Have you ever nearly taken a drink from a bottle of soda only to be yelled at by someone “DON’T DRINK THAT!” As it turns out, that someone else had used the bottle to store chemicals, it wasn’t soda at all.  Talk about shock!

I recall investigating an incident where a gentleman sat down on for lunch and unbeknownst to him drank a chemical mixture in an unlabeled container—a soda bottle. He thought it was his soda. The liquid was the same color. He was lucky—he lived.

It’s an unlikely event, but it could and does happen. Nearly every business has some type of chemical in it—some are in their original, labeled containers, others are not.

By the way, did you know that you can get hit with an OSHA violation and potentially a fine if you place chemicals in unlabeled containers? Did you know that “Hazard Communication” was OSHA’s third most frequently cited violation in 2009?

OSHA’s Hazard Communication (29 CFR 1910.1200) requires all chemicals be evaluated and the possible effects and routes of entry be communicated to employees. OSHA also requires employers to have a written hazard communication program that includes container labeling and other forms of warnings, material safety data sheets, and employee training.

Further, chemical manufacturers must ship products with a label identifying the chemical, warnings appropriate to the chemical, and manufacturer contact information. The manufacturer must also provide Material Safety Data Sheets that explain what to do in the event of a chemical exposure.

Additionally, if an employer breaks chemicals down into different containers, OSHA requires each container be labeled either with words, pictures, or symbols describing the identity of the product, routes of entry, and bodily effects. The only exception to this rule is if the product in the secondary container is “intended only for the immediate use of the employee who performs the transfer.”

That said—does the unlabeled bottle of Windex cleaner that you transferred from a larger container need to be labeled?  Indeed it does—it will be used over time and perhaps by a variety of employees. Household products used in an occupational setting in amounts greater than at home, placed in another container, need to be labeled.  

When you transfer any chemical, liquid, solid, or anything that may be hazardous into another container—label it so that the accident above does not repeat itself!

Posted by Donna Clendenning