Environmental, Health and Safety Services

Container Labeling and Other Forms of Warning

The HazCom Coordinator or designee shall ensure primary and secondary hazardous chemical containers are properly labeled. All labels and warnings should be legible, written in English and prominently displayed on the container.

Primary or Original Manufacturer’s Labels

Chemical manufacturers, importers, or distributors are required by OSHA to label, tag or mark each container of hazardous chemicals with the following label elements after they classify the hazards of the chemical. Virginia Tech employees must understand how to read and follow chemical labels. Each label has five (5) key elements in addition to manufacture information:

  • Name, Address and Telephone Number of the chemical manufacturer, importer or other responsible party.
  • Product Identifier (how the hazardous chemical is identified) can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier is found both on the label and in section 1 of the SDS for any given chemical.
  • Signal Words alert the reader to the relative severity of hazard posed by that chemical. There are only two words used as signal words, "Danger" and "Warning." Within a specific hazard class, "Danger" indicates a more severe level of hazard, and "Warning" indicates a less severe level of hazard. There will only be one signal word on the label no matter how many hazards a chemical may have. If a chemical has more than one hazard and one of the hazards warrants a "Danger" signal word, then "Danger" should appear on the label, even if it’s other hazards warrant the "Warning" signal word.
  • Pictograms are graphic symbols used to communicate specific information about the hazards of a chemical. OSHA requires chemical hazards be conveyed via pictograms on primary labels. Each pictogram is determined by the specific OSHA hazard classification(s). See OSHA’s nine pictograms and corresponding hazards in the following table below.
  • Hazard Statements describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. For example: "Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin." The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards no matter what the chemical is or who produces it.
  • Precautionary Statements describe recommended measures to minimize or prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling. There are four types of precautionary statements:
    1. prevention (to minimize exposure)
    2. response (in case of accidental spillage or exposure, emergency response, and first-aid)
    3. storage
    4. disposal
  • Labels on incoming containers must not be defaced or removed until the container is empty. If the label becomes faded, illegible or destroyed they should be replaced and remain durable, legible, and firmly affixed to the container(s).

    The example label depicts the use of all labeling elements:


    Secondary or Alternative Labeling

    The following guidelines summarize the secondary or alternate labeling options available:

    1. Creating Your Own Container Labels:
      • The full chemical or product name(s) (as it appears on the SDS) and the primary or general hazard can be written directly on the container or written/printed on a label to be affixed to the container.
      • For common chemicals/chemical products, you can use:
        1. An abbreviation or trade name that is commonly used and easily recognized
        2. A standard chemical formula (not structural formula) that is commonly used and easily recognized
      • Always include the primary or general hazard, (FLAMMABLE, for example) which can be written directly on the container, or written/printed on a label to be affixed to the container.
      • If a container is too small or identity name is too large, a codified name may be used on the container when defined in a notebook or reference sheet that is accessible to all. When many chemical names are needed, readily accessible notebook references may be used and primary hazards must also be communicated in the notebook or in the general work space using word, symbols or pictograms.
      • You can even include the five label elements as used on primary labels. However, secondary workplace container labels do not require inclusion of the five label elements.
      • The primary or general hazards can placed on container labels using words, pictures, symbol or a combination of these that provide general information about the hazards of the chemical.
    2. Using Existing Workplace Container Labeling Systems:
      • Examples: National Fire Protection Association (NFPA) or Hazardous Materials Identification System (HMIS); the new Globally Harmonized System of Classification and Labeling (GHS) is also available.
      • Any rating system can continue to be used as long as employees have immediate access to the specific hazard information (typically via safety data sheets or container labels) associated with the hazardous material(s). Task-specific training must be provided to ensure that all employees are fully aware of the hazards of the chemicals used, and how to correctly interpret the hazard rating system in use.
      • IMPORTANT: Note that the hazard severity ranking within the NFPA and HMIS systems is opposite from the newer OSHA hazard classification severity rankings. NFPA diamonds and HMIS labels range from 0 to 4 where 4 is the most severe. These labels use general hazard groups (flammable, health hazard and reactivity or physical hazard). OSHA hazard classification rankings use 1 as the most severe category of a given hazard classification and are more specific hazards.
    3. Secondary Labeling Requirements:
      • Every label must convey the required information clearly, legibly and in English. Where other languages are spoken in the work area, information may be presented on labels in other languages in addition to the required English words. Virginia Tech does not mandate any single labeling system.
      • There are currently many labeling (marking) systems in use. The best programs utilize a simple system that is readily recognizable and easily understood. Any worker should be able to quickly identify the general hazard of a material and the severity of the hazard by glancing at the label.

Transfer Containers

  • When hazardous chemicals are transferred from a labeled container to a portable container that is only intended for immediate use by the individual who performs the transfer, no labels are required for the portable container. However, it is best practice to always label secondary containers in the event the user is distracted or a spill occurs. Labeling will eliminate confusion where there are more than one (unlabeled) containers in use, and ensure that container content is known in the event of an emergency where outside personnel may be involved.
  • Transfer container labeling must include the name of the substance and hazard warnings in a manner consistent with your work areas established alternative workplace labeling system.