Types of Containers and Labels
Container labeling can be a very effective method to communicate the physical and health hazards of chemicals used in the workplace. The information on a container label will vary depending on what type of container it is and how it is used. We will discuss labeling requirements under the HCS 2012 labeling requirements in this section.
We’ll look at the labeling requirements for each of the four types of containers listed below:
- Shipped/primary containers
- Workplace/secondary container
- Stationary containers
- Portable containers
Shipped ‐ Primary Container Label Requirements
Under the new HCS 2012, labels on containers shipped from manufacturers or distributors must be labeled, tagged or marked with the following six items:
1. Product Identifier – This should include the chemical identity of the substance.
2. Signal Word ‐ Signal words used in GHS are “Danger” and “Warning.” Danger is for the more severe hazard categories.
3. Hazard Statements ‐ This is a phrase assigned to a hazard class and category that describes the nature of the hazards of a hazardous product, and the degree of the hazard.
4. Pictograms ‐ These include symbols plus other elements, such as a border, background pattern or color that conveys specific information.
5. Precautionary Statements ‐ These are phrases (and/or pictograms) that describe the recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous product.
6. Supplier Identification – Includes the name, address and telephone number of the manufacturer or supplier of the substance or mixture.
Workplace or Secondary Container Labeling
Most employers use the primary containersthey purchase to store and use chemicals.
However, they may also use their own containers such as coffee cans, drums, plastic jugs, spray bottles, etc. to store and use smaller quantities of chemicals they purchase. These are called workplace or secondary containers.
Make sure your secondary containers are properly labeled, not only to protect employees, but to avoid OSHA citations. One of the most frequent citations related to HCS 2012 is “improperly labeled secondary containers.” OSHA sees this all the time, and whatever OSHA sees the most, they cite the most: Remember that.
The employer must ensure that each workplace or secondary container of hazardous chemicals the workplace is labeled, tagged or marked with either:
- The information required on shipped container labels; or,
- Product identifier and words, pictures, symbols, or combination thereof, which provide at
least general information regarding the hazards of the chemicals, and specific information regarding the physical and health hazards of the hazardous chemical.
Portable Container Labeling
It is important to know that portable containers must be under the positive control of the employee using it. If the employee walks away from the container and loses control of the chemical, it must be labeled as a workplace/secondary container.
Portable containers are used to transfer hazardous chemicals from labeled containers, and are intended only for the immediate use of the employee who performs the transfer. The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer.
Drugs which are dispensed by a pharmacy to a health care provider for direct administration to a patient are exempted from labeling.
Labeling Solid Materials
For solid metal (such as a steel beam or a metal casting), solid wood, or plastic items that are not exempted as articles due to their downstream use, or shipments of whole grain, the required label may be transmitted to the customer at the time of the initial shipment, and need not be included with subsequent shipments to the same employer unless the information on the label changes.
For example, treated lumber is covered since the lumber is not completely cured at the time of shipment and the hazardous chemical will, to a varying degree, offgas during shipment and be available for exposure to employees. Railroad ties treated with creosote should have an accompanying safety data sheet (SDS) when shipped.
HCS 2012 Pictogram Requirements
The HCS 2012 requires GHS pictograms on labels to alert users of the chemical hazards to which they may be exposed. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s). The pictogram on the label is determined by the chemical hazard classification.
While the GHS uses a total of nine pictograms, OSHA will only enforce the use of eight. The environmental pictogram is not mandatory but may be used to provide additional information. Workers may see the ninth symbol on a label because label preparers may choose to add the environment pictogram as supplementary information