Labeling secondary containers
Date Posted: 02/03/2019
If an employee transfers a cleaning solvent from its original container into a smaller, secondary container does it have to be labeled? What if that same employee leaves the secondary container and starts working in a different area, no longer controlling the container during his or her shift, and does not return to use up the product or empty the container?
The hazard communication ("HazCom") standard at 1910.1200(f)(8) says, in part, "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." If the chemical is used in the same shift by the same person, you are not required to label the secondary container.
In the second instance, in which the container is left unattended and may be used by an employee on another shift, the container does need to be labeled because it does not fall under the "immediate use of the employee who performs the transfer."
What kind of labeling is needed?
If the chemical is going to be used only "in house," then the container is to be labeled in accordance with 1910.1200(f)(6). Label it with the product identifier, words, pictures, symbols, or a combination thereof.
You can use HMIS or NFPA labels, or your own system, for in-house container labels as stated in 1910.1200(f)(7).
It is not a requirement that a label show the hazard statements, precautionary statements, or first aid information on the label as stated in 1910.1200(f)(6).
How does the HazCom standard define "hazardous chemical"?
1910.1200(c) gives the definition of hazardous chemical as "any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified."
Health hazard, according to the regulations, means a chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard.
Physical hazard is defined as a chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid, or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits flammable gas.
The HazCom standard at 1910.1200(b)(1) requires chemical manufacturers or importers to classify the hazards of chemicals which they produce or import.
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