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From: "GOODE, SCOTT" <SRGOODE**At_Symbol_Here**MAILBOX.SC.EDU>
Subject: [DCHAS-L] GHS labeling of secondary containers
Date: May 9, 2013 2:58:42 PM EDT
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <5E76EF51D002544DAC5CFA68490FC5DA1D96D018**At_Symbol_Here**CAE145EMBP03.ds.sc.edu>

Demystify: 
A university in my state recently was inspected and told to provide GHS labels for solutions prepared for their students. They purchase 12 M HCl (as an example) which has the appropriate label but they prepare 0.1 M HCl for use in student labs. They were told that the 0.1 M HCl requires a GHS label.

Not that you can win an argument with regulatory officials, but in industrial and research labs we make up thousands of solutions and samples each day.

I noticed that someone quoted the Code of Federal Regulations in an earlier response to a GHS labeling question. Does the CFR address requirements on solutions made in-house?

Does a 96-well plate does need 96 tiny labels?

--------------------------------------------------------
Scott Goode, Professor
Department of Chemistry and Biochemistry
University of South Carolina
631 Sumter Street
Columbia SC 29208

Email: Goode**At_Symbol_Here**sc.edu
Phone: 803-777-2601
Fax: 803-777-9521

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