OSHA’s Requirements for Secondary Labeling of Chemical Containers

The US Occupational Safety and Health Administration (OSHA) requires all chemical containers in a dental office to be labeled with either the original (primary) manufacturer’s label or a secondary label. A color-coded system is not required.

If a chemical is transferred from the original (primary) manufacturer’s container to a different container, the container must be labeled with a secondary label. The secondary label must include the “product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.”

Because the regulation is somewhat vague as to what exactly must be on a secondary label, to ensure compliance, a simple way to label a secondary container is to photocopy or take a picture of an original label and affix the copy to the secondary container. Another method is to print the required information, laminate it, and affix it to the secondary container. Handwritten legible labels are also acceptable.

The most important thing to remember is that labeling is an ongoing duty—all containers of hazardous materials must always be labeled. Therefore, it is important to designate someone responsible for ensuring that the labels are maintained on the containers in your office and that newly purchased materials are checked for labels before use.

For our OSHA Review subscribers… please refer to the July/August 2023 Training Document, which covers hazard communication, in Section VI of your OSHA Review binder, for more detailed information on chemical labeling requirements in a dental office.

OSHA Review, Inc. a registered continuing education provider in the State of California, specializing in Dental Practice Act, infection control, and Cal/OSHA training. OSHA Review subscribers in California receive updated regulatory compliance and infection control training thorough our bi-monthly newsletter.