Do you have GHS secondary container confusion? A secondary container by definition is defined as any container being used beyond the original manufacturer’s bottle that the chemical was shipped in. This may include, but is not limited to: portable or working containers, such as spray bottles, jugs, jars, flasks, beakers or small storage bottles in immediate use.
Secondary container labels are required when transferring chemicals from the original container into a secondary container. Secondary containers must comply with the labeling requirements if any of the following events occur:
-Does not meet Permanent Container requirements
-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
When a secondary container is used for longer than one shift or does not meet the Permanent Container requirements outlined, a label needs to be applied to the secondary container. This label must contain two key pieces of information:
-The identity of the hazardous chemical(s) in the container (i.e. Product Name)
-The hazards present
There are many ways to communicate this hazard information. Employers should select a system that will work for each location.
Secondary containers are not required to be labeled when the following criteria are met:
-The material is used within the work shift of the individual who makes the transfer
-The worker who made the transfer is in the work area the entire time during use
-The container stays in within the work area and in the possession of the worker who filled the container
OSHA has not changed the general requirements for secondary container labeling specifically. Employers have the option to create their own workplace labels by using all of the information provided by the manufacturer or using a combination of the elements. When it comes to the designs, OSHA states: “If the employer chooses to use the pictograms that appear in Appendix C on the workplace (or in-plant) labels, these pictograms may have a black border, rather than a red border” If the label is pre-printed with diamonds, the diamond may be colored in: however, the red cannot be visible. An “x” or other symbol through the diamond is not permitted. Employers may continue to use rating systems such as the National Fire Protection Association (NFPA) or Hazardous Materials Identification System (HMIS) requirements for workplace labels, as long as they are consistent with the HazCom 2012 / GHS Standard.
Tags: GHS, National Marker Company, NMC, Secondary Labels