or a combination of these, which provide at least general information regarding the hazards of the chemicals. This option includes the use of NFPA or HMIS labels.

The label on the shipped container of a hazardous chemical and/or Section 2 of the Safety Data Sheet (SDS) can help you determine what information to put on a secondary label. As you create a label, keep in mind that its purpose under HazCom is to serve as an immediate visual warning of the chemical’s hazards. The product identifier allows employees to locate the accompanying SDS for more detailed information.

Regardless of the labeling option you use for secondary containers, you must ensure that your training program instructs employees on how to use and understand the labeling system.

Additionally, workplace labels and other forms of warning must be:

• Legible,
• In English (other languages may be added to aid in employee comprehension), and
• Prominently displayed on the container, or readily available in the work area throughout each work shift.

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