From: Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU>
Subject: Re: [DCHAS-L] GHS and secondary container labeling in acedemia
Date: Sun, 17 Nov 2013 20:35:03 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: CAEwQnqjkgagqBr1Q=5bT1PC77NRBPtZNAsDMwESjt-CTfp48+A**At_Symbol_Here**


4.7 Are workplace containers covered in the GHS ?
Products falling within the scope of the GHS will carry the GHS label at the point where they are supplied to the workplace, and that label should be maintained on the supplied container in the workplace. The GHS label or label elements can also be used for workplace containers (e.g., storage tanks). However, the Competent Authority can allow employers to use alternative means of giving workers the same information in a different written or displayed format when such a format is more appropriate to the workplace and communicates the information as effectively as the GHS label. For example, label information could be displayed in the work area, rather than on the individual containers. Some examples of workplace situations where chemicals may be transferred from supplier containers include: containers for laboratory testing, storage vessels, piping or process reaction systems or temporary containers where the chemical will be used by one worker within a short timeframe.

and from:

Workplace Labels
OSHA has not changed the general
requirements for workplace labeling.
Employers have the option to create their own
workplace labels. They can either provide
all of the required information that is on the 5
label from the chemical manufacturer or, the
product identifier and words, pictures, symbols
or a combination thereof, which in combination
with other information immediately available
to employees, provide specific information
regarding the hazards of the chemicals.
If an employer has an in-plant or workplace
system of labeling that meets the requirements
of HazCom 1994, the employer may continue
to use this system in the workplace as long
as this system, in conjunction with other
information immediately available to the
employees, provides the employees with
the information on all of the health and
physical hazards of the hazardous chemical.
This workplace labeling system may include
signs, placards, process sheets, batch tickets,
operating procedures, or other such written
materials to identify hazardous chemicals. Any
of these labeling methods or a combination
thereof may be used instead of a label from the
manufacturer, importer or distributer as long
as the employees have immediate access to
all of the information about the hazards of the
chemical. Workplace labels must be in English..
Other languages may be added to the label if
If the employer chooses to use the pictograms
that appear in Appendix C on the workplace (or
in-plant) labels, these pictograms may have a
black border, rather than a red border.
Employers may use additional instructional
symbols that are not included in OSHA's
HCS pictograms on the workplace labels. An
example of an instructional pictogram is a
person with goggles, denoting that goggles
must be worn while handling the given
chemical. Including both types of pictograms
on workplace labels is acceptable. The same is
true if the employer wants to list environmental
pictograms or PPE pictograms from the HMIS
to identify protective measures for those
handling the chemical.
Employers may continue to use rating systems
such as National Fire Protection Association
(NFPA) diamonds or HMIS requirements
for workplace labels as long as they are
consistent with the requirements of the Hazard
Communication Standard and the employees
have immediate access to the specific hazard
information as discussed above. An employer
using NFPA or HMIS labeling must, through
training, ensure that its employees are fully
aware of the hazards of the chemicals used.
If an employer transfers hazardous chemicals
from a labeled container to a portable
container that is only intended for immediate
use by the employee who performs the
transfer, no labels are required for the portable

On Sun, Nov 17, 2013 at 2:33 PM, Kevin Creed <kcreed**At_Symbol_Here**> wrote:
Greetings All,

Although the Hazcom/GHS standard does not apply to students, I think there
is some room for 'thinking outside the box' so that we can meet the intent
of the standard and, thus, provide effective, safe communication to
From (c) Definitions: "Label elements" means the specified
pictogram, hazard statement, signal word and precautionary statement for
each hazard class and category."
From (f)(6) Workplace Labeling: "Except as provided in paragraphs
(f)(7) and (f)(8) of this section, the employer shall ensure that each
container of hazardous chemicals in the workplace is labeled, tagged or
marked with either: ...
(ii) Product identifier and words, pictures, symbols, or combination
thereof, which provide at least general information regarding the hazards
of the chemicals, and which, in conjunction with the other information
immediately available to employees under the hazard communication program,
will provide employees with the specific information regarding the
physical and health hazards of the hazardous chemical."

From (f)(7): "(f)(7) The employer may use signs, placards,
process sheets, batch tickets, operating procedures, or other such written
materials in lieu of affixing labels to individual stationary process

So, a combination of identifying small containers with at least the name
of the material plus a number or color coded designation that is tied to a
poster/legend/handout that then provides the required labeling elements
for that material (and any other materials requiring the same elements)
may be the most practical and effective. Although the standard refers to
using batch tickets, etc. for stationary containers, and not very small
containers, I think for our identified need this type of approach is worth

We shouldn't miss the opportunity of integrating the hazardous
identification/communication piece into the lab session curriculum such
that students have to actively access and understand the information, as
confirmed by the lab write up or quizzes, etc.

Also, smart phone access of QR squares, label scans, etc,. that can bring
chemical hazard information to the user/student might be considered as



Kevin Creed

Manager, ChemTracker Program

Stanford University


480 Oak Road

Stanford, CA 94305-8007

office: 650-723-4767

cell: 408-529-0724

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf
Of Osterby, Meg
Sent: Sunday, November 17, 2013 8:18 AM
Subject: Re: [DCHAS-L] GHS and secondary container labeling in acedemia

I also need a solution to this issue. We are a small technical college
and have less than 100 total lab students spread between 3-5 courses each
semester. We use 60 mL droppers for most lab solutions, since larger
amounts are far more than we would use in years. Even so, our dropper
bottles are used multiple semesters. We store them in wooden sleeves on
shelves in the stockroom. In the past, we've labeled them with the
chemical name or formula and concentration only, since they are so small
there isn't room for much more. How do we deal with the new labeling
requirements when there isn't physically room on the bottle for such a
detailed label? Would putting the labels on the wooden sleeves be
sufficient? (They don't go into the lab with the solutions, however, so
the students using the solutions would never see them.) I don't see a
solution to this dilemma, since the bottle sizes are so small.

Meg Osterby
Lead Chemistry Instructor
Western Technical College
400 7th St. N.
LaCrosse, WI 54601

"It's better to be careful 100 times, than to be killed once."
Mark Twain

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf
Of Marlyn Newhouse
Sent: Sunday, November 17, 2013 8:37 AM
Subject: Re: [DCHAS-L] GHS and secondary container labeling in acedemia

Dear Ones,

We stopped using the smaller bottles and are using 100 mL bottles. We
attach a test tube with a small pipette for the "dropper". The label and
test tube are secured with clear packing tape.


Marlyn Newhouse, D.A.
Associate Professor of Chemistry
1050 Union University Drive
Jackson TN 38305

From: DCHAS-L Discussion List [dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of
Melissa Charlton-Smith [charltonsmith**At_Symbol_Here**WVWC.EDU]
Sent: Sunday, November 17, 2013 7:42 AM
Subject: [DCHAS-L] GHS and secondary container labeling in acedemia

Out of curiosity, for those of you in academia, how are you handling GHS
secondary container labeling in teaching lab situations where the average
freshman student isn't exactly known for their attention to detail? We
often have a multitude of small dropping bottles with 30 to 50 ml which
becomes a labeling nightmare because of lack of space for labels due to
the small size of the container.


Mel Charlton-Smith
School of Sciences Chemical Hygiene Officer-NRCC Lab Coordinator, Lecturer
BS-CHO program Department of Chemistry WV Wesleyan College Buckhannon, WV


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