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HazCom labels for secondary containers

ยท 2 min read

A chemical arrives with the manufacturer's label on it. Then someone pours some into a spray bottle, a bucket or a smaller jug, and that new container has no label at all. OSHA's Hazard Communication Standard (HazCom), 29 CFR 1910.1200, covers exactly this case.

What a workplace label needs

Under 1910.1200(f)(6), each container of a hazardous chemical in the workplace must be labeled, tagged or marked with either:

  • The same information as the shipped container's label: product identifier, signal word, hazard statements, pictograms, precautionary statements and the name, address and phone number of the manufacturer, importer or responsible party; or
  • The product identifier plus words, pictures, symbols or a combination of them that give at least general information about the chemical's hazards, which together with the other information employees can get through your HazCom program (such as the safety data sheet) tell them the specific physical and health hazards.

The second option is what most secondary labels use. The product identifier should match the name on the safety data sheet, so anyone can look it up. HazCom has a narrow exception for a portable container that the person who filled it uses immediately, but anything left on a shelf, passed to another worker or kept past the shift needs a label.

A corrosive cleanerCustomize โ†’
Gas under pressureCustomize โ†’
With hazard statementsCustomize โ†’

The pictograms

HazCom uses the pictograms of the Globally Harmonized System (GHS): a black symbol on a white background inside a red diamond. There are nine:

  • Health hazard: carcinogens, reproductive toxicity, respiratory sensitizers, target organ toxicity, aspiration hazards.
  • Flame: flammable gases, liquids and solids, pyrophorics, self-heating and self-reactive substances, organic peroxides.
  • Exclamation mark: irritants, skin sensitizers, acute toxicity (harmful), narcotic effects.
  • Gas cylinder: gases under pressure.
  • Corrosion: skin burns, serious eye damage, corrosive to metals.
  • Exploding bomb: explosives, some self-reactives and organic peroxides.
  • Flame over circle: oxidizers.
  • Skull and crossbones: acute toxicity that can be fatal or toxic.
  • Environment: aquatic toxicity. This one is part of GHS but not required by OSHA, which does not regulate environmental hazards.

Copy the pictograms and signal word from the product's safety data sheet or original label rather than guessing. DANGER is for the more severe hazards and WARNING for the less severe; a label carries only one.

Languages

Workplace labels must be legible, in English, and prominently displayed, or the information must be readily available in the work area throughout each shift. Under 1910.1200(f)(10), employers with employees who speak other languages may add the information in those languages, as long as it is presented in English as well. The label builder has a field for a second signal word, so DANGER can read DANGER / PELIGRO, and you can write the hazard statements in both languages.

Making a label

The HazCom label builder draws a 6 by 4 inch label (or 4 by 6 portrait) with the product name large at the top, the signal word, up to four pictograms, hazard and precautionary statements and an optional supplier line. For a bottle that lives in a wet sink area, print on waterproof label stock or laminate it.

If the same chemical needs a door or storage-area sign as well, an NFPA 704 diamond or a DANGER sign with a GHS pictogram does that job. For more on second languages, see bilingual safety signs.