HAZCOM – Labeling Secondary Containers
Date Posted: 01/30/2024
According to the Division of Occupational Safety and Health (DOSH), chemicals in secondary containers must be labeled with at least general information regarding the hazards of the chemicals, which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.
What is the Difference Between Primary and Secondary Containers?
Primary containers come straight from the manufacturer. They come in drums, tubs, pails, bottles, or other larger canisters that are pre-labeled with the chemical identifier. The "primary container" labels are required to include the manufacturer’s information.
Once you have transferred a chemical from its original container (in which it arrived from the supplier) to a new one, that container is considered secondary. Secondary chemical containers should follow the same GHS chemical container label guidelines as primary containers, with a few exceptions.
When is a Secondary Container Label Required?
According to WAC 296-901-14012, "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. For purposes of this section, drugs which are dispensed by a pharmacy to a health care provider for direct administration to a patient are exempted from labeling." Secondary containers are required to be labeled with a GHS chemical label, given if any of the following events occur:
The material is not used within the work shift of the individual who makes the transfer.
The worker who made the transfer leaves the work area.
The container is moved to another work area and is no longer in the possession of the worker who filled the container.
Labels on portable containers are not required if the worker who made the chemical transfer uses all of the contents during the work shift.
Why is it Important to Label Secondary Containers?
Incidents, injuries, and illnesses can occur if a worker uses a chemical without understanding the hazards of that chemical. The common causes of incidents or health effects that can be traced back to secondary container labels include:
The material not being used within the same work shift as the person who made the transfer from the primary to the secondary container.
The person who oversaw the transfer leaving the work area.
The secondary container itself leaves the work area to a location where it cannot be correctly identified.
What Information is Required for Secondary Containers?
Product Name/Identifier: This should match the product identifier on the safety data sheet.
General Hazard Statement: This can be communicated with words, pictures, symbols, or any combination that provides at least general physical and health hazards associated with the chemical.
Resources
Chapter 296-901 WAC - Globally Harmonized System for Hazard Communication
Hazard Communication Standard (HCS) Update (osha.gov)
