Secondary Container Labels
Chemicals get poured out of their original drums and bottles into spray bottles, buckets, squeeze bottles, gas cans and sprayers. If those containers aren't labeled, the next person has no idea what's inside, how it can hurt them, or what to do after a splash. Unlabeled bottles cause poisonings, burns, fires and dangerous mixing.
- Janitors & Cleaners
- Maintenance Techs
- Painters
- Mechanics
- Farm & Landscape Workers
What the rule says
OSHA's Hazard Communication Standard (29 CFR 1910.1200, and the construction standard that adopts it) requires that hazardous chemical containers in the workplace be labeled. When you transfer a hazardous chemical to another container, the new container generally needs a workplace label with:
- the product identifier (the name on the original label and safety data sheet), and
- words, pictures, symbols or a combination that, with the other information at the workplace, give workers specific information about the chemical's physical and health hazards.
Employers can copy the full manufacturer label, or use their own system, such as the NFPA 704 diamond or HMIS colors, as long as it gives the product identifier and the hazard information consistently. See Hazard Communication and Safety Data Sheets.
The immediate-use exception
A portable container filled from a labeled container does not need a label if it is intended only for the immediate use of the employee who made the transfer. “Immediate use” means the chemical is under that worker's control and used by them during the work shift in which it was transferred.
- If the container is left behind, handed to someone else, stored, or used past the shift, it needs a label.
- When in doubt, label it. A label takes seconds.
- Company policy may be stricter than OSHA and require labels on all secondary containers.
Common problems
- Food and drink containers: soda bottles, cups and jugs are mistaken for beverages. Never store chemicals in them, even labeled.
- Handwritten labels that fade or smudge, or abbreviations only the writer understands.
- Mixing chemicals in one bottle, such as bleach with ammonia or acids, which can release toxic gas. See Chlorine and Chemical Storage.
- Diluted products: the diluted mix may still be hazardous. Label the diluted container with the product and dilution.
- Reusing containers that held something else. Old residues can react.
- Gas cans and sprayers that need approved, labeled containers. See Flammable Liquids.
Good practice
- Use the right container: compatible material, tight cap, designed for the product. Spray bottles for strong chemicals should be chemical-resistant.
- Use pre-printed labels from your supplier or employer, or print durable labels with the product name and hazard pictograms and signal word where used.
- Put the label on every time you fill, before you put the cap on.
- Add the date or batch for mixed products and keep the SDS available.
- Wear the PPE the SDS requires when pouring, and use funnels and drip pans. See Chemical-Protective Clothing.
- Empty and dispose of old containers correctly. See Hazardous Waste Disposal.
If you find an unlabeled container
- Don't sniff, taste or touch it. Don't pour it down a drain.
- Tell your supervisor and keep others away. Treat it as hazardous until identified.
- If someone has been exposed, rinse and get medical help, and call Poison Control at 1-800-222-1222 in the U.S. See Chemical Exposure First Aid.
- Identify the contents through safe methods set by your employer, such as checking where it came from, and dispose of it properly if the contents can't be identified.
Secondary container checklist
- The container is made for the chemical and is not a food or drink container
- It has a label with the product name and hazard information
- Handwritten labels are legible and use names others understand
- I know the immediate-use exception and when it ends
- I never mix chemicals in one container, and I have the SDS handy
Standards & references
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