Secondary container labeling is one of the most misunderstood — and most frequently cited — areas of OSHA's Hazard Communication Standard. If your employees ever transfer a chemical from its original container into a different bottle, bucket, or spray can, you need to understand these rules.
What Is a Secondary Container?
A secondary container is any vessel that holds a hazardous chemical that was transferred from the manufacturer's original labeled packaging. Common examples include:
- Spray bottles filled from bulk containers
- Mop buckets with diluted cleaning solutions
- Small jars of solvents taken from gallon cans
- Transfer drums at fueling stations
There is one important exception: if the employee who transfers the chemical uses the entire amount during their shift and the container remains under their control the entire time, a secondary label is not required. The moment that container is set down and could be picked up by another worker, it must be labeled.
What Must a Secondary Label Include?
Under OSHA's HCS 2012 (and continuing into the GHS Rev 7 update), a secondary container label must include at minimum:
- Product Identifier: The name of the chemical that matches the SDS (e.g., "Acetone" or "Simple Green All-Purpose Cleaner").
- Hazard Information: Words, pictures, symbols, or a combination that provides at least general information about the hazards of the chemical.
You do not need to reproduce the full GHS label (with all pictograms, signal words, hazard statements, and precautionary statements) — though doing so is considered best practice.
Common Mistakes to Avoid
Writing Just the Chemical Name
Writing "Brake Cleaner" on a spray bottle with a marker satisfies the product identifier requirement, but it does not satisfy the hazard information requirement. You need at minimum a hazard warning alongside the name.
Using Internal Codes
Labels that say "Solution B" or "Blue Stuff" are not compliant. The product identifier must match what's on the SDS so any employee can look up the safety information.
Ignoring Diluted Solutions
Many employers assume diluted cleaning chemicals don't need labels. If the diluted solution still presents any hazard — even mild skin irritation — it requires a label.
Label Format Options
OSHA gives employers flexibility in how they label secondary containers. Here are the three most common approaches:
Option 1: Printed GHS Labels
The gold standard. Print a label with the product name, relevant GHS pictograms, and key hazard statements. This is what SafeSheet's label generator creates automatically.
Option 2: HMIS or NFPA Labels
Many employers use the familiar HMIS (colored bar) or NFPA (diamond) rating systems. These are acceptable as long as employees are trained to read them.
Option 3: Handwritten Labels
Technically acceptable if they include both the product identifier and hazard information. However, handwritten labels fade, smear, and become illegible — especially in wet or oily environments.
During an OSHA inspection, illegible labels are treated the same as missing labels. If the inspector cannot read the label, you will be cited. Consider waterproof printed labels for any container in a wet or chemical-heavy environment.
Best Practices
- Standardize your approach. Pick one labeling method and use it consistently across all locations.
- Print, don't write. Printed labels last longer and are always legible.
- Match your SDS. Every label should reference a product name that has a corresponding SDS in your system.
- Audit monthly. Walk the floor once a month and check for faded, missing, or illegible labels.
- Use a digital tool. Platforms like SafeSheet let you generate compliant labels directly from your chemical inventory with one click.