GHS Secondary Container Labels: OSHA Guide

GHS labeling under OSHA HazCom is the standardized way hazardous chemical information appears on labels and Safety Data Sheets. If your team pours a hazardous chemical from its original shipped container into a spray bottle, bucket, jug, tank, or drum, the new workplace container usually needs a label. The practical rule is simple: If a hazardous chemical leaves its original container and will not be used up by the same worker in the same shift, label it.

You do not need a full-time safety department to get this right. You need the correct Safety Data Sheet (SDS), a label that identifies the product and communicates its hazards, a way for employees to reach the SDS, and training that makes the label useful. This guide explains each requirement in plain English and shows how to make a secondary container label from the SDS.

TLDR

GHS is a United Nations framework. In the United States, OSHA’s Hazard Communication Standard, 29 CFR 1910.1200, is the enforceable rule.
OSHA uses the term workplace container. Businesses often call the same item a secondary container.
A secondary container can use the full GHS label or a simpler workplace label that identifies the product and communicates its hazards.
The immediate-use exemption applies only when the employee who transfers the chemical uses it during that work shift.
Do not remove or deface an intact supplier label. If it becomes unreadable, relabel the container immediately.
The safest small-business process is to generate labels from the exact SDS instead of retyping hazard information.

Quick Answer: Under OSHA HazCom, employers must label workplace containers of hazardous chemicals unless a narrow exemption applies. A compliant secondary container label may reproduce the full shipped-container label, or it may show the product identifier plus words, pictures, symbols, or a combination that communicates the chemical’s hazards when used with information immediately available to employees.

TLDR
Table of Contents
What is GHS labeling under OSHA HazCom?
What is the difference between GHS and OSHA HazCom?
What is a secondary container under OSHA?
Do I need to relabel manufacturer containers?
Do I have to use full GHS labels on secondary containers?
Can I use a simplified workplace labeling system instead of GHS?
How do I make a compliant secondary container label?
Do spray bottles and squeeze bottles need GHS labels?
Do I need to label containers of water or non-hazardous liquids?
How does Helios Comply help generate secondary container labels?
Frequently asked questions
Sources

What is GHS labeling under OSHA HazCom?

GHS labeling is the standardized chemical hazard format OSHA incorporated into the Hazard Communication Standard. For hazardous chemicals leaving a manufacturer, importer, or distributor, 29 CFR 1910.1200(f)(1) requires six types of information: a product identifier, signal word, hazard statement or statements, pictogram or pictograms, precautionary statement or statements, and the responsible party’s name, U.S. address, and telephone number.

GHS stands for the Globally Harmonized System of Classification and Labelling of Chemicals. The United Nations publishes this framework for chemical classification, labels, and SDSs. OSHA first aligned HazCom with GHS in 2012 and updated the standard again in 2024, primarily to align with GHS Revision 7.

The six shipped-container elements answer these questions:

Product identifier: Which chemical or product is this? The identifier must correspond to the name used on the SDS.
Signal word: How severe is the hazard? OSHA uses “Danger” for more severe hazards and “Warning” for less severe hazards.
Hazard statements: What can the chemical do?
Pictograms: Which hazard types need immediate attention? OSHA designates eight pictograms for mandatory HazCom hazards. The ninth GHS environmental pictogram is not mandatory under OSHA.
Precautionary statements: How should a person prevent exposure, respond, store the product, or dispose of it?
Supplier identification: Who is responsible for the chemical, and how can that party be contacted?

A label is only one part of HazCom. Employers also need a written program, a chemical list, SDS access, and employee training. The label is the warning at the point of use. The SDS carries the longer explanation. Our guide to OSHA HazCom requirements for small businesses explains how those duties fit together.

Hazard Communication was the second most frequently cited federal OSHA standard in fiscal year 2025. That ranking does not mean every citation involved a missing secondary label, but it does show why a repeatable labeling process deserves attention.

What is the difference between GHS and OSHA HazCom?

GHS is an international framework published by the United Nations. OSHA HazCom is a federal workplace-safety regulation. A U.S. employer complies with 29 CFR 1910.1200, not with the UN publication by itself. OSHA decides which GHS revisions and hazard classes become part of the U.S. rule, so OSHA’s text controls when the two differ.

Question	GHS	OSHA HazCom
Who publishes it?	The United Nations	The U.S. Occupational Safety and Health Administration
Is it enforceable for a U.S. employer?	Not by itself	Yes, through 29 CFR 1910.1200
What does it cover?	A model for chemical classification, labels, and safety data sheets	Workplace duties for classification, labels, SDSs, written programs, and training
Which version applies?	The UN periodically publishes revised editions	OSHA adopts and modifies selected provisions through federal rulemaking
What should a U.S. business follow?	Use it as background	Follow the current OSHA standard and any applicable state-plan rule

OSHA’s 2024 final rule was published on May 20, 2024, took effect on July 19, 2024, and primarily aligned HazCom with GHS Revision 7. It also adopted certain Revision 8 methods for skin corrosion and irritation. During the tiered transition, regulated parties may follow the prior standard, the updated standard, or both. Check OSHA’s rulemaking page for the dates that apply to substances, mixtures, workplace labels, program changes, and training.

An imported product advertised as “GHS compliant” is not automatically enough for a U.S. workplace. Check it against OSHA’s HazCom rule and any applicable state-plan requirements. Required information must appear in English.

What is a secondary container under OSHA?

A secondary container is a workplace container into which a hazardous chemical is transferred from its original shipped container. OSHA’s rule uses “workplace container,” while many employers use “secondary container.” Spray bottles, buckets, pails, jugs, safety cans, mix tanks, and refilled drums can all fall into this category.

The distinction is about use, not size. Both a squeeze bottle and a stationary tank can be workplace containers after a chemical is transferred into them.

Issue	Primary or shipped container	Secondary or workplace container
Typical example	A solvent can received from the distributor	A shop bottle refilled from that solvent can
Who labels it?	The manufacturer, importer, or distributor before shipment	The employer that controls the workplace
Minimum label approach	Full elements required by 1910.1200(f)(1)	Full shipped-container label or the workplace alternative allowed by 1910.1200(f)(6)
Supplier contact information required?	Yes	Not under the alternative in 1910.1200(f)(6)(ii)
Can signs or process sheets replace the individual label?	Not as the general shipped-container rule	For stationary process containers, 1910.1200(f)(7) permits signs, placards, process sheets, batch tickets, operating procedures, or similar written materials if they identify the containers and convey the required information
Immediate-use exemption available?	No	Yes, but only under the narrow conditions in 1910.1200(f)(8)

Common examples include a cleaner in a spray bottle, solvent in an auto-shop bench bottle, coating in a jobsite can, sanitizer in a food-service bucket, and a chemical in a process tank. The employer must decide whether the material is hazardous in the form employees use and label it accordingly. See our guides to solvent and parts-washer labeling in auto shops and chemical labeling in manufacturing facilities.

Does the immediate-use exemption apply?

Did one employee transfer the hazardous chemical from a labeled container?
Will only that employee use the portable container?
Will that employee use it during the work shift in which the transfer occurred?

If any answer is no, label the container. A shared bottle, a bottle handed to the next shift, or a bottle stored overnight does not meet the exemption.

For a fuller treatment of edge cases, read when a secondary container label is required.

Do I need to relabel manufacturer containers?

No, not while the incoming label is intact and legible. Under 29 CFR 1910.1200(f)(9), an employer must not remove or deface an existing label on an incoming container unless the container is immediately marked with the required workplace information. Paragraph (f)(10) also requires workplace labels to remain legible, in English, and prominently displayed.

If a label fades, tears, gets covered, or becomes chemically damaged, identify the product from reliable records and the SDS library. Then apply a label that satisfies 1910.1200(f)(6). You may reproduce the supplier label, but the workplace-label alternative does not require all six shipped-container elements.

Never identify an unreadable container by color, odor, location, or memory. Isolate an unknown chemical under your site’s procedure. Required label information must appear in English under 1910.1200(f)(10), although other languages may be added. Organized physical SDS binder books can provide a paper backup for label information.

Do I have to use full GHS labels on secondary containers?

No. OSHA gives employers two choices under 29 CFR 1910.1200(f)(6). The workplace container may carry the same information required for a shipped container, or it may carry the product identifier plus words, pictures, symbols, or a combination that provides general hazard information and works with other information immediately available to employees.

The simplified option does not mean “write something close enough.” The product identifier must correspond to the SDS, and the label must communicate the hazards. If it gives only general information, immediately available resources and training must supply the specific physical and health hazard information.

OSHA’s June 20, 2017 interpretation letter confirms that paragraph (f)(6)(ii) does not require the manufacturer’s contact details, precautionary statements, or hazard statements. But an employer using a less complete system must show that employee awareness is at least as effective as it would be with complete health-effects information.

For a business without a safety specialist, the full GHS format is often easier to manage. A simplified label can fit a small bottle, but employees must still identify the chemical, understand the warning system, and reach the supporting information immediately. See the required GHS label elements in detail.

Can I use a simplified workplace labeling system instead of GHS?

Yes, on workplace containers, if the system meets 29 CFR 1910.1200(f)(6)(ii). HMIS or NFPA 704 may contribute to workplace labeling, but the complete program must communicate the chemical’s specific physical and health hazards. These alternatives cannot replace the full label for a shipped container.

NFPA 704 was designed primarily for emergency responders evaluating acute hazards during a fire, spill, or similar event. Its familiar diamond rates health, flammability, and instability from 0 to 4, with 4 indicating the highest severity. HazCom hazard categories run in the opposite direction, with Category 1 generally representing the most severe hazard. Never copy the category number from SDS Section 2 into an NFPA diamond.

OSHA’s comparison QuickCard explains another limitation: NFPA 704 covers acute health hazards, while HazCom communicates acute and chronic effects. An unsupplemented NFPA diamond can omit a chronic hazard such as carcinogenicity. Employers using HMIS or NFPA must check the system against the SDS and train employees on its colors, numbers, and letters.

For a small business, use a GHS-format workplace label generated from the SDS unless space makes it impractical. It gives new and temporary workers recognizable hazard language without requiring a separate rating method. A compact hybrid label can work when it identifies the exact product and states the hazards plainly.

How do I make a compliant secondary container label?

Start with the current SDS for the exact product in the container. Take the product identifier from Section 1 and the required label elements from Section 2, then print the label on stock that will remain attached and readable under actual working conditions. Apply it before an employee uses the container.

Locate the exact SDS. Match the product name, manufacturer, and formulation. Do not substitute a sheet for a similar product or concentration.
Copy the product identifier from Section 1. Keep it consistent with the SDS and your chemical list so employees can find the right sheet.
Read Section 2. It contains the hazard classification, signal word, hazard statements, pictograms, and precautionary statements.
Choose the format. Use the complete six-element label or the product identifier with hazard words, pictures, or symbols permitted by 1910.1200(f)(6)(ii). The shorter option depends on training and immediately available information.
Generate and review the label. Compare it with SDS Sections 1 and 2. Do not rephrase standardized hazard statements on a full GHS label.
Print for the work environment. Water, oil, solvents, abrasion, heat, and curved bottles can defeat office labels. See our guide to printing and distributing labels across your crew.
Apply the label before use. Put it where a worker can see it. Do not place it on a removable lid that could be swapped.
Inspect labels routinely. Replace unreadable labels and confirm that the corresponding SDS remains available.

Dilution may change a mixture’s classification, so do not automatically copy the concentrate’s label onto a use-dilution bottle. Use the manufacturer’s SDS or guidance for the diluted product. If the supplier has not classified the use dilution, get competent safety guidance rather than calculating a new classification from percentages alone.

Label information	Where to find it	Workplace note
Product identifier	SDS Section 1	Use the name that corresponds to the SDS
Signal word	SDS Section 2	“Danger” or “Warning,” when assigned
Hazard statements	SDS Section 2	Use the standardized wording on a full GHS label
Pictograms	SDS Section 2	Use the pictograms assigned to the product
Precautionary statements	SDS Section 2	Cover prevention, response, storage, and disposal as assigned
Supplier identification	SDS Section 1	Required on the full shipped-container format, not on the simplified workplace option

Common secondary container labeling mistakes

Using an abbreviation that does not match the SDS product identifier
Leaving a refilled container unmarked
Copying concentrate hazards onto a use dilution without supplier guidance
Using a HazCom category number as an NFPA 704 rating
Printing a label that falls off or becomes unreadable
Keeping the SDS where employees cannot immediately access it

Do spray bottles and squeeze bottles need GHS labels?

Usually, yes. A spray bottle or squeeze bottle filled with a hazardous chemical is a secondary container and needs a workplace label unless the immediate-use exemption in 29 CFR 1910.1200(f)(8) applies. The employee who transfers the chemical must be the person who uses it, and the use must occur during that employee’s work shift.

A janitorial employee who fills a bottle, controls it, and uses it during that shift may qualify for the exemption. A bottle placed on a shared cart, handed to another worker, or stored overnight does not. Label it.

Small bottles do not erase the requirement. A compact workplace label can use the product identifier with clear hazard words or symbols when the rest of the program supplies the specific information immediately. A QR code can open the full SDS, but it should supplement the visible warning.

Cleaning companies can also use pre-populated SDS books for cleaning products as part of a paper backup, while our HazCom guidance for cleaning companies covers broader inventory, access, and training needs.

Do I need to label containers of water or non-hazardous liquids?

HazCom workplace labeling applies to hazardous chemicals covered by 29 CFR 1910.1200. Plain water and a product that is not classified as hazardous are outside that labeling duty. Still, naming the contents of every workplace bottle is a sensible policy because an unmarked liquid invites mix-ups.

Do not assume a cleaner is non-hazardous because it is sold to consumers or described as mild. Check the exact product’s SDS, particularly Section 2, and consider how employees use it. The consumer-product exemption in 1910.1200(b)(6)(ix) is limited to products used in the workplace for the purpose intended by the manufacturer or importer when the duration and frequency of use are not greater than a consumer’s exposure.

If Section 2 says the product is not classified under HazCom, keep the SDS or supplier documentation. Marking the bottle “Water” or with the product name is simple housekeeping, not an admission that HazCom applies.

How does Helios Comply help generate secondary container labels?

Helios Comply connects secondary container label generation to the SDS library where the source information belongs. Instead of retyping product names, hazard statements, and pictograms from scattered PDFs, a small team can manage SDSs in the cloud, digitize paper records with AI-assisted extraction and classification, and generate GHS secondary container labels from organized product data.

QR code SDS access gives employees a direct route to the full sheet. Offline access supports crews without a reliable connection. Multi-location management helps an owner use one process across several shops or jobsites.

Software does not take over the employer’s legal responsibility. Your business still must identify hazardous chemicals, keep the correct SDSs, maintain its program, and train employees. Helios reduces the clerical work involved in turning SDS data into a printed label.

Start your free trial to organize SDSs and generate secondary container labels. If your binder or shared drive needs hands-on setup help, call (855) 920-5202.

Frequently asked questions

Do spray bottles need GHS labels?

A spray bottle containing a hazardous chemical normally needs a workplace label. Under 29 CFR 1910.1200(f)(8), shared bottles and bottles kept for a later shift do not qualify for the immediate-use exemption.

Do I need to label a bottle of water?

HazCom does not require a workplace label for plain water because it is not a hazardous chemical. Labeling the bottle “Water” is still good practice because it prevents confusion with cleaners, solvents, or other clear liquids.

Do I have to relabel the manufacturer’s container?

Not if the original label is intact and legible. Replace a damaged label promptly, but do not cover a usable supplier label merely to standardize its appearance.

Can I handwrite a secondary container label?

A handwritten workplace label can work if it is legible, prominently displayed, durable, identifies the product, and communicates the hazards. Abbreviations and fading ink can make it inadequate.

Can a QR code replace all text on a secondary container label?

A QR code is useful for opening the SDS, but an unlabeled code alone does not state the product identifier or provide general hazard information as required by 1910.1200(f)(6)(ii). Use the code to support a visible workplace label, not to hide the identity and hazards behind a scan.

Can I use NFPA or HMIS labels on secondary containers?

Yes, if the complete labeling and HazCom program communicates the chemical’s specific physical and health hazards and employees are trained on the system. NFPA 704 by itself can miss chronic health effects, so review the label against the SDS and add information where necessary.