From: "Kennedy, Sheila" <s1kennedy**At_Symbol_Here**>
Subject: Re: [DCHAS-L] GHS/Label issue
Date: Wed, 20 Nov 2013 20:09:48 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: FA001EE30BA70F4D926117C13DAFFFDF419F6662**At_Symbol_Here**XMAIL-MBX-AT1.AD.UCSD.EDU


I sounds as though some of them are as easily confused as we are.

Is there some subtlety of wording that I’m missing here?



Sheila Kennedy, C.H.O.

Safety Coordinator | Teaching Laboratories

UCSD Chemistry & Biochemistry |MC 0303

s1kennedy**At_Symbol_Here** |

Office: (858) 534-0221 | Fax: (858) 534-7687


From: Kim Gates [mailto:kim.gates**At_Symbol_Here**]
Sent: Wednesday, November 20, 2013 10:45 AM
To: Kennedy, Sheila
Subject: GHS/Label issue


Sheila - I read your email on DCHAS abt GHS & labels: 


PLEASE correct me if I have this wrong, but my understanding is that the new GHS requirements (HazComm2012) is part of the Hazard Communications Standard. Laboratories such as ours work under the Laboratory Standard, which doesn't include these new standards. Neither one strictly applies to students, who are not employees.


I am in 100% agreement with you about label requirements & haz com vs. labs. The Lab Std only says not to deface incoming labels & label when chems leave the lab as per haz com. I have a copy of the preamble (yes, I'm that geeky) and it states:

"To avoid any confusion which could arise regarding hazard identification relating to the HCS as distinct from that relating to this standard, OSHA has added three clarifying statements regarding laboratory generated chemical substances"....


The Lab standard has no requirement for labeling secondary containers and makes the point that these chemicals are different from HCS labels. 


So - my big question - how does OSHA post this handout on their web site for lab standard?


this says laboratory containers must be labeled as per HCS!


Have you guys thought abt this problem? What did you decide?



Kim Gates
Laboratory Safety Specialist
Environmental Health & Safety
Stony Brook University
Stony Brook, NY 11794-6200
FAX: 631-632-9683
EH&S Web site:

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.