What counts as a secondary container?
Anything that isn't the original packaging from the chemical manufacturer. This includes spray bottles you fill with disinfectant, jugs you decant solvent into, plastic squirt bottles for adhesive, and refilled buckets of cleaning concentrate.
What must a workplace label include?
- The product identifier (the chemical or product name) matching the SDS in your library
- Words, pictures, symbols, or a combination that convey the chemical's hazards
- Information that, together with training, makes the hazards understandable to workers
OSHA gives employers flexibility in how they meet these requirements. The simplest path is to reproduce the original GHS label format — pictogram, signal word, hazard statement. Many employers print short-form workplace labels that include the chemical name, signal word, and the most important pictograms.
Why secondary container labeling fails so often
- An employee decants a cleaner into an unmarked spray bottle 'just for today' — and it sits on the shelf for six months.
- Old labels become illegible from chemical splash and are not replaced.
- Multiple chemicals get stored in similar containers with handwritten markers that don't communicate hazards.
- Refilled buckets of concentrate carry only the brand name, not the chemical or hazard information.
I've never met a small-business owner who didn't have at least one unlabeled spray bottle somewhere. The fix is just to issue printed labels every time you refill — but it almost never happens without a system.