RTK Law - Secondary Container Requirements
All hazardous chemicals introduced into the workplace by employers and used by employees, shall be in labeled containers that meet the requirements of OSHA's Hazard Communication Standard (29 CFR 1910.1200).
It is important to understand that the RTK Law recognizes two types of containers and labels: primary and secondary. A primary label is one that is prepared by the manufacturer of the chemical and is affixed to all containers of this chemical before it is shipped to buyers. These labels are required to meet all of the requirements established under the RTK Law, therefore, the employer/buyer would be in full compliance if they elect to rely on the primary labels supplied by the manufacturers.
The primary container's label must include the following information:
- Identity of the chemical;
- Appropriate hazard warnings; and
- Name & address of the manufacturer, distributor, or responsible party.
If an employee transfers material from a primary container into another container which will be used only in that facility, that container is called a secondary container. Their labels must include:
- Identity of the chemical; and
- Appropriate hazard warning.
Temporary secondary containers (beakers, flasks) in laboratories shall be labeled with the name of the chemical and date of filling as a minimum. The name of the chemical (its identity) on either label (primary or secondary) should always match the identity on the MSDS.
Appropriate hazard warnings on container labels should always address any immediate hazards, such as flammability or corrosivity. These are properties which could have an immediate effect if the chemicals are mishandled.
- Route of exposure
In addition, any known chronic (long term) hazards (depending on the severity) should also be addressed on container labels.
- Birth defects
- Target organs
- Body systems affected