From: Jeff Tenney <Jeff.Tenney**At_Symbol_Here**SDMYERS.COM>
Subject: Re: [DCHAS-L] GHS labeling of secondary containers
Date: May 13, 2013 8:32:58 PM EDT
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <452117618.4813047.1368129498823.JavaMail.root**At_Symbol_Here**>

Here is an excellent resource:


Here is an excerpt from an article at:



Fourth HazCom 2012 Deadline: June 1, 2016 (Employers)

By this date, employers must be fully compliant with OSHA's adoption of GHS. They must complete any necessary updates to their hazard programs and workplace labeling procedures, and all affected employees must be trained on any new hazard or safety procedure identified during the chemical reclassifications done by manufacturers and distributors.

As with the employee training on how to read GHS formatted SDSs and labels, employers may not wish to wait until the deadline before getting into full compliance. Either way, at no time will employers be exempt from complying with either the old HCS or the new (or some combination of the two). In other words, employees must not lose any of the protections they had under the old HCS.

Many employers have questions about how to best produce HazCom 2012-compliant workplace labels (also called secondary container labels or in-plant labels).This is one area where OSHA is a little more flexible. Employers can continue to use their current workplace labeling systems so long as they take into account new hazard classifications. In other words, workplace labels will continue to be performance based. HazCom 2012 does not specify for employers exactly what has to be on the label. Instead, it tells employers the effect the labels must achieve in regards to providing employees important hazard information. What OSHA says is that the workplace label must provide the same understanding for employees that a shipping label would.

OSHA says employers can either replicate the hazard information found on the shipping label or use "some combination" of the elements (product identifier, signal words, pictograms, hazard statements, precautionary information), which, along with training, achieve the same affect. A way to think about it would be the equation: workplace label + training (must) = shipping label. Best practice is to replicate the information found on the shipping label, which is something a good secondary labeling system can easily do. This, of course, not only provides the best information for employees, it also provides the most compliance coverage for employers.


From the standard:


(f) Labels and other forms of warning.

The HCS is designed to provide

information through three different

media: labels or other forms of

immediate warning; safety data sheets;

and training. Labels are attached to the

container of chemicals, and thus

provide the information that employees

have the most ready access to in the

workplace. Given that they are attached

to containers, they are by necessity

somewhat limited in the amount of

information they can present. The labels

provide a snapshot or brief summary of

the more detailed information provided

to employees in training programs, or

available to them on safety data sheets.

They are not intended to be a complete

or detailed source of information on the


In the current HCS, the requirements

for labels are performance-oriented




The current HCS similarly requires

identity and appropriate hazard

warnings for in-plant containers. OSHA

has taken a flexible approach to in-plant

labeling, allowing a wide variety of

systems to be used as long as all of the

required information is readily available

to employees when they are in their

work areas. Thus the current standard

allows employers to continue to use

systems such as the Hazardous

Materials Information System (HMIS)

and the National Fire Protection

Association (NFPA) labeling systems

that use numerical rankings of hazard.


We plan to continue to use the NFPA system.


Hope this helps,

Jeff Tenney



From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU]On Behalf Of David H Silberman
Sent: Thursday, May 09, 2013 3:58 PM
Subject: Re: [DCHAS-L] GHS labeling of secondary containers


Maybe in California we've had more practice with interactions with regulatory officials: we occasionally win a few.   


One example that may be applied to GHS labeling requirements for other than purchased reagents is to differentiate between working solutions (defined as those in containers such as beakers, flasks that will not be used as storage and will be gone within 24 hours) and stock solutions that will be stored.  In Santa Clara County and I suspect other counties in the state, we are required to label any chemical that will be stored in a container other than that which was purchased with the full chemical name (i.e., 12 M Hydrochloric Acid, and not 12 M HCl); working solutions are exempt from that requirement.


The bottom line is to work with local regulators (who provide the interpretation).  Since this is a relatively new area for everyone, it may help your cause to get a consortium of those being regulated in the same room with those who regulate them.




PS A few words of advice:  avoid sarcasm and extreme / hyperbolic examples.  The humor gene may have been deleted among within the genome of some of our regulatory colleagues


David H. Silberman
Director, Health and Safety Programs
Stanford University School of Medicine
1265 Welch Road, Mail Code 5459
Medical School Office Building, Room X-104 
Stanford, CA 94305

Direct Line: 650-723-6336
Office Line: 650-723-0110
FAX Line:    650-736-0179

Mobile:      650-924-0962

Sent: Thursday, May 9, 2013 11:58:42 AM
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


Previous post   |  Top of Page   |   Next post

The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.