Perhaps you recall an article from one of our recent newsletters entitled “Fatal Thirst.”  It is a tragic story about a man who drank blue liquid out of a Gatorade bottle.  The bottle had the drink label on it but after swallowing half a mouthful, the worker realized he had ingested a highly toxic metal-aging chemical.  He died soon after the incident.
 
One of the most frequently cited OSHA regulations is the Hazard Communication standard. This standard outlines many important aspects with regard to how employers communicate with employees (and downstream customers) the hazards of materials they produce and use.  As in the example above, we frequently deal with citations involving inappropriate, inadequate, or non-existent labeling of secondary containers.  A secondary container is one which a hazardous material is transferred into, typically for ease of use (e.g. repackaging of a cleaning solution into a spray bottle).  The hazard communication standard states that the label must meet the following criteria:
 
•  Identify the container contents;
•  Have appropriate hazard warnings, words, pictures, and/or symbols which provide at least general information regarding the hazards; of the chemical; and
•  Labels must be legible, in English (plus other languages, if desired).
 
The hazard warning can be words, pictures, symbols, or combination of all.  The warning must provide at least general information regarding the hazards of the chemicals, which in conjunction with the other information is immediately available to employees. Under the hazard communication program, employees need to be provided with the specific information regarding the physical and health hazards of the hazardous chemical.  “Other information” includes the product MSDS, technical documentation and specific operating procedures established by the employer. 
 
There are two exemptions to the labeling portion of the Hazard Communication standard.  One of these exemptions allows for employers to use written materials that contain the information listed above. This material needs to be readily accessible to employees and specifically identify the stationary container(s) to which the information is applicable.  The other is an exemption for containers into which hazardous chemicals are transferred from labeled containers, and are intended only for the immediate use of the employee who performs the transfer.  In this context immediate use means within the shift the material was transferred.  Due to the specificity of these exemptions, it is the opinion of Hellman & Associates Inc. that labeling of secondary containers is the most effective method of compliance.
 
Hellman & Associates is now able to print labels for our clients.  Should you need a standard or a customized NEC or ANSI label, we can provide it for you – quicker and less expensive than commercial printers.  Please contact us or inquire through our “Ask The Expert” tab on our website.