In a Letter of Interpretation, OSHA clarified its requirements for labeling of small containers of hazardous chemicals, such as 5 milliliter (mL) vials or 50 mL bottles, under the revised Hazard Communication standard (HCS 2012).
Under the HCS 2012, OSHA reiterated that labels must be attached to a hazardous chemical’s immediate container. A manufacturer, importer, or distributor can not attach an HCS 2012 label only to the outside packaging of a shipped hazardous chemical. Nor is it acceptable to use a key (e.g., a numbering system) linking each individual 5 mL vial or 50 mL bottle to an accompanying sheet(s) containing the information required on the HCS 2012 label. OSHA did say that labeling can be accomplished with pull-out labels, fold back labels, tags or other methods.
As a practical accommodation, where the chemical manufacturer can show that it is not feasible to use pull-out labels, fold back labels, or tags, containing the full HCS 2012 required information, OSHA stated that the shipped small container (i.e., the actual container holding the hazardous chemical), at a minimum, must contain the following:
- Product identifier
- Appropriate pictograms
- Manufacturer’s name and phone number
- Signal word
- A statement indicating the full label information for the chemical is provided on the outside package.
Additionally, the outside packaging, at a minimum, must comply with the following:
- All the applicable label elements, as defined in 29 CFR 1910.1200(f)(1).
- The outside package must be clearly marked to ensure the complete label elements are visible and it must clearly inform users that the small container must be stored in the outer container bearing the complete label. The complete label must be maintained on the outer package (e.g., not torn, defaced, destroyed).
- The manufacturer must ensure that any alternative labeling used does not conflict with any other standards.