A secondary container is any container used after a chemical is transferred out of its original shipped container. These containers are used throughout industrial, laboratory, maintenance, and production environments.

Common examples include:

• Spray bottles

• Squeeze bottles

• Jars and beakers

• Process tanks

• Portable or temporary-use containers

• Bottles used during maintenance, cleaning, or lab work

OSHA requires these containers to remain labeled so workers always know what the substance is and what hazards it presents.

Secondary container labels ensure hazard communication continues after a chemical is transferred from its original container. Workers routinely move chemicals for cleaning, production, maintenance, batch mixing, sampling, or research. Once the chemical leaves the primary container, hazard information can easily be lost.

Without appropriate workplace labeling, chemicals may be:

• Mistaken for other substances

• Stored incorrectly

• Mixed with incompatible materials

• Used without proper PPE

• Handled by workers unaware of the hazards

Secondary labels prevent these risks by keeping hazard information visible wherever the chemical is used. This supports OSHA’s core expectation: Every worker must know exactly what they are handling at all times.

Primary container labels are created by the manufacturer or importer and must follow full GHS requirements exactly as listed in the SDS. They are standardized, fixed, and required for all shipped containers.

Secondary container labels are created by the employer after a chemical is transferred for workplace use. These labels are more flexible but must still clearly identify the chemical and communicate applicable hazards in a way workers understand. OSHA allows simplified GHS information or systems like NFPA or HMIS when employees are trained. Secondary containers may qualify for the immediate-use exemption under strict conditions.

The table below summarizes the key differences at a glance.

OSHA requires labeling of any secondary container when:

• More than one worker may use it

• It will be used across multiple shifts

• It will be stored for any amount of time

• It may be moved to another work area

• The chemical will not be used immediately

• The identity of the contents may become unclear

• The original primary label is not visible or accessible

In practice, if anyone other than the person who filled the container might handle it, the container must be labeled.

Employers should assume labeling is required unless all exemption criteria are fully met.

A secondary container does not require a label only if every condition below is met:

1. The employee who filled the container will use the chemical

2. The chemical is used during the same work shift

3. The container remains under the employee’s direct control

4. The container is not set down in a way that others could use it

5. The contents are fully consumed or disposed of immediately

If any condition is not met, the container must be labeled.

Common examples that do not qualify, even though many facilities mistakenly assume otherwise:

• Bottles left on cleaning carts

• Containers used by rotating crews

• Shared solvent bottles

• Lab containers used for extended testing

• Bottles stored for later use

This is one of the most frequently misunderstood parts of OSHA’s HCS and a common source of citations.

OSHA requires every secondary container label to communicate two key elements: the product identifier and hazard information. These components ensure workers can recognize the chemical and understand associated risks before handling or storing it.

The product identifier must match exactly what appears on the primary container and in Section 2 of the SDS. This prevents confusion between similar substances and ensures workers can locate the correct SDS immediately.

OSHA allows several compliant approaches, as long as the hazards are clear and consistent with the SDS.

A full GHS-style label mirrors the primary container and may include the signal word, hazard statements, pictograms, precautionary statements, and supplier details. This provides the strongest level of clarity and is common in laboratories, chemical processing, and high-risk operations.

Some workplaces use a shorter format that includes the product identifier along with key hazard warnings, PPE requirements, or safe-handling instructions. This approach is acceptable if employees have been trained and the information is accurate.

Workplaces may use NFPA or HMIS systems if:

• The labels communicate equivalent hazards

• Workers are trained to interpret them

• The information does not contradict the SDS

This option is widely used in maintenance, warehousing, utilities, and general industry.

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