Chemicals do not always stay in their original containers. Workers pour them into smaller bottles, tanks and buckets, and mix them in the process. This lesson explains how those containers are labeled.
The employer's duty
1910.1200(f)(6) says the employer must make sure that each container of hazardous chemicals in the workplace is labeled, tagged or marked. There are two ways to do this:
- put on the same label information as the supplier's label (the six elements), or
- use a workplace label: the product identifier plus words, pictures, symbols or a combination that give the general hazards of the chemical. Together with the other information that is immediately available to employees (such as the written program and the SDS), this must let you know the specific physical and health hazards.
Workplace labels must be legible, in English and prominently displayed on the container or readily available in the work area throughout each shift. The employer may add other languages if workers need them.
NFPA 704 and HMIS
Many workplaces use systems such as NFPA 704 (a diamond with four colored squares and numbers) or HMIS (colored bars with numbers). The standard allows them as workplace labels if the employer's program makes sure workers understand them and if they together with the SDS give the specific hazards.
Be careful: in these systems 4 is the most severe rating. In the GHS, Category 1 is the most severe. Never compare the numbers across the two systems. These rating systems are also not GHS labels, and you cannot use them in place of a supplier's label on a shipped container.
Containers that need no label
A portable container filled from a labeled container for the immediate use of the employee who makes the transfer does not need a label. "Immediate use" means the chemical stays under that person's control and is used up during that shift.
If you pour a solvent into a bucket, put it on a shared bench and go home, the bucket needs a label. When in doubt, label it.
Other forms of warning
For stationary process containers such as tanks, vessels and pipe systems in a plant, the employer may use signs, placards, process sheets, batch tickets, operating procedures or other written materials in place of a label on each container. They are acceptable only if they identify the containers they apply to and give the same information, and employees can easily get it.
Unlabeled pipes
The written program must say how workers are informed about the hazards of chemicals in unlabeled pipes in their work area. If you must work on a pipe and do not know what it holds, stop and ask before you open it.
Labels you may not remove
Do not remove or deface a label on an incoming container unless the container is immediately re-marked with the required information. A container whose label has peeled off should be taken out of use and reported.
What if there is no label?
An unlabeled container is a hazard in itself. You cannot tell whether it holds water or acid.
- Do not use it, smell it or taste it.
- Keep other people away.
- Tell your supervisor, who will find out what it is.
Never use food containers
Never put chemicals in drink bottles, cups or food containers. A person who sees a soda bottle will drink from it. Poisonings happen this way every year.
What to remember
- Every container needs a label, except a portable one for immediate use by the person who filled it.
- A workplace label has the product identifier and general hazard information, and the SDS gives the specifics.
- NFPA and HMIS numbers are not GHS categories.
- Never use an unlabeled container, and never use food containers for chemicals.