Misinformation Regarding Manufacturer Information on GHS Labels

OSHA Regulations for secondary container label requirements are often misunderstood.

There is a common misconception that exists regarding secondary container label requirements. The confusion lies within the definition of primary and secondary chemical containers, respectively.

According to the OSHA Hazard Communication Standard, also known as HazCom [29 CFR 1910.1200(f)(1)], primary and secondary containers are defined differently and contain different label requirements.

Primary chemical containers are shipped to a location from the supplier/manufacturer of the chemical. Primary containers, also known as permanent, arrive with a label on them. The label on the primary containers include the manufacturer information.

When the larger drum of chemicals arrives, it is broken up into smaller containers for employee use. These smaller containers are known as secondary, or portable containers. The HazCom Standard indicates conditions that must be met that requires a secondary label, found here.

Given that conditions are met that would require a secondary identification, the HazCom standard says the labels “must contain two key pieces of information: the identity of the hazardous chemical(s) in the container, and the hazards present (OSHA 2015).” 

This amendment to the HazCom standard is often overlooked. All secondary container GHS chemical safety labels are NOT required to include the manufacturer information. HCL’s library of GHS labels do not contain any manufacturer information.

HCL Labels is happy to include any custom information that you would like on your labels. Contact us today if you would like to include manufacturer information!

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For more information regarding OSHA secondary container label requirements, please review the Quick Facts sheet here.

2018 Hazardous Waste Format – Regulatory Update

Federal regulation 49 CFR 172.301 requires an updated format for Hazardous Waste Marking and Communication.

In case you haven’t already noticed, HCL Labels recently updated the artwork on all of our hazardous waste storage, shipping, and identification labels. The old format contains a larger box at the bottom of the label.

This update has taken effect at HCL in order to meet the new standard for hazardous waste identification. According to the regulation, all hazardous waste labels must contain separate box for the UN, NA, or ID number that is at least 12mm (0.47 inches) high.

HCL would like to advise all of our customers who maintain a hazardous waste program at their facility, to ensure that you stock the proper identification labels. You can view our updated library of hazardous waste labels at the link below.


The New Format:

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