Workplace or Secondary Container Labeling

How to Know When You Need GHS Labels for Secondary Containers

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 workplace or secondary containers.

Make sure your secondary containers are properly labeled, not only to protect employees, but to avoid OSHA citations. One of the most frequent citations related to HCS 2012 is “improperly labeled secondary containers.” OSHA sees this all of the time, and whatever OSHA sees the most, they cite the most. Remember that.

The employer must ensure that each workplace or secondary container of hazardous chemicals in the workplace is labeled, tagged or marked with either:

  • The information required on shipped container labels; or,
  • Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and specific information regarding the physical and health hazards of the hazardous chemical.