Labeling Hazardous Chemical Containers

The Texas Hazard Communication Act (THCA) requires that all hazardous chemicals be properly labeled. A Hazardous Chemical according to the THCA means an element, compound, or mixture of elements or compounds that is a physical or health hazard, or has a hazardous substance as defined in OSHA 29 CFR 1910, Subpart Z, Toxic or Hazardous Substances, or by the ACGIH, Threshold limits for Chemical Substances.

Basically, any compound or chemical that is known to cause a health hazard or physical hazard is a hazardous chemical.

Original (Primary) Container Labeling

Original (Primary) container labels must be maintained.

Normally, the original manufacturer's label in good condition will satisfy this requirement.

The supervisor of every University work area where containers of hazardous chemicals are present is responsible for assuring that the manufacturer or suppliers label is not removed or defaced, unless it is illegible or inaccurate.

If re-labeling is required, the label must include, at a minimum, the following items found on the material's MSDS;

  • Name of the chemical
  • Pertinent physical and health hazards (including the organs that would be affected)
  • Manufacturer's name and address

Secondary Container Labeling

Secondary containers must be labeled by department.

A “secondary container” is any container used when a chemical is transferred from its original container into another container for other than immediate use.

The supervisor of every University work area is responsible for assuring that all secondary containers are labeled with at least the name of the chemical as it appears on the MSDS and the appropriate hazard warnings.

Limited Exceptions to Labeling Requirement

A container may be unlabeled if it is a portable container intended for the immediate use (same work shift) of the employee who transferred the chemical from a properly labeled container. There are no other exceptions under the THCA.

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