Secondary or Repackaged Container Labeling in the Laboratory
Posted on Fri, Oct 23, 2009 @ 07:21 AM
By Bret Skinner, Technical Specialist
In
this day and age, there are many regulatory agencies that demand the
proper labeling of commercially available chemicals and their
containers. In particular, the OHSA HAZCOM standard requires that
hazardous chemicals be marked with the chemical names and also a
universal method to communicate the hazards involved with such a
chemical. This communication is usually achieved with symbols or a
universal scale such as the Hazardous Materials Identification System
(HMIS), or the NFPA 704 diamond which uses a scale of 1-4 to
communicate the severity of a chemical’s health hazards, flammability
and reactivity. However, what labeling requirements are there for
solutions prepared or repacked in secondary containers by laboratory
personnel?
OSHA HAZCOM has no specific standard for the labeling of
secondary containers, however many letters of interpretation have
stated that these containers have the same labeling requirements as
commercial chemical containers. What does this mean? The common
laboratory practices of labeling prepared chemical solutions with lab
tape or marker may only comply with HAZCOM if it accomplishes the
demands of the standard in that: the labeling identifies the chemicals
in the container, and that the labeling effectively communicates the
hazards of the chemical. Common chemical abbreviations seen every day
in the laboratory setting such as “NaOH” or “HCl” may not comply with
the standard. Although these abbreviations communicate both the
chemical and its hazards to trained laboratory personnel, would
custodial staff or a firefighter necessarily know what these items
were? Also, would custodial personnel know how to initiate a proper
response to an emergency involving these chemicals? If the answer is
not “Absolutely” then one has not met their HAZCOM requirements.
So what can be done? It is often not practical to get
every person in every lab to properly label every chemical container
every time. Therefore EH&S departments must help develop systems
that will aid laboratory personnel to accomplish the HAZCOM standards
as easily as possible so that they may continue to do their job:
research.
Some easy solutions to aid with proper labeling of secondary chemical containers:
• Purchase commercially available secondary containers that meet the OHSA standard (see attached photo).
• Work with personnel in order to learn what chemical
preparations are in use in their laboratory. Make a list, and create
preprinted labels that meet the standard and are easy to use. One could
even create a database of the labels and attach it to a website for
easy access.
• Ask your chemical manufacturers for extra labels that meet the standards and apply them to secondary containers.
• Training, training, training! Usually, everyone is willing to
help with these safety issues. Giving personnel correct knowledge of
the standards can make these very intelligent people into valuable
safety tools.
NFPA 704 diamond for Sodium Hydroxide (NaOH)
Wash Bottles with NFPA Diamonds.