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Date: May 9, 2013 3:14:40 PM EDT
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Subject: Re: [DCHAS-L] GHS labeling of secondary containers
Date: May 9, 2013 3:58:18 PM EDT
Author: David H Silberman

From: Dave Einolf <dave**At_Symbol_Here**ENDEAVOUREHS.COM>
Subject: Re: [DCHAS-L] GHS labeling of secondary containers
Date: May 9, 2013 3:37:51 PM EDT
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <5E76EF51D002544DAC5CFA68490FC5DA1D96D018**At_Symbol_Here**CAE145EMBP03.ds.sc.edu>

Am surprised they didn't claim this exemption:

1910.1200(f)(8)
The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer.

They would have to have the students transfer from the bulk 0.1M HCl container to their lab benches, but the smaller containers would be exempt.

Regards,

Dave

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of GOODE, SCOTT
Sent: Thursday, May 9, 2013 11:59 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] GHS labeling of secondary containers

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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