From: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
Subject: Re: [DCHAS-L] GHS labeling of secondary containers
Date: May 9, 2013 11:17:21 PM EDT
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <5E76EF51D002544DAC5CFA68490FC5DA1D96D018**At_Symbol_Here**>

The labeling requirements do not apply so stringently to a container that is filled only with material to be fully consumed in the course of one day (shift). I think the basic idea was that the person who put it in the container is more likely to be around throughout that time.

If you diluted HCl is to be stored in the container for more than the one day, then it must be labeled in full compliance with the CFR requirements (i.e. HazMat 2012 as is applies to Labs)

Peter Zavon, CIH
Penfield, NY


-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of GOODE, SCOTT
Sent: Thursday, May 09, 2013 2:59 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

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

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