You can set up a workable secondary container labeling system in one day if you already have a chemical list and a Safety Data Sheet (SDS) for each product. Start with the product identifier and hazard information in the supplier SDS, print labels suited to the container and work area, then apply them before anyone else uses the chemical.
If you are still deciding how GHS secondary container labels are generated, OSHA gives employers two choices under the Hazard Communication Standard (HazCom), 29 CFR 1910.1200(f)(6). You may reproduce the shipped-label elements, or use the product identifier with words, pictures, symbols, or a combination that communicates the hazards when paired with the information available through your HazCom program.
Quick Answer
- Use the supplier label and Section 2 of the SDS as your source. Do not classify the chemical yourself or guess which hazards apply.
- Download official pictogram files from OSHA or UNECE at no cost.
- Choose paper only for clean, dry conditions. Use label stock sold for wet, chemical-prone, or outdoor environments where needed.
- A handwritten label can work if it meets 29 CFR 1910.1200(f)(6) and remains legible under 1910.1200(f)(10).
- Do not rely on the immediate-use exception unless the chemical stays under the control of the worker who transferred it and is used within that shift.
Table of Contents
- Quick Answer
- Where do I get GHS pictograms for printing labels?
- What size and durability should chemical labels be?
- Can I handwrite a secondary container label?
- Are label makers and templates enough for a small shop?
- Can I set up a compliant system in one day?
- What free OSHA resources help small businesses comply?
- How Helios Comply Helps
- Frequently Asked Questions
- Sources
Where do I get GHS pictograms for printing labels?
Download them free from the UNECE GHS pictogram page or OSHA’s pictogram download page. OSHA provides printable PNG, JPG, and EPS files. Section C.2.3.1 of Appendix C requires a black hazard symbol on white with a red diamond frame when a GHS pictogram is used.
Copy only the pictograms that apply to the product. Check the supplier label and Section 2, Hazard(s) Identification, of the SDS. Do not pull a blurry symbol from image search, redraw it, or decide that a chemical “looks corrosive.” OSHA’s files are 300 dpi, and its EPS files can be resized without distorting the symbol. Review the required label elements before building a full shipped-label-style template.
|
Pictogram |
Hazards commonly represented |
OSHA-mandatory pictogram? |
|
Health hazard |
Carcinogenicity, respiratory sensitization, reproductive toxicity, target-organ toxicity, mutagenicity, aspiration toxicity |
Yes, when assigned by the classification |
|
Flame |
Flammables, pyrophorics, self-heating chemicals, self-reactives, organic peroxides |
Yes, when assigned |
|
Exclamation mark |
Skin or eye irritation, skin sensitization, harmful acute toxicity, narcotic effects, respiratory irritation |
Yes, when assigned |
|
Gas cylinder |
Gases under pressure and chemicals under pressure |
Yes, when assigned |
|
Corrosion |
Skin burns, serious eye damage, corrosive to metals |
Yes, when assigned |
|
Exploding bomb |
Explosives, self-reactives, organic peroxides |
Yes, when assigned |
|
Flame over circle |
Oxidizers |
Yes, when assigned |
|
Skull and crossbones |
Acute toxicity that is fatal or toxic |
Yes, when assigned |
|
Environment |
Aquatic toxicity |
No. OSHA does not regulate environmental hazards under HazCom |
What size and durability should chemical labels be?
OSHA sets no minimum label size. It sets a minimum standard: legible, in English, and prominently displayed. That language comes from 29 CFR 1910.1200(f)(10). Select a size that keeps the product name and hazard message readable after the label is applied to the container.
|
Container |
Practical starting size |
Suggested stock |
Typical exposure |
|
32-ounce spray bottle |
2 by 3 inches |
Weather-resistant sheet label |
Splashes and frequent handling |
|
1-gallon jug |
3 by 4 inches |
Polyester or vinyl rated for the surface |
Moisture or cleaning chemicals |
|
5-gallon pail or drum |
4 by 6 inches |
Durable industrial label stock |
Rough handling, washdown, or outdoor use |
|
Dry indoor bottle |
Size needed for readable text |
Paper may be adequate |
Low splash and low abrasion |
These sizes are shop-floor recommendations, not OSHA dimensions. Check the label manufacturer’s compatibility guidance for the container surface and chemical exposure. Test one label before printing a full batch. This matters for cleaning crews working across multiple sites, where spray, moisture, and repeated handling can make a readable label fail early.
Can I handwrite a secondary container label?
Yes. OSHA does not prescribe a printing method in 29 CFR 1910.1200(f)(6). A handwritten secondary container label can comply if it has the required information and stays legible, in English, and prominently displayed as required by 1910.1200(f)(10). Use a permanent marker that will not smear on the chosen stock.
Paragraph (f)(6)(ii) permits a “product identifier and words, pictures, symbols, or combination thereof” that gives general hazard information and works with the specific information immediately available through the HazCom program. That option does not require the full shipped-label set. It does require a real hazard message, not just “cleaner” or an employee nickname.
The portable container exception in 1910.1200(f)(8) is narrow. An unlabeled portable container is allowed only when the chemical is intended for the immediate use of the worker who transferred it. “Immediate use” means that worker controls and uses it within the same shift. Label shared bottles and anything left for later.
Are label makers and templates enough for a small shop?
A template and an ordinary office printer are enough for many small shops. A monochrome thermal label maker can print durable product identifiers and hazard words, but it cannot print a compliant red GHS pictogram border. That does not automatically make a text-based 1910.1200(f)(6)(ii) label invalid. It does make the device unsuitable for copying the full pictogram-bearing supplier label by itself.
If you want pictograms, use a color printer or pair the thermal label with the correct preprinted pictogram stickers. For auto repair shops decanting solvents, keep one controlled template per product and assign one person to update it when a new supplier label or SDS arrives. Otherwise, old labels and current SDS files can drift apart.
Can I set up a compliant system in one day?
Yes, a typical small shop can inventory containers, confirm SDS files, print labels, and brief workers during one shift. The labeling work can be completed in a day, but it does not replace the written HazCom program required by 29 CFR 1910.1200(e) or employee information and training required by 1910.1200(h).
- Hours 1 and 2: Walk every work and storage area. List each hazardous chemical and every spray bottle, bucket, jug, or other secondary container.
- Hour 3: Match each product to its SDS. Request missing sheets from the supplier before making a label. Use the exact SDS product identifier.
- Hour 4: Copy the applicable hazard information from the supplier label and SDS Section 2 into the controlled template.
- Hour 5: Print a test label, check readability and adhesion, then print the batch. Apply labels to clean, dry container surfaces.
- Hour 6: Walk the shop again. Remove empty mystery containers, correct mismatches, and place spare labels where transfers happen.
- Before close: Explain the labeling method, the immediate-use exception, and where employees can obtain the SDS and specific hazard information.
For construction and contractor operations, repeat the final check by truck, gang box, and jobsite. A master file at the office does not fix an unlabeled bottle in the field.
What free OSHA resources help small businesses comply?
Use OSHA’s Pictogram QuickCard, Small Entity Compliance Guide, and 2024 HazCom rule page. OSHA published the final rule on May 20, 2024, aligning the standard primarily with GHS Revision 7.
Small and midsize employers can also request OSHA’s free, confidential On-Site Consultation Program. It is separate from enforcement and does not result in citations or penalties, though employers must agree to correct serious hazards identified by the consultant. If you want a physical backup, Helios also offers pre-populated SDS binder books.
How Helios Comply Helps
Manual templates work, but someone still has to find the right SDS, transfer the correct fields, control revisions, and make the label available where the chemical is used. Helios Comply digitizes SDS files, organizes extracted information, generates GHS secondary container labels, and can place a QR code on a label so a worker can open the full SDS.
Mobile and offline SDS access also help teams reach hazard information where service is unreliable. The employer still owns the chemical inventory, written program, labels, training, and employee access. Software supports that work; it does not guarantee compliance.
Start a free trial of Helios Comply, or call (855) 920-5202 for hands-on setup help.
Frequently Asked Questions
Where do I get GHS pictograms for printing labels?
Download the official files from OSHA or UNECE. Use only the pictograms assigned on the supplier label or in SDS Section 2.
What size and durability should chemical labels be?
OSHA does not mandate dimensions. Under 29 CFR 1910.1200(f)(10), the label must remain legible, in English, and prominently displayed. Match the stock and adhesive to the container and work conditions.
Can I handwrite a secondary container label?
Yes. The printing method is not prescribed. The label must satisfy 1910.1200(f)(6), remain legible under (f)(10), and communicate the chemical’s hazards.
Are label makers and templates enough for a small shop?
They can be. A monochrome label maker cannot reproduce a red GHS pictogram, but 1910.1200(f)(6)(ii) also allows a product identifier and hazard words or symbols when the rest of the HazCom information is immediately available.
Can I set up a compliant system in one day?
You can complete a basic labeling rollout in one shift if your SDS files are available. A complete HazCom program also needs the written program, SDS access, and effective employee information and training.
What free OSHA resources help small businesses comply?
Start with OSHA’s HazCom QuickCards, Small Entity Compliance Guide, current regulatory text, and free On-Site Consultation Program.
Sources
- Electronic Code of Federal Regulations, 29 CFR 1910.1200
- OSHA, Hazard Communication Pictograms
- OSHA 3491, Hazard Communication Standard Pictogram QuickCard
- OSHA, Labeling of Secondary Containers interpretation
- OSHA 3695, Small Entity Compliance Guide for Employers That Use Hazardous Chemicals
- OSHA’s Final Rule to Amend the Hazard Communication Standard
- OSHA Small Business Benefits and Resources
- UNECE, GHS Pictograms