OSHA clarifies secondary container labeling guidelines for employers

When OSHA adopted the Globally Harmonized System (GHS) in 2012, it wasn't immediately clear to many veterinarians how changes to labeling rules would affect them in the workplace. 

Initially it seemed as though veterinarians would be required to display GHS labels on all chemical products within the hospital, meaning hospitals would have to change their secondary labeling procedures.

The latest guidance from OSHA reveals that the organization has not changed the general requirements for workplace labeling. When it comes to secondary container labeling, OSHA said veterinarians and other employers can proceed as usual as long as they are adequately informing employees about hazardous chemicals.

"If an employer has an in-plant or workplace system of labeling that meets the requirements of HazCom 1994, the employer may continue to use this system in the workplace as long as this system, in conjunction with other information immediately available to the employees, provides the employees with the information on all of the health and physical hazards of the hazardous chemical," OSHA said in its briefing.

According to OSHA, as long as employees have immediate access to all information about the hazards of the chemical, and as long as secondary container labels do not conflict or confuse GHS pictograms or signal words, employers can use a workplace labeling system that includes any of the following labeling methods:

  • Signs
  • Placards
  • Process sheets
  • Batch tickets
  • Operating procedures
  • Other written materials to identify hazardous materials 

More information

Read the full briefing at the OSHA website. 

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