Labeling Secondary Containers: OSHA Requirements You Need to Know
A properly labeled container is a safe container. One of the last things you want to ask when you’re working with hazardous materials is “What’s in that container?” To avoid this problem, The Occupational Safety and Health Administration (OSHA) has strict regulations on the containers used to store and transport chemicals at worksites.
If you already package chemicals, or other manufacturing supplies, offering secondary containers is a great way to add a new revenue stream. This lets customers order locally-used containers alongside supplies and bulk chemicals. When is this labeling required, and how can you make sure your containers conform to regulations?
What is a Secondary Container?
Secondary containers are used to hold hazardous chemicals or products, but are not issued and filled by the manufacturer (ex. a large fuel tank on site that is used to fill fuel cans). While you can easily buy OSHA-certified fuel cans, other chemicals need their own labels. Sometimes, a secondary container is called a portable container or workplace container.
Secondary labeling covers containers, but not equipment. Let’s say you have a barrel of solvent for parts cleaning. If that solvent is transferred directly from its original container to a parts washer, you don’t need any additional labeling. However, if an employee needs to put the solvent in a container and carry it to the parts washer, that transfer container needs a label. That way, if the container is no longer in the worker’s possession, its contents can be identified
Like primary containers, portable containers must meet most Globally Harmonized System of Classification and Labeling of Chemicals (GHS) requirements, as well as the OSHA Hazardous Container Standard (HCS). This includes label elements already used on bulk container labels, like standard pictograms and product identifiers. If you want to know more about GHS label requirements, read our blog entry on the subject.
Specific regulations on workplace container labels are covered by HazCom standard 1910.1200(f)(6)(ii.) In general, this regulation is a little less strict than primary container regulations. Some information required on a primary container can be left on the Safety Data Sheets (SDSs), as long as the SDS is readily available to employees.
The sheets for every chemical used at the workplace should be in a binder on the shop floor, not in a locked office. This way, hazard information (including health hazards) is readily available if employees need to deal with spills or chemical exposure in the work area.
OSHA requires this information on workplace container labels:
– Name of the product
– National Fire Protection Association (NFPA) diamond
– GHS health and physical hazard pictograms
This specific information must be available in the SDS, but isn’t required for the label:
– The manufacturer’s name and address
– Precautionary statements
– Hazard statements
Naturally, the container should only be used for the product on the label, both to follow labeling regulations and for safety.
OSHA directive CPL 02-02-079, Inspection Procedures for the Hazard Communication Standard (HCS 2012), states that employers who use alternative labeling for secondary chemical containers are still held accountable for ensuring employee hazard awareness. In other words, they should have training in handling chemicals that are used during the work shift, as well as have access to the required information.
There are three exceptions to secondary labeling requirements:
– The container size makes it impractical to include the label information.
– The chemicals are produced at the workplace and are only used on-site.
– The chemicals are for immediate use by the person who transfers the material to the secondary container. To meet this qualification, the chemicals cannot be stored long term in the container or used by another employee.
Secondary label regulations only apply to containers used inside the facility. If you’re repackaging bulk products for sale, these new containers need to meet all OSHA requirements for primary containers.
Creating Labels that Meet Both United States and Canadian Labeling Requirements
In Canada, chemical labeling requirements are covered by WHMIS 2015, under the authority of the Canadian Centre for Occupational Health and Safety (CCOHS). While not identical to OSHA requirements, there are enough similarities between CCOHS and OSHA regulations that it is possible to make labels compatible with both standards. While each set of standards has requirements, you can add more information as needed.
Here’s what the label needs to include in order to meet WHMIS 2015:
– The product name, which must be written exactly as it is on the SDS
– Safe handling precautions using either pictograms or text and graphics that are identical to those used by the supplier on the primary container.
– A reference to the SDS, making it easy for employees to get required information.
Under WHMIS 2015, there are three exceptions for labeling portable containers:
– Products that are sold in bulk or without packaging do not need to meet secondary labeling requirements. Like OSHA standards, these chemicals fall under bulk or primary container regulations.
– Containers up to 100 mL may exempt hazard statements.
– Containers up to 3mL where the label would hinder normal use only require shipping and storage information.
Other Considerations for Secondary Container Labels
OSHA requirements cover the entire life of the container, so it’s important to use labels that can withstand the workplace environment, including repeated handling, corrosion, and environmental exposure. For most uses, that means choosing plastic labels or paper labels with a heavy coating to protect against moisture and UV light exposure.
If you need more flexibility to cover a variety of products, consider one of our print-and-apply applicators. These labelers have print engines that add black text and graphics to labels, letting you use a stock design and add relevant information about the specific product. When you select your labels, you need a coating that absorbs ink, but still delivers adequate environmental resistance. Direct thermal paper is a poor choice for these labels, since the paper naturally darkens over time.
We Can Help You Add Labels to Bring Your Containers Into Compliance
No matter what you’re labeling, CTM Labeling Systems has the machines needed for accurate, reliable placement. Contact us and we’ll get to work creating a labeling system that fits your production environment. We offer machines that work with almost any type of packaging, from cans and shipping boxes to spray bottles and chemical containers. See what we can do for you!