Labeling Requirements

In 2015, OSHA became aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), which is an international approach to standardizing classification of hazards, and labeling. The GHS standardized label elements, which are not subject to variation and must appear on the chemical label, contain the following elements:

• Product name
• Signal word
• Pictograms
• Hazard statement(s)
• Precautionary statements
• Manufacturer name, address, and telephone number

For chemicals purchased prior to 2015 the labels on primary containers must have at least the following components:

• The name of the chemical as it appears on the Safety Data Sheet.
• Warnings about any physical and health hazards.
• The manufacturers name and address.

When using material directly from the manufacturer bottle, consider adding:

• Date when it was obtained,
• Date when it was opened,
• Date of expiration, if possible

When working with peroxide formers, it is also important to add the date the chemical is tested for peroxides. For more information on peroxide formers, see Chemical Hazards sections.

Non-Original Containers

Transferring a chemical from an original container into a non-original container such as wash bottles, squirt bottles, temporary storage containers, beakers, flasks, bottles, vials, etc. or any container must be properly labeled. All containers must have a means of communicating their content and the hazards of the content either on the container or in the area where the container is stored. Containers must comply with these labelling requirements if any of the following events occur:

• The material is not consumed within the work shift of the individual who makes the transfer.
• The personnel who made the transfer leaves the work area.
• The container is moved to another work area and is no longer in the possession of the personnel who filled the container.

In general, RMS recommends writing out the full chemical name and any hazards associated with that chemical.  Labels on secondary containers must be maintained and not defaced and have at least the following components:

• The name of the chemical
  • Either as it appears on the SDS or if using a short-hand name or abbreviation for the chemical, make sure this is documented in a key that is located in your lab or easily accessible in your laboratory notebook. If you are graduating or leaving your lab, please make sure this key is given to the Chemical Hygiene Officer.
• The name or initials of who that chemical belongs to.
• Warnings about any physical and health hazards, which may be expressed through words, pictures, symbols, or a combination of these.
• The date it was transferred to that container.
• Small Containers - For containers, which may be too small to write out a chemical name, structure, or formula, laboratories can:
  • Place containers in any type of overpack container (beaker, plastic bottle, etc.) and label the overpack with the chemical name and its hazards.
  • For vials in a rack, label the rack with the chemical name and its hazards.
• Date of expiration, if possible

Use of abbreviations such as structures, formulas, or acronyms should be avoided whenever possible. However, if abbreviations are used, an abbreviation key in a visible location (preferably close to the chemicals or in laboratory notebook) should be provided. The key must contain the abbreviation and the name of the chemical. It is also useful to include the hazards of the chemical on the “key.” The abbreviation key must be readily available upon request by RMS and emergency responders. If you are graduating or leaving your lab, please make sure this key is given to the Chemical Hygiene Officer.

• Teaching Samples - For preserved specimens in bottles, bags, or other containment units, the container must list the preservative and its hazards (ex: 70% Ethanol, Flammable and Toxic).
  • Any samples generated for teaching should be disposed of before the end of the semester. Teaching samples should NOT be left in the laboratory. It is the responsibility of the Laboratory Supervisor or Instructor of Record to ensure that these samples are appropriately disposed of.
  • If samples are labelled as “Unknown A,” or “Unknown B,” for teaching purposes, a key must be kept by both the Laboratory Supervisor or the Instructor of Record. These samples at the end of the semester should be relabeled for their actual chemical name or properly disposed of.
• Research Samples - Should be stored on shelves, in boxes, or racks that are labeled with the preservative and its hazards. If individual samples taken out of storage areas for processing that will be left unsupervised, they must have a label listing the preservative and its hazards.

When synthesizing (both known and novel) compounds and storing samples, individual containers, like vials, should AT LEAST contain the name of the chemical or synthesized product and the name or initials of the person who made it.

When synthesizing or storing a large number of samples (of same hazard class and compatibility), consider work area labeling. Work area labeling includes:

• Many samples of vials with the same hazards
• Anything too small to support a label
• Containers of the same hazard class stored together in a bin

The work area label would include similar information as above like the name of chemical (if all samples are the same), name or initials of who it belongs to, and the hazard class associated with those chemicals.