In the United States, chemical labeling requirements are governed by OSHA’s Hazard Communication Standard (HazCom 2012), which aligns with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
Labels are an important part of hazard communication; they provide critical information to protect workers from chemical exposure risks. Understanding the difference between primary and secondary container labels is essential for compliance with GHS (Globally Harmonized System) standards and keeps your employees safe.
What Is a Primary Container Label?
A primary container label is the original label provided by the manufacturer, importer, or distributor on the container in which the chemical is shipped.
OSHA Requirements for Primary Labels: Must include all GHS label elements.
- Product identifier – Matches the name in the Safety Data Sheet (SDS)
- Supplier information – Name, address, and phone number of the responsible party
- GHS pictograms – For all applicable hazard classes
- Signal word – “Danger” or “Warning”
- Hazard statements – Standardized descriptions of hazard types and severity
- Precautionary statements – Guidance on safe handling, storage, and disposal
- Supplemental information – As required by OSHA or other applicable regulations
Example: A gallon of paint thinner shipped from the manufacturer with a label containing the flammable pictogram, “Danger” signal word, and hazard/precautionary statements.
What Is a Secondary Container Label?
A secondary container label is used when a chemical is transferred from its primary container into another container for use within the workplace.
When Required Under HazCom:
- Any container holding a hazardous chemical beyond immediate use by the person who transferred it must be labeled.
- Exceptions apply only if:
- The chemical is used immediately by the employee who transferred it, and
- The container never leaves their control during use.
- The chemical is used immediately by the employee who transferred it, and
Required Elements for Secondary Labels (minimum OSHA requirements):
- Product identifier – Same as on the SDS
- Hazard information – Words, pictures, symbols, or a combination that provides general hazard awareness
- Recommended: Include signal words, hazard statements, and pictograms for clarity
Key Differences Between Primary and Secondary Labels
| Differences | Primary Container Label | Secondary Container Label |
|---|---|---|
| Created and Applied By | Manufacturer, importer, or distributor | Employer or workplace staff transferring the chemical |
| Content | Full GHS label (product ID, supplier info, pictograms, hazard & precautionary statements) | Minimum: product ID + hazard information; Recommended: pictograms, signal words, hazard statements |
| Purpose | Communicate full hazard and regulatory information to any handler | Communicate hazards to employees in the workplace |
| When Required | On all shipped chemical containers | On all workplace containers not used immediately by the person who filled them |
| Regulatory Basis | OSHA HazCom 2012 (29 CFR 1910.1200(f)) | OSHA HazCom 2012 workplace labeling requirements |
Common HazCom Compliance Mistakes
- Leaving secondary containers unlabeled when shared or stored for later use
- Using abbreviations or chemical codes that employees can’t understand
- Not matching the product name to the SDS exactly
- Failing to update labels when chemical formulations or hazards change
The Easy Way to Stay Compliant
Manual creation of compliant secondary labels can be slow and error-prone. SDS Manager’s free GHS Secondary Label Generator allows you to:
- Auto-fill hazard information directly from your SDS
- Support multiple label sizes and layouts
- Add OSHA-compliant GHS pictograms and hazard statements automatically
- Include QR codes linking directly to the SDS for instant access
With automation, you can maintain compliance, save time, and reduce labeling errors across your workplace.
Frequently Asked Questions (FAQs)
Q. What is the main difference between primary and secondary container labels?
A: Primary labels are provided by the manufacturer and include full GHS information; secondary labels are applied in the workplace when chemicals are transferred into another container.
Q. Do all secondary containers need a label?
A: No. If the container is used immediately by the person who filled it and never leaves their control, labeling is not required. Otherwise, it must be labeled.
Q. Can I handwrite secondary container labels?
A: Yes, as long as they are legible, durable, and include required hazard information.
Q. Do secondary labels need pictograms?
A: While not strictly required by OSHA, including relevant GHS pictograms is considered best practice for clarity and safety.
Q: How can I make sure my labels are OSHA-compliant?
A: Use the chemical’s SDS for accurate hazard and product information, and ensure your label elements match regulatory requirements.