Compliance tips from our experts

By: October 14th, 2013 Email This Post Print This Post

From time to time, we get questions from our readers asking for clarification on some of OSHA’s regulations. As we get closer to the December 1 deadline to be in compliance for the Global Harmonization System, there is bound to be some confusion. Here’s a question from a clinic in Pennsylvania about labeling bottles, and an answer from our expert, Marge McFarlane.


“I would like to know if it is OK to pour cleaning solutions into clear refill bottles and if so, would it be enough to label these bottles with just the name/type of cleaning solution?”


“It is permissible to fill a second container with cleaning chemicals, however the Hazard Communication Standard requires that the secondary containers have all the hazard information off the original label.
The label is intended to be an immediate visual reminder of the hazards of a chemical. Any warning statements and precautions need to be on the secondary label. The only exemption is when the employee uses the container for their shift only and never leave the bottle unattended. I do not see this scenario often with cleaning solutions.

Labeling needs to include the chemical name that matches the MSDS or newer Safety Data Sheet (SDS). Warning statements include information such as “warning” or “danger” and any target organs affected, such as “inhalation may cause lung damage.”


By Judy Ruggeri on October 14th, 2013 at 9:02 pm

I was under the impression the Dec 1 deadline was for training employees on the new system. We are able to use are old labels until the final phase in 2015.

By John Palmer on October 15th, 2013 at 9:01 am

Hi Judy –

That is true, yes. You may use the old labels until 2015, but the new ones will be popping up before then as well. So, yes, you need to train your employees by Dec. 1 to recognize both labels. I’m sorry if that was misleading and thank for reading!



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