A full GHS label has six elements: product identifier, signal word, hazard statements, pictograms, precautionary statements, and supplier identification. OSHA requires all six on shipped hazardous chemical containers under 29 CFR 1910.1200(f)(1). A secondary container kept in your workplace may use that full label or OSHA’s workplace-label alternative.
That distinction is the key to checking spray bottles, buckets, and transfer jugs correctly. A copied supplier label is one option. A simpler in-house label can also comply if it identifies the product and communicates the hazards through a system employees understand. See the full secondary container labeling requirements for the broader decision process.
Quick Answer
Under 29 CFR 1910.1200(f)(1), shipped-container labels need all six GHS elements. Under paragraph (f)(6), a workplace secondary container may instead show the product identifier and hazard information through words, pictures, symbols, or a combination. The right option depends on whether the container is shipped or remains under your workplace HazCom program.
Table of Contents
- What are the six required elements?
- What do the nine pictograms mean?
- How are Danger and Warning different?
- How do hazard and precautionary statements differ?
- What must a workplace label contain?
- How do you audit a label?
- How does Helios Comply help?
- What else should facility managers know?
- Sources
What are the six required elements of a GHS label?
A shipped hazardous chemical label must show the product identifier, signal word, hazard statements, pictograms, precautionary statements, and responsible-party information. These requirements come from 29 CFR 1910.1200(f)(1). Paragraph (f)(2) also requires the label to be legible, prominently displayed, and in English, although other languages may be added.
|
Element |
What it communicates |
SDS check |
|
Product identifier |
The name or code connecting the container to one SDS. |
Section 1 |
|
Signal word |
“Danger” or “Warning,” when the classification requires one. |
Section 2 |
|
Hazard statements |
Standardized descriptions of the chemical’s hazards. |
Section 2 |
|
Pictograms |
Red-framed diamonds for applicable hazard classes. |
Section 2 |
|
Precautionary statements |
Prevention, response, storage, and disposal measures. |
Section 2 |
|
Supplier identification |
Name, address, and phone number of the manufacturer, importer, or responsible party. |
Section 1 |
The identifier must match the SDS, not just a floor nickname such as “blue degreaser.” Supplier information is required on shipped-container labels, but not on the alternative workplace label in paragraph (f)(6). OSHA ranked Hazard Communication second on its fiscal year 2025 Top 10 list, so unreadable or missing labels deserve attention during routine floor walks.
What do the nine GHS pictograms mean?
GHS uses nine pictograms. OSHA enforces eight under HazCom when the chemical classification calls for them. The environment pictogram is not required under OSHA HazCom. It may appear as supplementary information. Always use SDS Section 2 rather than selecting a pictogram based on what a product looks like or how workers usually use it.
|
Name |
Symbol description |
Hazards shown on OSHA 3491 |
|
Health hazard |
Person with chest starburst |
Carcinogenicity, mutagenicity, reproductive toxicity, respiratory sensitization, target organ toxicity, aspiration toxicity |
|
Flame |
Flame |
Flammables, pyrophorics, self-heating chemicals, emits flammable gas, self-reactives, organic peroxides, desensitized explosives |
|
Exclamation mark |
Exclamation point |
Irritation, skin sensitization, harmful acute toxicity, narcotic effects, respiratory tract irritation |
|
Gas cylinder |
Horizontal cylinder |
Gases and chemicals under pressure |
|
Corrosion |
Liquid damaging a hand and metal |
Skin burns, serious eye damage, corrosive to metals |
|
Exploding bomb |
Bursting object |
Explosives, self-reactives, organic peroxides |
|
Flame over circle |
Flame above a circle |
Oxidizers |
|
Skull and crossbones |
Skull above crossed bones |
Fatal or toxic acute toxicity |
|
Environment |
Dead tree and fish |
Aquatic toxicity, non-mandatory under OSHA |
A product may carry several pictograms. Appendix C.2.3.1 requires a black hazard symbol on a white background inside a red frame. The red frame is still required when the rest of the label is printed in black and white. An empty red diamond is not permitted.
What is the difference between Danger and Warning?
“Danger” identifies the more severe hazard category, while “Warning” identifies the less severe category. They are the only signal words used for this purpose. Appendix C.2.1 says that when “Danger” applies, “Warning” must not appear. A label never carries both Danger and Warning.
The hazard class and category determine the word. For example, Appendix C assigns “Danger” to Category 1 skin corrosion and “Warning” to Category 2 skin irritation. Some classifications need no signal word, so absence alone does not prove a defect. Compare the label with SDS Section 2 instead of choosing a word from memory.
What are hazard statements and precautionary statements?
Hazard statements describe what a chemical can do and, where appropriate, the degree of hazard. Precautionary statements tell the user how to reduce harm through prevention, response, storage, or disposal. Appendix C allocates both by hazard classification, while SDS Section 2 gives the label elements for the product.
“Causes serious eye damage” is a hazard statement. An instruction to wear eye protection or rinse after eye contact is precautionary. Do not substitute a handwritten note such as “strong stuff.” Start with the current SDS. Appendix C permits appropriate combinations in certain cases, but that is not permission to improvise wording on the floor.
Employees must also be able to reach the SDS during each work shift under 29 CFR 1910.1200(g)(8). Pre-populated SDS binder books can support physical access. Digital systems can work when access is immediate, has no barriers, and accounts for a loss of connectivity.
What must a workplace label contain when you do not use a full GHS label?
For a hazardous chemical container kept in the workplace, 29 CFR 1910.1200(f)(6) allows the shipped-container information or an alternative. The alternative needs the product identifier plus “words, pictures, symbols, or combination thereof” that provide general hazard information and, with other immediately available HazCom information, give employees specific physical and health hazard information.
The identifier is non-negotiable. An HMIS, NFPA, or other in-house system can be part of the program, but workers must understand it and have immediate access to the supporting hazard information. A colored square or number that nobody can explain is not useful communication.
Paragraph (f)(8) creates a narrow portable-container exemption. No label is required when an employee transfers a chemical from a labeled container for that same employee’s immediate use. “Immediate use” means the chemical remains under that person’s control and is used only by that person within the work shift. A bottle left for a coworker or the next shift does not fit. Read more about when a secondary container actually needs a label.
We recommend a full GHS-style workplace label when space and operations allow. A simpler system can comply, but it places more weight on training and consistent interpretation. A full label puts more information at the point of use. Follow a repeatable process for printing labels without gaps or errors.
How do you audit a secondary container label on the floor?
Check the container against its SDS and your written HazCom program. For a full GHS-style label, verify all six elements. For an alternative workplace label, verify the identifier, hazard message, employee understanding, and immediate access to specific information. Replace a bad label rather than relying on what regular users already know.
Per-container audit checklist:
- Is the entire label readable and securely attached?
- Does the identifier lead to one specific SDS and inventory entry?
- For a full label, do the signal word, statements, and pictograms match SDS Section 2?
- Are required pictograms complete, with red frames and no empty diamonds?
- Does a shipped-container label include the responsible party’s name, address, and phone number?
- For an alternative label, can employees explain the system and reach specific hazard information immediately?
- For an unlabeled portable container, is it controlled and used only by the employee who filled it within that shift?
Paragraph (f)(9) requires workplace labels to remain legible, in English, and prominently displayed. Paragraph (f)(10) requires employers to ensure that incoming labels are not removed or defaced.
How does Helios Comply help with secondary container labels?
Helios Comply generates GHS secondary container labels from information in your SDS library, reducing manual copying into separate templates. It also supports AI-assisted SDS digitization, QR-code SDS access, offline access, and multi-location management. That keeps label work closer to the source documents and makes the matching SDS easier for employees to retrieve.
Software does not transfer the employer’s responsibility. Your team still needs an accurate inventory, verified SDS information, properly applied labels, employee training, and routine inspections. Manufacturers can use SDS management for manufacturing facilities to organize records and produce labels from the same system.
Start a free Helios Comply trial to organize your SDS library and generate secondary container labels. For hands-on setup help, call (855) 920-5202.
What else should facility managers know?
Does every secondary container need all six elements?
No. All six apply to shipped hazardous chemical labels under paragraph (f)(1). A workplace container may use paragraph (f)(6), which requires the identifier and effective hazard communication. Using all six is often clearer, but it is not the only federal OSHA option.
Can Danger and Warning appear together?
No. If any applicable hazard requires “Danger,” the label uses “Danger” and omits “Warning.” Some categories require no signal word.
When can a portable container go unlabeled?
The employee who transfers the chemical must keep control of it and be its only user within that work shift. If another person may use it, label it.
Is the environment pictogram required by OSHA?
No. It represents aquatic toxicity and may appear as supplementary information, but OSHA does not mandate it under HazCom.
Sources
- Electronic Code of Federal Regulations, 29 CFR 1910.1200
- OSHA, Appendix C, Allocation of Label Elements
- OSHA 3491, Hazard Communication Standard Pictogram QuickCard
- OSHA 3636, Labels and Pictograms
- OSHA interpretation on workplace labels and immediate use
- OSHA Top 10 Most Frequently Cited Standards for Fiscal Year 2025