This material is for training purposes only to inform the reader of occupational safety and health best practices and general compliance requirements and is not a substitute for provisions of the OSH Act of 1970 or any governmental regulatory agency.
 MODULE 3: CHEMICAL CONTAINER LABELING
Types of Containers
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'll discuss the various labeling requirements in this module.
We'll take a look at the labeling requirements for each of the four types of containers referred to in the hazard communication standard:
- Primary containers
- Secondary containers
- Stationary containers
- Portable containers
Primary container labeling
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The chemical manufacturer, importer, or distributor must ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following three elements of information:
- Identity of the hazardous chemical(s);
- Appropriate hazard warnings, including target organ effects of the hazardous chemical; and
- Name and address of the chemical manufacturer, importer, or other responsible party.
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Most containers you receive directly from the manufacturer or purchase from a distributor are called primary containers. Labeling with the above information on these containers is usually adequate in communicating the hazards of the chemical.
The label is intended to be an immediate visual reminder of the hazards of a chemical. It is not necessary, however, that every hazard presented by a chemical be listed on the label. The Material Safety Data Sheet (MSDS) is used for this purpose. Manufacturers, importers, and distributors will have to assess the evidence regarding the product's hazards and must consider exposures under normal conditions of use or in foreseeable emergencies when evaluating what hazards are listed on the label. This is not to say that only acute hazards are to be listed on the label, or that well-substantiated hazards should be left off the label because they appear on the data sheet.
It's important to understand that the hazard warning must convey the particular physical and health hazards of the chemical, including target organ effects. Employees exposed to health hazards must be apprised of both changes in body functions and the signs and symptoms that may occur to signal those changes. Statements such as "Hazardous if Inhaled," "Caution," "Danger," are precautionary statements and are not to be considered appropriate hazard warnings. If, when inhaled, a chemical causes lung damage, then the appropriate warning is "lung damage," not inhalation.
A label may not be shipped separately, even prior to shipment of the hazardous chemical, since to do so defeats the purpose of providing an immediate hazard warning. Mailing labels directly to purchasers by-passes employees involved in transporting and handling the hazardous chemical.
Labeling solid materials
Remember, in an early module we said the hazardous chemicals under the HAZCOM program include solids. 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;
The label may be transmitted with the initial shipment itself, or with the material safety data
sheet that is to be provided prior to or at the time of the first shipment. This exception to requiring labels on every container of hazardous chemicals is only for the solid material itself, and does not apply to hazardous chemicals used in conjunction with, or known to be present with, the material and to which employees handling the items in transit may be exposed (for example, cutting fluids or pesticides in grains). 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.
If the hazardous chemical is regulated by OSHA in a substance-specific health standard, the chemical manufacturer, importer, distributor or employer must ensure that the labels or other forms of warning used are in accordance with the requirements of that standard.
Secondary container labeling
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Most employers use the primary containers they 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 secondary containers. |
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Generally, your employer must make sure that each secondary container of hazardous chemicals in the workplace is labeled, tagged or marked with at least the following information:
- Identity of the hazardous chemical(s) contained therein; and,
- Appropriate hazard warnings, or words, pictures, and/or symbols which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information (an MSDS) will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.
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Alternative labeling methods
Here are two examples of alternative labeling systems. The hazard communication standard recognizes the use of alternative in-plant labeling systems such as the HMIS (Hazardous Materials Information System), NFPA (National Fire Protection
Association), and others which may be used in industry. These alternative systems use color, numbers and other information to convey the hazards of the chemical.
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These systems rely on
numerical and/or alphabetic codes to convey hazards and are generally non-specific.
OSHA has permitted these types of in-plant labeling systems to be used when an
employer's overall HCS program is proven to be effective despite the potential absence
of target organ information on container labels. Under these circumstances, the
employer should assure - through more intensified training - that its employees are fully
aware of the hazards of the chemicals used. Additionally, employers must ensure that
their training program instructs employees on how to use and understand the alternative
labeling systems so that employees are aware of the effects (including target organ
effects) of the hazardous chemicals to which they are potentially exposed. If you use alternative labeling systems, OSHA inspectors will determine whether workers can recognize what hazards correspond to what code ratings/symbols. This can be achieved through employee interviews.
Employers using alternative labeling systems must ensure that their employees are
aware of all information required to be conveyed under the HCS. OSHA will make a
plant-specific determination of the effectiveness of the complete program when an
inspection is conducted. Any employer who relies on one of these types of alternative
labeling systems, instead of using labels containing complete health effects information
will - in any enforcement action alleging the inadequacy of the labeling system - bear the
burden of establishing that it has achieved a level of employee awareness which equals
or exceeds that which would have been achieved if the employer had used labels
containing complete health effects information (59 F.R. 6156).
The key to evaluating the effectiveness of any alternative labeling method is to
determine whether employees can correlate the visual warning on the in-plant container
with the applicable chemical and its appropriate hazard warnings. The alternative
labeling system must also be readily accessible to all employees in their work area
throughout each work shift. For purposes of this provision, the term "other such written
materials" does not include material safety data sheets used in lieu of labels.
Stationary process container labeling
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Stationary process containers are...well...stationary! Storage tanks are good examples. The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required on secondary containers. The written materials must be readily accessible to the employees in their work area throughout each work shift. |
Portable container labeling
| 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. 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. |
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Figure this out...
It's important to know that portable containers must be under the positive control of the employee using it. Let's say an employee is cleaning some parts with solvent he has placed in a coffee can. As long as he is using it for immediate use and can prevent another employee from exposure, labeling is not required. However, if he walks away from the workstation to go on a break (or for any reason), losing control of the chemical, the status of the container changes.
Other important labeling requirements
Labels are useless unless they accurately communicate the hazards of their associated chemicals. It's important to keep labels in good condition at all times. The employer must not remove or deface existing labels on incoming containers of hazardous
chemicals, unless the container is immediately marked with the required information.
The employer must ensure that labels or other forms of warning are:
- legible, in English,
- prominently displayed on the container, or
- readily available in the work area throughout each work shift
Employers having employees who speak other languages may add the information in their language to the material presented, as long as the information is presented in English as well.
Well, there you have it....well most of it. Be sure to review the standard for more information all the labeling requirements. Now it's time to take the module quiz. If you can't answer a question, just scroll back up and review the related material.
Take the Review Quiz
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