A lot has been said on LinkedIn about secondary container labeling, and at least seven (7) posts were absolutely wrong. Those posts have been shared more than 400 times; I wish I knew how many views. Many people agreed with the original posters that secondary containers had to be labeled the same as shipped containers. I disputed the posts, only to have several of my comments removed. The ones I shared in my LinkedIn SAFTENG group to set the record straight got me in trouble; the posts were removed, and now I cannot share other posts in my group. Yet the incorrect posts continue to gain traction still today. Moral of the story, there are a lot of snakeoil salespeople in this profession, so be careful where you seek advice!
NOTE: One poster updated their post and sent me a nice note in response. I think the others are being paid to post their crap so people will spend the $ on the labels with all the Pictograms, Signal Words, Precautionary Statements, etc. Why else would they keep these blatantly incorrect posts up? Even more sad is how many safety people fall for these gimmicks.
Here are the labeling requirements for SECONDARY CONTAINERS in a workplace. Notice these requirements fall under .1200(f)(6); very different from the requirements for “Shipped Containers”, which fall under (f)(1).
1910.1200(f) Labels and other forms of warning
1910.1200(f)(1) Labels on shipped containers.
The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked. Hazards not otherwise classified and hazards identified and classified under (d)(1)(ii) do not have to be addressed on the container. Where the chemical manufacturer, importer, or distributor is required to label, tag or mark the following shall be provided:1910.1200(f)(1)(i) Product identifier;
1910.1200(f)(1)(ii) Signal word;
1910.1200(f)(1)(iii) Hazard statement(s);
1910.1200(f)(1)(iv) Pictogram(s);
1910.1200(f)(1)(v) Precautionary statement(s);
1910.1200(f)(1)(vi) Name, U.S. address, and U.S. telephone number of the chemical manufacturer, importer, or other responsible party.
Here are the requirements for secondary containers in a workplace. PLEASE take note that OSHA permits an employer to label their secondary container in the same manner as a “shipped container” if they prefer to do this (i.e., see (f)(6)(i)); but it is an OPTION – NOT a requirement as many claim.
1910.1200(f)(6) Workplace labeling.
Except as provided in paragraphs (f)(7) and (f)(8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either:
1910.1200(f)(6)(i) The information specified under paragraphs (f)(1)(i) through (v) of this section for labels on shipped containers; or,
1910.1200(f)(6)(ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.
1910.1200(f)(7) The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(6) of this section to be on a label. The employer shall ensure the written materials are readily accessible to the employees in their work area throughout each work shift.
1910.1200(f)(8) The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. For purposes of this section, drugs which are dispensed by a pharmacy to a health care provider for direct administration to a patient are exempted from labeling.
1910.1200(f)(9) The employer shall not remove or deface existing labels on incoming containers of hazardous chemicals, unless the container is immediately marked with the required information.
1910.1200(f)(10) The employer shall ensure that workplace labels or other forms of warning are legible, in English, and prominently displayed on the container, or readily available in the work area throughout each work shift. Employers having employees who speak other languages may add the information in their language to the material presented, as long as the information is presented in English as well.
With all that said, here is a label that I made for a client to put on their secondary containers. And “secondary containers” include their Bulk Storage Tanks.
This label meets the (f)(6) requirements and has been seen/inspected by dozens of OSHA CSHOs since 2012 (the year GHS came about), and not one of them complained about the label. The NFPA 704 Diamond is widely recognized, and when included in the facility’s HAZCOM written program and training, it is an accepted means of labeling. The 704 Diamond label MUST include the chemical name or some means for the worker(s) to be able to look up the SDS of said chemical. In the example above, the chemical is N-Methyl-2-pyrrolidone (NMP). Not a requirement, but something I have done my entire career, I always make the name label color-coded to match the piping color coding in ANSI/ASME A13.1 Pipe Labeling standard. Flammable Liquids are labeled with yellow labels and black print. Hence, the NMP is on a yellow background with black font.
Some have challenged the use of the NFPA 704 Diamond on secondary containers. These challenges were worthy, but OSHA and NFPA allow the NFPA 704 Diamond to be used on secondary containers. The label above has been used on bulk and small secondary labels since I started my industrial safety career in 1992, when my first internship involved labeling storage tanks at a chemical facility.
I would also point out that the IFC requires the NFPA Diamond be used on storage tanks and on entry doors to chemical storage areas. In fact we can find this in the 704 standard, which is a strong indication that NFPA is NOT limiting its use for secondary containers:
Exception: For containers with a capacity of 3.78 L (1 gal) or less, symbols can be reduced in size, provided the following:
(1) The reduction is proportionate.
(2) The color coding is retained.
(3) The vertical and horizontal dimensions of the diamond are not less than 25 mm (1 in.).
(4) The individual numbers are no smaller than 3.2 mm ( ¹ ⁄8 in.) tall.
Another figure provided in NFPA 704 indicates that NFPA is perfectly fine with using the Diamond on bulk storage tanks, as they provide instructions for this use and the following image to show the correct application:
Here is some WRONG application of the NFPA 704 Diamond (just for fun).
