Chemical container labeling is one of the most effective and efficient ways to communicate hazard information to your workers and coworkers and prevent accidents and injuries.

Clear and consistent labeling that follows the Labels Under Texas Hazard Communication Act (THCA), Chapter 502 of the Texas Health and Safety Code and UH Chemical Hygiene Plan is required in all University of Houston laboratories, shops, clinics, and other locations where employees use, store, and transport chemicals.

Chemical manufacturers are required to follow labeling requirements on the original container labels, and the users of these chemicals are also required to follow labeling requirements when they transfer chemicals to secondary containers (also called “transfer vessel”), or label chemical waste bottles.

The basic requirements for labeling chemicals and template for creating labels are discussed in the sections below.

• Original Manufacturer Labels
• Secondary Chemical Container Labels
• Secondary Container Label Templates and Printed Copy Request Form
• Waste Labels
• Chemical Container Labels for Shared Space

Original Manufacturer Labels

As of December 1, 2015, all original labels provided by the manufacturers or distributors of hazardous chemicals will be required by OSHA to be Globally Harmonized System (GHS) compliant. GHS compliant labels will have pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification. The label on an original chemical container must be legible and written in English. Do not accept materials if the label is illegible or missing required information. (See example of original label below)

Avoid damaging the original container’s label, if possible. If a container label becomes damaged or is no longer readable, a new label must be prepared in compliance with the Labels Under Texas Hazard Communication Act.

Secondary Chemical Container Labels

Many University workplaces, including laboratories, shops, and other facilities, purchase hazardous chemicals or products in different quantities and concentrations, or for mixing with other chemicals. Sometimes the chemical may need to be transferred to a smaller or different “secondary” container (e.g., vials, flasks or bottles) for dilution, mixing, or general use.

If you transfer a hazardous chemical into a secondary container, the secondary container must be correctly labeled to ensure workers are readily aware of the contents and understand the hazards.

The Labels Under Texas Hazard Communication Standard requires secondary chemical container labels contain at least the following information:

• the identity appearing on the Safety Data Sheet (SDS) (i.e., product/chemical names)
• the appropriate hazard warnings (e.g., “flammable”, “corrosive”, “irritant”)

The hazards may be expressed through words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of chemicals. The hazard information can be found on the original container, or from the SDS.

It is the best practice to label the secondary container with the name of the person preparing it and the date of preparation. The label can also include additional information, such as the composition of chemicals and percent concentration in the container, the date the chemical was received, the date a container was opened (if the chemical could degrade or react over time), or any other information useful for safe and efficient use.

Employees in the workplace must be able to readily understand the chemical and hazard information on a secondary container label.

Abbreviations or Acronyms

Abbreviations or acronyms should be avoided. However, if you use any abbreviations, lab must hang up a “key/explanation” to the abbreviations in a visible location (preferably close to the chemicals and/or by the door). The “key/explanation” must contain the abbreviation and the name of the chemical. Including the hazards of the chemical on the “key” is also useful information.

The abbreviations should be understood by all lab personnel, and the key/explanation must be readily available upon request by visitors, emergency responders, EHS and state and federal regulatory agencies.

Small Containers and Sample Storage

For small containers, such as vials and Eppendorf tubes, which may be too small to write out a chemical name, structure, or formula, laboratories can implement other systems to identify the chemicals such as:

• Placing the vial or small container in an overpack container such as Ziploc bag, beaker, vial/test tube rack, basket, box, tray, etc., and labeling the overpack container with the chemical name.
• Laboratories can use “price tag” style labels or paper tag in which the chemical name is written out on a tag, and the tag is then attached to the small container with string, wire, or a rubber band.

Secondary container labels are not required if both of the following apply, but still encouraged:

• The reagent, stock solution and chemicals mixed for use are under the direct control of the person who transferred or prepared it, and
• The container will be emptied during that person’s work shift.

Secondary Chemical Container Label Templates and Printed Copy Request Form

EHS has prepared a secondary chemical container label template for your use. The template is formatted for printing on Avery Template 5163 (2” x 4” label, 10 labels per page, 8½” x 11” page).

The template can be resized to fit smaller containers. The example photo below can also be used to make labels in bigger sizes.

Waste Labels

Visit the EHS Waste Labels webpage for requirements on waste labels and about pickup and disposal of hazardous chemical waste.

Chemical Container Labels for Shared Space

In a shared laboratory space, chemical storage cabinets, including general cabinets, storage cabinets under the fume hoods, flammable safety cabinets, and refrigerators, shelves, etc., should be labelled by PI’s last name for easy identification. If chemicals are stored in a shared cabinet or area (e.g. fume hood or working bench), PI’s last name should be labelled on each bottle of the chemical or chemical waste, including the secondary containers.

PIs in a shared laboratory/space should meet regularly to discuss safety expectations in the shared space and any concerns, such as housekeeping expectations, laboratory staffing schedules, protocols for sharing chemicals and equipment, etc.