Why GHS Secondary Labeling Matters (and How to Get It Right)
Ever spotted a water bottle or Gatorade jug on-site filled with an unknown liquid? Maybe someone guessed what it was based on the smell, the color, or who used it last. Sound familiar?
It might seem harmless, but this kind of guessing game leads to real injuries—1 in 4 chemical-related incidents on job sites come from unlabeled or improperly labeled containers. That’s a big deal when you consider how often we transfer chemicals around throughout the day.
What Is a Secondary Container?
A secondary container is any container you transfer a chemical into for temporary use—like spray bottles, jugs, or even buckets. According to OSHA’s Hazard Communication Standard (HazCom 2012), if you don’t use it up right away, you must label it with a GHS chemical label so everyone knows if it contains hazardous materials. There are no exceptions to secondary container labels.
If it’s not labeled and someone else picks it up later, they won’t know what they’re dealing with—or how dangerous it might be. Labeling both primary and secondary containers containing hazardous chemicals is key to preventing injuries.
Why Secondary Container Labels Matter So Much
Hazard communication violations have ranked in OSHA’s top five safety citations year after year. And when secondary containers aren’t labeled correctly, workers are at risk for:
- Chemical burns
- Poisoning
- Respiratory problems
- Long-term health effects
These injuries aren’t just painful—they lead to missed work, workers’ comp claims, and serious regulatory fines. The risks are even higher in industries like construction and oil & gas, where job sites are busy, environments are tough, and materials get moved around constantly.
How Do We Stay Ahead of the Problem?
1. Label Primary and Secondary Containers Clearly
If you’re transferring a chemical and not using it immediately, it needs a compliant label. No exceptions. Use Globally Harmonized System (GHS) secondary labels that include:
- Chemical name
- Hazard warnings
- Relevant pictograms
This keeps everyone on the same page and safe from accidental poisoning or burns. We recommend matching the secondary container labels to the primary container labels for clarity. No matter which labeling system you use for secondary chemical containers, make sure the product identifier matches the one on the safety data sheet.
2. Use the Right Container
Don’t pour industrial chemicals or hazardous substances into leftover soda bottles or Gatorade jugs. It might seem convenient, but it’s a recipe for disaster. Always use containers designed for chemical storage—ones that are compatible, leak-proof, and clearly marked. This automatically prevents physical and health hazards.
3. Keep GHS Compliant Labels Clean and Legible
A label doesn’t help if it’s unreadable. Replace labels that are faded, smudged, or peeling. Make it easy for anyone to know exactly what’s inside—no guesswork.
4. Store Chemicals Properly
Prevent physical hazards by storing secondary containers in designated areas—away from heat, sunlight, or anything that could react. And never leave them lying around where someone might accidentally pick them up and use them incorrectly.
5. Train Everyone
Make sure your team knows how to label secondary containers, read GHS labels, and understand the symbols. If someone doesn’t recognize a hazard pictogram, they may not treat a chemical with the caution it deserves.
6. Do Regular Checks
Supervisors should make secondary labeling part of their routine site inspections. It only takes a minute to check that containers are labeled properly, but that minute could prevent an injury.
Pro Tips on Secondary Labeling From the Field
- If you’re only using a chemical for a quick task and plan to use all of it immediately, a label isn’t required. But if you leave any behind, you need to label it.
- Use weather-resistant labels on outdoor sites—rain or dust can destroy handwritten tags fast.
- Always create compliant labels–Keep extra GHS labels and markers on hand in your tool trailer or job box so there’s no excuse not to label.
Secondary labeling isn’t red tape—it’s real-world safety. A missing label might not seem like a big deal in the moment, but it’s one of the leading causes of chemical injuries on job sites.
Let’s keep things simple: If you transfer it—label it. Include necessary components, such as hazard statements and the chemical name. If you wouldn’t drink from it, don’t store chemicals in it. And if the label’s worn out, replace it before someone gets hurt.
Want to make labeling even easier? Consider using pre-printed GHS label templates or digital tools to generate them on the spot. Safety starts with the little things—and this is one of the easiest wins on the board.
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