In the industrial labs I have worked (for at least 12 years) we had to label with hazards all containers, made in-house and brought in. We mostly used the HMIIS system before GHS.
The only exception from this rule were samples prepared for immediate use in instruments (HPLC, NMR etc.). They needed to remain in the autosamplers or be processed or labeled.
All other containers were labeled according to in-house rules, i.e. if a vendor didn't label their container according to our minimum standards we added our own labeling. And, we didn't like that vendor ... :).
Speaking only for myself...
From: "SCOTT GOODE" <SRGOODE**At_Symbol_Here**MAILBOX.SC.EDU>
Sent: Thursday, May 9, 2013 2:58:42 PM
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
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