GHS secondary container labels are a crucial step to ensure continuous safe transportation, handling and use throughout the life of a hazardous material. But secondary container labeling can be overlooked or misunderstood. Let’s dive into the world of GHS secondary container labeling, including:
Let’s start with the two governing bodies that guide and enforce the labeling of hazardous materials and chemicals – the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals and the OSHA HazCom (Hazard Communication) Standard 29 CFR 1910.1200.
In general, the difference comes down to use cases and size. Primary containers are usually for purposes of transport and storage, while secondary containers are generally used in the workplace for specific tasks. Examples of secondary containers might include spray bottles used for cleaning or disinfecting solutions, small containers used to hold solvents or paints, or jugs or bottles used for storing laboratory chemicals.
Primary containers are generally large storage containers, including drums, tanks or silos. Primary container labeling is vital for ensuring workplace safety as it’s essential that anyone coming into contact with these substances fully understands the risks they pose. Primary or shipped container labels are used on any container leaving the workplace. These labels must have the six required elements of a GHS chemical label.
Secondary containers are smaller receptacles, such as bottles and packages, that hold a smaller portion of the hazardous material. Secondary container labels are sometimes called workplace labels. These containers don’t always fall under the same requirement that primary containers do. A best practice is to match this label to the primary container label for consistency, if possible. However, other labeling options can be used.
Secondary container labeling ensures the continued safe transport, handling and use of hazardous chemicals. Since secondary containers are usually smaller, easily transported and more accessible to workers and bystanders than primary containers are, proper labeling is just as important as it is for primary container labeling. Failure to follow OSHA HazCom requirements can lead to worker injuries, property and environmental damage, fines, work stoppage and more.
Not always. GHS labels for secondary containers are exempt when the following criteria are met:
While primary container labels must contain the six required elements for GHS labeling, secondary container labels require a minimum of two elements, according to OSHA. They are:
While the labeling requirements for secondary container labels are less strict, they must be accompanied by supporting safety information, e.g. safety data sheets, as detailed in OSHA CFR 1910.1200(b)(4)(ii). This ensures employees have access to specific information regarding any hazardous chemical in the workplace. A best practice is to apply as many of the six elements of a compliant GHS label to your secondary containers as possible.
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The Brady Workstation GHS Label App allows you to easily create GHS labels right from your Safety Data Sheets (SDS). Just enter SDS data one time and then create any size label and print it at any time.
