Patrick W. Saltmarsh Tim Hunt, CHST Dir. of Envt’l, Safety Health and Safety Corporate Director W. J. L. Derenzo French Excavating Corp. Companies
GHS: Secondary Containers In 2012, OSHA revised the Hazard Communication standard. That revision included the addition of compliance with the Global Harmonized System (GHS). Material Safety Data Sheets (MSDSs) became Safety Data Sheets (SDSs), and the standardized form for SDSs was adopted. However, compliance with GHS is more than just Safety Data Sheets. We have all heard of the term “Right to Know,” which was created with the original standard, the revised version brought about the term “Right to Understand.”
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secondary container is any container holding a product that is not the original container supplied by the manufacturer. Three common causes of incidents or health effects that can be traced back to secondary container labels include: 1.
The material was not being used within the same work shift as the person who transferred from primary to a secondary container.
2. The person who oversaw the transfer left the work area. 3. The secondary container itself leaves the work area where it cannot be correctly identified. At a minimum, a secondary container label must include the full name of the chemical and the hazard. Secondary containers are usually smaller, such as spray bottles, jugs, and jars. A driver of whether a secondary container needs to be labeled is based on the term immediate use. Immediate use means that the hazardous chemical will be controlled and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred. To create a secondary container label, you need to start with the Safety Data Sheet. Every primary container containing hazardous chemicals should MARCH, 2022
arrive from the supplier with an OSHA-compliant Safety Data Sheet (SDS). The SDS will provide the information needed to create the secondary container label. You can find the product name in Section 1 of the SDS. Section 2 provides the pictograms, signal words, and any special hazard statements relevant to the secondary container label. Finally, the National Fire Protection Association (NFPA) and Hazardous Material Information System (HMIS) ratings can be found in Section 16. continued on page 58
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