OSHA Labeling Requirements for GHS and Secondary Container Labeling

OSHA Labeling Requirements for GHS and Secondary Container Labeling

Introduction to OSHA Labeling Requirements

Workplace safety is a top priority in any industry handling hazardous chemicals. The Occupational Safety and Health Administration (OSHA) sets strict guidelines for labeling to ensure workers have clear, standardized information on chemical hazards. These guidelines fall under the Hazard Communication Standard (HCS), which aligns with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

Understanding OSHA labeling requirements is crucial for compliance and workplace safety. Whether labeling primary containers from manufacturers or secondary containers used within a facility, businesses must follow specific rules to prevent miscommunication and hazardous incidents.

Overview of the Hazard Communication Standard (HCS) and GHS

The Hazard Communication Standard (HCS) is OSHA’s regulation designed to make sure that employees handling hazardous chemicals are informed about potential risks and protective measures. This standard aligns with the Globally Harmonized System (GHS), an internationally recognized framework for classifying and labeling chemicals.

HCS and GHS labeling help standardize the way chemical hazards are communicated, making it easier for workers to understand risks, regardless of their location or industry. Compliance with these standards reduces workplace accidents, improves emergency response, and helps businesses meet regulatory requirements.

Key Aspects of the HCS include:

  • Hazard classification – Chemicals must be classified based on their health and physical hazards.

  • Labeling requirements – Manufacturers, importers, and employers must label hazardous chemicals properly.

  • Safety Data Sheets (SDSs) – Detailed hazard information must be provided in a standardized format.

  • Employee training – Workers must be trained to recognize and understand hazard labels and SDSs.

HCS-compliant labels must be present on all hazardous chemical containers, including secondary containers used within a facility.

HCS Required Label Elements and Their Importance

To comply with HCS, chemical labels must include specific elements that clearly communicate safety information. These standardized elements help workers quickly identify hazards, understand risks, and take necessary precautions to prevent workplace accidents.

The Six Required Elements of an HCS-Compliant Label

  1. Product Identifier – The chemical name or code that matches the Safety Data Sheet (SDS) to ensure consistency.

  2. Signal Word – Either Danger or Warning, indicating the severity of the hazard.

  3. Pictograms – Standardized symbols representing specific hazards, such as flammability or toxicity.

  4. Hazard Statements – Descriptions of the nature and severity of the hazard (e.g., “Causes severe skin burns and eye damage”).

  5. Precautionary Statements – Instructions on safe handling, storage, and emergency response (e.g., “Keep away from heat, sparks, and open flames”).

  6. Supplier Identification – The name, address, and phone number of the manufacturer or distributor.

These elements are essential for workplace safety, helping to prevent exposure incidents, maintain compliance, and support emergency response.

Secondary Container Label Requirements: What You Need to Know

Primary chemical containers come with HCS-compliant labels, but secondary containers—such as spray bottles, beakers, or transfer containers—also require proper labeling when holding hazardous chemicals. Since these containers are commonly used in daily operations, clear labeling is critical for both safety and compliance.

What Must Be Included on a Secondary Container Label?

OSHA allows flexibility in secondary container labeling but requires enough information so that employees can identify the chemical and its hazards. Labels should include:

  • The product identifier (chemical name or code).

  • Pictograms, hazard statements, and precautionary statements from the original manufacturer’s label.

  • A signal word (Danger or Warning, if applicable).

Some workplaces use workplace-specific labels that follow HCS but provide simplified information, such as NFPA or HMIS labels. However, these must still convey the necessary hazard details.

Exceptions to Labeling Requirements

If a secondary container is under the direct control of the employee who transferred it and will be used immediately, OSHA does not require a label. However, best practices suggest labeling all secondary containers to prevent confusion and accidental exposure.

Proper secondary container labeling not only helps businesses comply with OSHA labeling requirements but also protects employees from avoidable chemical hazards.

Best Practices for OSHA-Compliant Labeling

Ensuring proper labeling of hazardous chemicals is essential for maintaining a safe and compliant workplace. Following best practices can help businesses meet OSHA labeling requirements while reducing the risk of accidents and regulatory violations.

1. Use Durable, Legible Labels: Labels should be resistant to chemicals, abrasion, moisture, and extreme temperatures to prevent fading or peeling. A damaged or unreadable label can lead to serious safety risks and non-compliance.

2. Standardize Labeling Across the Workplace: Consistency in labeling helps employees quickly recognize hazards. Whether using HCS-compliant labels or workplace-specific labeling systems (such as NFPA or HMIS), all labels should provide clear and accurate information.

3. Train Employees on Labeling Requirements: Workers should understand how to read labels, recognize hazard pictograms, and follow precautionary statements. Regular training allows employees to safely handle chemicals and identify mislabeled or missing information.

4. Regularly Inspect and Replace Labels: Routine inspections help identify worn-out or missing labels before they become a hazard. Implementing a proactive labeling maintenance program reduces the risk of compliance issues.

5. Maintain Proper Documentation: Make sure that all labels match the corresponding Safety Data Sheets (SDSs) and that documentation is up to date. This helps streamline compliance audits and improves workplace safety.

Avoiding Common Mistakes and Ensuring Compliance

Errors in HCS-compliant labeling can lead to workplace hazards and regulatory violations. Here are some common pitfalls to watch for:

  1. Missing or Incomplete Labels – Secondary containers without proper labeling create confusion and increase the risk of exposure.

  2. Illegible or Low-Quality Labels – Faded or damaged labels make hazard identification difficult, putting workers at risk.

  3. Outdated Labels – Failing to update labels when chemical hazards change can result in misinformation and non-compliance.

  4. Unapproved Symbols or Abbreviations – Custom markings may lead to misinterpretation, reducing label effectiveness.

  5. Lack of Employee Training – Without proper training, workers may overlook critical hazard information or mishandle chemicals.

By recognizing these mistakes, businesses can take corrective action to strengthen compliance and workplace safety.

How GMP Labeling Supports Your Compliance Needs

GMP Labeling provides HCS-compliant labels designed for durability, clarity, and regulatory compliance. Our high-performance labels withstand chemicals, moisture, and extreme conditions to maintain long-term readability. We also offer custom solutions tailored to your facility’s needs, backed by decades of expertise in FDA-regulated industries.

Stay compliant and keep your workplace safe with GMP Labeling. Reach out to a specialist today!

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