Container Labeling: A Key to Compliance

Decide on a format for labeling, then designate someone with the responsibility of ensuring containers are properly labeled, and label information is reviewed and updated when necessary

Each year when federal statistics are released, it comes as little surprise that violations of OSHA's Hazard Communication Standard are among the top 10 safety citations issued to general industry. With more than 4,000 violations issued each year, OSHA continues to make it quite clear that having a dusty, nearly empty binder of MSDS wedged on the top shelf of someone's office is not enough.

In order to truly meet the intent of the HazCom Standard, facilities must have a written plan that outlines their hazard communication program, ensure employees are properly trained about the hazards in their workplace, and document that each employee who could be exposed to a hazard understands what he needs to do to protect himself.

One of the facets of a complete hazard communication program is establishing a process for proper container labeling. Like the dusty binder on the top shelf, a container with a piece of curled masking tape that has something written in smudged ballpoint pen probably is not going to satisfy a compliance officer.

Documenting container-labeling responsibilities and providing proper training are two keys to compliance with the container labeling requirements of this standard.

Chemical Manufacturer Responsibilities

The burden of properly evaluating and classifying chemicals to determine their hazards falls upon the manufacturer or importer of the chemical. [29 CFR 1910.1200(d)(1)] OSHA allows employers to rely on this information and regard it as accurate when they are preparing a hazard evaluation for their facilities.

Each container of hazardous chemicals must have a Material Safety Data Sheet (MSDS) that lists hazardous components and provides information about health hazards, proper use, and emergency procedures. Containers also must have the following identification on the container, label or tag [29 CFR 1910.1200(f)(1)]:

  • The identity of the hazardous chemical
  • Appropriate hazard warnings
  • The name and address of the chemical manufacturer, importer, or other responsible party

If a chemical manufacturer or importer becomes aware of a new hazard, labels and information must be revised within three months.

In addition to the OSHA requirements for containers to be properly labeled, DOT also has requirements to ensure the safety of hazardous materials in transit. The labeling requirements of both entities must be adhered to.

Employer Responsibilities

After evaluating the chemical hazards present, a hazard communication plan can be created. Employers must create a chemical inventory and gather an MSDS for each hazardous chemical. As part of the plan, employers also must develop a program that describes how containers of hazardous chemicals at a facility will be properly marked so employees can eas ily identify the chemical and the hazards it presents. [29 CFR 1910.1200(f)(5)]

Employee training and education is critical to the full implementation of the Hazard Communication Standard. Documenting training plans and schedules for refresher training sessions in the written plan helps everyone know where responsibilities lie, and doing this also can provide a framework for keeping track of training certificates and other forms of communication relevant to the standard.

Written Programs

The facility's written hazard communication program must describe how containers will be labeled so hazards can be readily identified. Because all facilities are different and because hazard communication is a performance-based standard, OSHA does not specify what a label must look like, but it does need to be legible, in English, and "prominently" displayed on the container.

In Appendix E of the Hazard Communication Standard, OSHA advises, "the primary information to be obtained from an OSHA-required label is an identity for the material, and appropriate hazard warnings." The advisory also explains the "identity" may be a common or trade name or the actual chemical name.

In workplaces where employees speak another language, information in other languages may be added, but it may not replace the English wording. [29 CFR 1910.1200(f)(9)] Hazard warnings on containers may be words, pictures, symbols, numeric representations, or a combination of these.

Chemicals are commonly transferred from drums or bulk containers (which are properly labeled, of course) into smaller, more portable containers to be used by employees. Unless the chemical dispensed will immediately be used by the employee who dispensed it [29 CFR 1910.1200(f) (7)], the portable container also must be properly labeled. [29 CFR 1910.1200(f) (5)] Written plans should detail these responsibilities.

Many facilities choose to use the NFPA (National Fire Protection Association) or HMIS (Hazardous Materials Information System) labeling standards to communicate a chemical's hazard. Both systems utilize a numeric scale to identify hazard levels. Although neither format is required, both are well-established, systemized methods that can help with compliance and facilitate employee training. Many MSDSs list the numeric values associated with these two standards for facility coordinators to use on their container labels.

After deciding on a format for labeling, employers should designate someone with the responsibility of ensuring containers are properly labeled, information on labels is reviewed periodically, and there is a process for labels to be updated as necessary if chemical hazards change. This person's duties should be documented in the written plan.


OSHA requires any employee who may be exposed to hazardous chemicals to be educated about those hazards. The training must ensure that employees know:

  • That they may be exposed to a hazardous chemical or chemicals
  • What they need to do to protect themselves from exposure
  • How to read container labels and MSDSs
  • Where MSDS are stored and where to go to obtain more information

For employees who will transfer chemicals from drums or bulk containers, proper training includes the need to use labeled containers—unless the chemical will immediately be used by the person who dispensed it. Employees also need to understand why the container needs to be labeled and either how to label it properly or whom to go to so the container does receive proper labeling.

Some facilities choose to provide the same training for all employees. Others tailor training to different areas within a facility. For example, office workers typically don't face the same hazards as workers in a production area or those in a warehouse. Tailoring training to each area can help workers have a more realistic view of the particular hazards that are applicable to them.

Avoid the temptation to lump everyone into a given category. While a receptionists and accountants generally fall into an "office worker" category and typically don't venture around a facility too much, other "office workers"— such as quality assurance, laboratory technicians, or technical services members— may routinely visit production areas or warehouses and should be aware of hazards they could encounter in those areas. In addition to training, proper signage in hazardous areas serves as a good reminder for these individuals and for everyone else who "visits" an area.

When training receiving crews, help them understand the importance of receiving only properly labeled chemicals, and perhaps receiving only those on a specified inventory. To aid in this, some facilities choose to require suppliers to send MSDSs in advance so precautions can be taken before the new chemical arrives on site.

Sometimes, MSDSs are shipped with packing slips or are in boxes of materials. Consider establishing a protocol for these MSDS to be forwarded to the safety officer or whoever is in charge of updating labels and other hazard communication information for the facility.

Rounding Out Safety

The Hazard Communication Standard was created to keep employees safe. It is a far-reaching standard that encompasses the entire facility, and, as such, can seem to be overwhelming at times. But when employees are properly taught to understand this standard and how it helps to keep them safe, they are more inclined to make sure they are doing their part to ensure hazards are properly identified in their work areas.

A properly educated employee will know that all containers need to be labeled, what that label means to him, how to properly protect himself from hazards, and where to go for MSDSs and more information— some of the things that will satisfy a compliance officer.

This article originally appeared in the July 2009 issue of Occupational Health & Safety.

About the Author

Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer, and technical writer for New Pig. She has more than 24 years of experience helping EHS professionals find solutions to meet EPA, OSHA, and DOT regulations and has had more than 100 articles published on a variety of EHS topics. She can be reached at 1-800-HOT-HOGS® (468-4647) or by email, [email protected]

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