Issue link: http://psai.uberflip.com/i/1414964
14 I PSAI Association Insight, September 29, 2021 When You Use Your Own Labels, Make Sure They Are OSHA-Compliant 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 CHEMICAL LABELING DOS AND DON'TS "[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." 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 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. (continued on page 15)