W EEKLY EDITION MAY 1, 2019
C hemical L abeling Dos and Don't s
When You Use Your Own Labels, Make Sure They Are OSHA - Compliant
By Karleen Kos, PSAI Executive Director
Apart from the mess and the hassle, you must also be cognizant of the labeling requirements for substances
that are transferre d out of their original, manufacturer - labeled containers. Here is the top line on what you
need to know to keep your workers safe and to comply with Occupational Safety and Health Administration
(OSHA) regulations with your in - house labels.
K n o w yo u r l ab e l l i n go . According to
OSHA's 1994 Hazard Communication
Standard (HCS) the term "label" means any
written, printed, or graphic material
displayed on or affixed to containers of
hazard ous chemicals.
That part might seem obvious. It's in the
Agency's 2015 Instruction on Inspection
Procedures for the HCS for enforcement
they clarify that a label,
"[Must be] at tached to the immediate
container of a hazardous chemical, or to the outside
packaging. [… a] label on each container [is required] and, therefore, labeling only the outside package is not
compliant." (underline added for emphasis)
These labeling require ments represent the minimum standards for manufacturers of chemicals.
When you buy chemicals in bulk, you will find a label on each of the barrels, jugs, or bottles sent by the
manufacturer. Once you transfer some of the chemical into a smaller container , the requirements for
secondary labeling kick in. A "secondary label" is any label that has not been printed by the manufacturer
and placed on the original packaging.
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