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Scenario: If I have ultrasonic solution in its original container and then I place the solution in the Ultra Sonic do I need to place a label on the Ultra Sonic stating it has Ultra Sonic Solution in it? I recently attended a seminar in which this was stated. I understand labeling if the solution is placed in a different container but just need clarification. Do you know if this is a new standard or an interpretation? I am not finding anything in writing. Please advise.

Ask OSAP believes that what you are possibly referencing is related to the US Department of Labor – Occupational Safety and Health Administration’s (OSHA’s) Hazard Communication Standard (HCS). Information contained in OSHA’s frequently asked questions includes:

What are the container labeling requirements under HAZCOM?

Under HCS, the manufacturer, importer, or distributor is required to label each container of hazardous chemicals. If the hazardous chemicals are transferred into unmarked containers, these containers must be labeled with the required information, unless the container into which the chemical is transferred is intended for the immediate use of the employee who performed the transfer. ¹

And the standard itself states:

1910.1200(f)(8)

The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. For purposes of this section, drugs which are dispensed by a pharmacy to a health care provider for direct administration to a patient are exempted from labeling. ²

Further general information pertaining to the Hazard Communication Standard can be accessed on the OSHA website at this link:

Hazard Communication
https://www.osha.gov/dsg/hazcom/index.html ³

If you have further questions regarding this matter, Ask OSAP recommends that you contact your area OSHA office. Please note that there may be varying requirements in those states with State OSHA Programs. Further information about State OSHA Programs can be accessed at:

http://www.osha.gov/dcsp/osp/faq.html ⁴

Resources

1- US Department of Labor – Occupational Safety & Health Administration. Frequently Asked Questions: Hazard Communication (HAZCOM). https://www.osha.gov/html/faq-hazcom.html#faq3 Accessed on October 15, 2014.

2- US Department of Labor – Occupational Safety & Health Administration. Hazard Communication Standard.https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099 Accessed on October 15, 2014.

3- US Department of Labor – Occupational Safety & Health Administration. Hazard Communication. https://www.osha.gov/dsg/hazcom/index.html Accessed on October 16, 2014.

4- US Department of Labor – Occupational Safety & Health Administration. Frequently Asked Questions about State Occupational Safety and Health Plans. http://www.osha.gov/dcsp/osp/faq.html Accessed on October 15, 2014.

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