Secondary Container Labels: Decanting Chemicals Safely

The rule in plain terms

OSHA's Hazard Communication Standard requires employers to label workplace containers of hazardous chemicals. A secondary container, such as a wash bottle, spray bottle, bucket, beaker or tank, receives a chemical from the supplier's container. The standard allows an exception for 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. Immediate use means the transferred chemical is under the control of and used only by the person who transferred it, within the work shift in which it was transferred.

If a container will be left unattended, used by someone else, stored for later or used on another shift, it needs a label.

What the label must say

The label must give the product identifier, which should match the name on the SDS, and words, pictures or symbols that give general information about the hazards. Options:

• Copy the supplier label elements: the signal word, pictograms and hazard statements.
• Use a workplace system with the product name, hazard pictograms and a short description, such as "Flammable liquid. Keep away from heat."
• Use NFPA or HMIS if employees are trained on them and they are consistent with HazCom.

See chemical labeling requirements for the supplier label elements and how they differ.

Practical tips

• Keep pre-printed labels for your commonest transfers: solvents, diluted cleaners, acid and base solutions.
• Include the dilution or concentration when it matters, such as "10% bleach solution".
• Add the date prepared and the initials of the person who prepared it for lab solutions.
• Use chemical-resistant label materials, because paper peels and ink runs.
• Never reuse food or drink containers. They invite swallowing accidents.
• Choose compatible materials. Some solvents attack certain plastics, and some oxidizers should not be stored in containers with organic residues; see storage compatibility.

Laboratory notes

Laboratories using the OSHA laboratory standard have additional expectations: labels on incoming containers must not be defaced, and the chemical hygiene plan typically sets rules for labeling of solutions. See the OSHA laboratory standard. Many labs use the same label for stock solutions, with fields for the chemical name, concentration, preparation date, preparer and hazards.

Common mistakes

• Writing only a nickname or abbreviation that nobody else understands.
• Labeling with the product trade name but not the hazard.
• Assuming an unlabeled bottle is "just water" without verifying.
• Letting the original container run out and discarding its label, so the SDS can no longer be matched.
• Decanting into a container that could be mistaken for a beverage.

When you find an unlabeled container, stop. Do not sniff or taste it, tell a supervisor, and arrange identification and disposal. See Section 13 for disposal and chemical inventory management to prevent orphan containers.

Worked scenario: a spray bottle on the next shift

A technician fills a spray bottle with a diluted disinfectant at the end of the day and leaves it on a trolley for the night cleaners. Because another person will use it on a later shift, the bottle does not qualify for the immediate-use exception. It needs a label with the product name and the main hazards, such as "Disinfectant, diluted. Irritant. Avoid contact with eyes." Even a simple pre-printed sticker does the job, as long as it names the product and the hazard in terms the next user understands.

A good test is to ask: if a new colleague found this container with no one around, would they know what it is and how to be careful? If not, label it.

A simple label template

• Product name: the name used on the safety data sheet.
• Concentration or dilution: when it differs from the original.
• Hazards: pictogram, signal word or a short phrase such as "Flammable" or "Corrosive".
• Precautions: the main one, such as "Wear gloves and eye protection".
• Prepared by and date: useful for lab solutions and for finding the source if something goes wrong.

Frequently asked questions