When chemicals are stored in a secondary container they should be labeled with?

Clear and consistent labeling that follows the Hazard Communication Standard is required in all University of Washington facilities including laboratories, shops, clinics, and other locations where employees use, store, and transport chemicals.

Chemical manufacturers are required to follow labeling requirements on the original container labels, and the downstream users of these chemicals are also required to follow labeling requirements when they transfer chemicals to secondary containers, label chemical waste, label UW-synthesized chemicals, label peroxide-forming chemicals, and label Chemicals of Interest per the Department of Homeland Security rules.

The basic requirements for labeling chemicals and templates for creating labels are discussed in the sections below.

Original manufacturer labels

The label on an original chemical container must be legible and written in English. It must include the chemical/product name as shown on the SDS and the manufacturer's name and address. Do not accept materials if the label is illegible or missing required information. (See example of original label below).

As of June 1, 2015, labels on chemicals/products shipped from the manufacturer must be consistent with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) as required by Washington Administrative Code (WAC) 296-901-140.

The WAC requires six elements on original labels (as of June 1, 2015):

1. Product name
2. Manufacturer's name and contact information
3. Signal word (e.g., "danger" or "warning")
4. Hazard statement(s) (e.g., "toxic if inhaled" or "combustible liquid")
5. GHS pictogram(s)
6. Precautionary statements (e.g., "Keep container tightly closed")

Avoid damaging the original container’s label, if possible. If a container label becomes damaged or is no longer readable, a new label must be prepared that includes the six required WAC elements to comply with GHS rules.

Read the Hazard Communication Standard for Labels and Pictograms for more information about original container label requirements.

Contact EH&S at 206.543.7388 or for assistance in preparing a replacement label.

Secondary chemical container labels

Many University workplaces, including laboratories, shops, and other facilities, purchase hazardous chemicals or products in large quantities, concentrates, or for mixing with other chemicals. To use the chemical/product it may need to be transferred to a smaller or different “secondary” container (e.g., vials, flasks or bottles) for dilution, mixing, or general use.

If you transfer a hazardous chemical into a secondary container, the secondary container must be correctly labeled to ensure workers are readily aware of the contents and understand the hazards.

The Hazard Communication Standard requires secondary chemical container labels contain at least the following information:

• Identity of the contents (spell out chemical names)
• Signal word, if known or suspected (e.g., “danger”, “warning”)
• Hazards, if known or suspected (e.g., “flammable”, “corrosive”, “irritant”)

Words, symbols, pictures, Globally Harmonized System (GHS) pictograms, or a combination thereof, which provide at least general information regarding the chemical’s physical and health hazards can be used on the secondary container label. 

It is best practice to label the working solution with the name of the person preparing the solution and the date of preparation. Information about the signal word, hazards and the precautionary statements from the label, can be obtained from the SDS, but dilutions and reactions may change the hazards and their severity.

The label can include additional information, such as the composition of chemicals and percent concentration in the container, the date the chemical was received, the date a container was opened (if the chemical could degrade or react over time), the name of the person who prepared the chemical, or any other information useful for safe and efficient use.

Employees in the workplace must be able to readily understand the chemical and hazard information on a secondary container label. Abbreviations or acronyms should not be used on the labels.

Secondary container labels are not required if both of the following apply:

1. The reagent, stock solution and chemicals mixed for use are under the direct control of the person who transferred or prepared it, and
2. The container will be emptied during that person’s work shift.

Secondary chemical container label templates

Note: New label template options A, B, C, D, replace older label template options 1, 2 and 3.

EH&S has designed four secondary chemical container label templates for your use.

Templates A and B are PDF fillable forms. Templates C and D are Word documents that show GHS pictograms.

Templates A, B and C are formatted for printing on Avery 5163 (2” x 4” label, 8 labels, 8½” x 11” page).

All templates can be resized to fit smaller containers. Links and instructions for the templates are given below.

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 SPRAYDiluted to 0.5 oz Quat per gal water [or whatever dilution rate you use]KEEP OUT OF REACH OF CHILDRENEYE 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.

When you use, store, or handle any type of hazardous chemicals on the job site you have a legal responsibility to ensure those chemicals are correctly labeled. Hazardous chemicals must be easy to identify, so staff are immediately alerted to the health and safety risks that the hazardous substances pose. This post outlines the essential steps that you can take to ensure you’re labeling and storing hazardous chemicals in the right way.

THINGS TO CONSIDER: Do you have procedures in place if a chemical label fell off a package of hazardous chemicals? How about when you decant fuel or cleaning products into portable containers? What do you do about containers that are too small for a label?

STEP 1: Chemical Labels in the Workplace

Before you can make sure a chemical is properly labeled, you need to know the requirements of the WHS Regulations. In Australia, labels on hazardous chemicals must be written in English with specific details to be included.

So, what should be included in the label and package of chemicals?

Your chemical labels must include the following:

• Product identifier
• Contact details of the manufacturer or importer
• Breakdown of the ingredients with percentages/ratios
• Hazard Pictogram
• Hazard Statement, Signal Word, Precautionary Statements
• First aid treatment and emergency procedures if not already included in the precautionary statements
• Expiry date (if applicable)

You’ll also need chemical labels and signs for any hazardous substances that are:

• Manufactured in your workplace (including research samples created in the lab)
• Transferred or decanted from the original container
• Held in a pipeline

Regardless of how small or big your container is, it needs to be properly labeled to illustrate the hazards associated with the chemical product.

Decanted or Transferred Hazardous Chemicals

If you decant or transfer hazardous substances out of their original container, you have a responsibility to ensure that the secondary or portable container features the correct chemical labels.

Many workplace accidents have occurred when staff have decanted cleaning chemicals into soft drink bottles or plastic cups — then mistakenly consumed by a co-worker or customer.

As a minimum, the secondary container holding a decanted chemical must display both:

• The product name/identifier; and
• A pictogram or hazard statement that identifies the hazard class of the chemical.

NOTE: The decanted hazardous chemicals do not require labeling if the entire amount is immediately used by the person who decanted it. However, it must only be used by that person and the chemical container must never be left unattended. When transferring hazardous substances, make sure that the container is cleaned thoroughly before use. Even the smallest traces of hazardous chemicals in seemingly ‘empty containers’ can lead to a hazard.

Small Containers

Sometimes, chemicals are stored or transferred into containers or ampoules which are so small that a label won’t fit. However, keep in mind that even the tinniest of containers still require the same amount of information as any other hazardous chemical container.

You may choose to keep very small ampoules in a box, attaching the label to the outside of the box or keeping a leaflet inside. Swing tags can also be attached to some small containers.

REMEMBER: The Code of Practice (by Safe Work Australia) for the Labelling of Workplace Hazardous Chemicals displays label templates for small containers.

Additional Chemical Labeling Requirements

In addition to the chemical labelling requirements, there are also further chemical labeling requirements for hazardous substances.

These chemical labeling requirements include:

• Waste products - if it is reasonably likely that a waste product is a hazardous substance, then it must be labeled with as much information as possible including pictogram, hazard class and precautionary statements.
• Pipework – pipework for hazardous chemicals must be colour-coded, with compliant signs and placards erected nearby. The pipework must be clearly marked on schematic drawings or site plans.
• Research chemicals – chemicals created in the lab for analysis must be labeled with as much information as possible including the chemical properties, ingredient mix and likely hazards.

REMEMBER: When dealing with complex chemical mixtures, such as in a laboratory setting, the identity of all hazardous substances must be determined so far as it’s reasonably practicable to do so. Ingredient and formulation information for these hazardous substance mixtures must include chemical families or sub-families, where possible.

STEP 2: Receiving Hazardous Chemicals

Having an excellent relationship with your suppliers, as well as understanding your supply chain, is a critical aspect of chemical safety.

Once you’re fully conversant with chemical labeling requirements, you should train your staff to only accept chemical deliveries if they have the correct label and Safety Data Sheet.

TIP: Apart from incorrectly labeled chemicals, don’t accept deliveries of chemical packages that are damaged or have broken seals. Reject gas bottles with worn label plates or outside their test date.

STEP 3: Storing Chemicals Safely

When they aren’t being used, it’s very important to ensure that your labeled chemicals are stored in a safe and efficient manner.

Being storage experts, the team here at STOREMASTA have a few quick recommendations:

• Create dedicated chemical stores for different hazard classes using purpose-built safety cabinets. For example: cabinets for compressed gases, corrosives, and detonators arrive with the correct placards, labels and signs.
• Have convenient under-bench cabinets available for smaller quantities of lab chemicals like acid. This dissuades staff from leaving chemicals on the floor, bench tops, window ledges, or balconies.
• Keep flammable liquids, corrosives and toxic chemicals in dedicated cabinets that are fitted with perforated shelving and a liquid-tight spill sump.
• Have correctly labeled spill kits on hand and train staff how to use them.
• Keep hard copies of Safety Data Sheets attached to chemical cabinets in a robust document box. Again, properly marked and labeled

One of the best ways to minimise risk when carrying hazardous chemicals, is to have consistent housekeeping practices. These practices will include such tasks as keeping packages stacked neatly, wiping down containers after use to remove residue, and ensuring that no chemicals are being stored in the spill sump of your indoor safety cabinet.

Housekeeping and maintenance of your chemical storage areas is not just a good idea, it’s a requirement under Australian WHS laws.

It’s also crucial to train your staff to put chemical containers away when they aren’t being used. If containers are left lying around a worksite, there is a high likelihood that a hazard will occur due to the lack of protection for the hazardous substance. Make sure your staff are trained to understand how to use their storage equipment, as well as the hazards that are being controlled when the chemicals are stored correctly.

STEP 4: Site Audits and Corrective Actions

Once you have everything in place, conduct regular site audits that note incorrect labels and missing placards.

Take corrective action after every audit, and make sure those labels are placed on the appropriate containers and all missing or damaged placards are replaced.

Regular inspections at your workplace will help you ensure that labels and storage procedures are being upheld by staff members.

Why is it Important to Label Chemicals in the Workplace?

Checking your chemical stores for correct container labeling and safety compliance auditing is an essential part of chemical risk management. It’s also an essential part of maintaining health and safety in your workplace. To learn more about how to fully comply with WHS Regulations and chemical safety standards through the implementation and maintenance of safe storage, why not access our eBook? The Ultimate DG Storage Handbook will walk you through all the important questions you’ll need to ask if you’re storing hazardous chemicals and dangerous goods in your workplace.