Portable Sanitation Association International

ASSOCIATIONINSIGHT Portable Sanitation Association International News BIWEEKLY EDITION JANUARY 6, 2021 Page 10 Chemical Labeling Dos and Don'ts Continued on page 11 Buying service route supplies in bulk can save money. Yet if you do it, sooner or later your team will be faced with the need to reduce the bulk-sized items into something smaller that can be carried on each route truck. With toilet paper this is easy. But with chemicals and cleaners, it is not. Apart from the mess and the hassle, you must also be cognizant of the labeling requirements for substances that are transferred 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. Know Your Label Lingo 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 hazardous 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] attached 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." (italics added for emphasis) These labeling requirements 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. When Is a Secondary Label Needed? The PSAI recently received a question from an operator wondering whether it was even necessary to label chemicals if the bottles are clear and it is obvious what is in them. The answer depends on two things: • whether the person who transfers the chemical from the large, manufacturer-labeled container to the smaller container is also the person who uses the chemicals AND • whether the smaller containers are completely used—or emptied—at the end of each shift. If the answer to both of the bullets above is "yes" then no label is needed. Most commonly the above criteria are met in laboratories. They would hardly ever apply to portable sanitation. If the answer to either bullets above is "no"—as they likely would be for portable sanitation—then you must put a secondary label on every container you use. The secondary label must include at a minimum: 1. the identity of the hazardous chemical(s) in the container (e.g., chemical name) AND 2. the hazards present. Labels for a hazardous chemical must contain: • Name, Address, and Telephone Number • Product Identifier • Signal Word • Hazard Statement(s) • Precautionary Statement(s) • Pictogram(s)

• Cover