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HazCom Labels
Primary vs. Secondary Container
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GHS HazCom
Regulation information
OSHA has not changed the general requirements for secondary container labeling specifically. Employers have the option to create their own workplace labels by using all of the information provided by the manufacturer or using a combination of the elements in the GHS label example on page 366. Employers may continue to use rating systems such as the National Fire Protection Association (NFPA) diamonds or Hazardous Materials Identification System (HMIS) requirements for workplace labels, as long as they are consistent with the HazCom 2012 / GHS standard.
Primary container labeling
Primary chemical containers are bags, barrels, bottles, boxes, cans, cylinders, and drums that you receive from the manufacturer. These containers should be labeled following the GHS mandates and include all six labeling elements. When a label is on a container directly from a supplier, this label cannot be removed, altered or defaced. If it needs to replaced, the new label must contain the same information as the original.
Secondary container labeling
Secondary containers are usually smaller than primary container, such as spray bottles, jugs or jars. They usually hold chemicals that are transferred from a primary container. Secondary containers must comply with GHS workplace labeling requirements except when the following criteria are met: The material is used within the work shift of the individual who makes the transfer The worker who made the transfer is in the work area the entire time during use The container stays in within the work area and in the possession of the worker who filled the container
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