Chapter 3: Development of Protocols
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Chapter 3.E. Labeling Secondary Containers
Introduction
Secondary or portable containers are those into which chemical products are transferred from the
original container or dispensing station for use throughout the building. Typically, custodial staff
members fill spray bottles of each product from a dispensing station and put them on their
cleaning cart. Some vendors provide labels for spray bottles with all of the required product
information.
When labels are not supplied, these spray bottles are often haphazardly labeled with marker or
tape, or not labeled at all. They can often be found inadequately labeled on the cleaning cart or in
rooms throughout the building if they were left behind by the custodian or were distributed to
teachers. This practice becomes an “accident waiting to happen.” In the case of exposure, there is
no health and safety information and the chemical is essentially an “unknown.”
Requirements
The Massachusetts Right to Know Law and the OSHA Hazard Communication Standard require
that secondary containers be labeled with the name of the product and the appropriate hazard
warning as specified below. Copies of the product’s label, or spray bottles that have the
manufacturer’s or distributor’s information printed on them may be obtained.
Required label information for secondary containers:
The brand name of the hazardous chemical (if the container is original) or the name
as listed on the material safety data sheet (MSDS; if the container is secondary).
Hazard warnings, listing
health hazards
such as effects on target organs and systems
(heart, liver, kidneys, nervous system, etc.) and
physical hazards
such as whether the
chemical is flammable, corrosive, or reactive.
Optional label information for secondary containers:
The name, date, and initials of who diluted the solution to track its expiration date.
Expiration dates can be found on the manufacturer’s label.
Hazardous Materials Identification System labels. These labels provide a good “at-a-
glance” warning to alert workers of the degree of hazard, particularly for those who
do not speak English.
Old Version
Revised Version – 2001
Health
Flammability
Reactivity
PPE
Health
Flammability
Physical Hazard
PPE (personal
protective equipment)