Are GHS pictograms required on secondary container labels?

No. The OSHA requirement under 29 CFR 1910.1200(f)(6) is 'words, pictures, symbols, or any combination thereof' that convey at least general hazard information. GHS pictograms are one option, but NFPA diamonds, HMIS color bars, plain hazard words, or in-house symbols are also compliant — as long as workers are trained on what they mean and the SDS is readily accessible.

When can I skip labeling a secondary container?

OSHA's single-shift exemption (29 CFR 1910.1200(f)(8)) allows you to skip the label only if ALL three conditions are met: (1) the container is intended only for the immediate use of the employee who performs the transfer, (2) it stays under that employee's immediate control for the entire work shift, and (3) it is emptied at the end of the shift. If the container is left unattended at lunch, used by a second worker, or kept overnight, a label is required.

What's the difference between a primary container label and a secondary container label?

Primary container labels (1910.1200(f)(1)) are what manufacturers and distributors put on the original chemical container — they require the full GHS format with 6 elements: product identifier, signal word, hazard statements, pictograms, precautionary statements, and supplier info. Secondary container labels (1910.1200(f)(6)) apply when an employer transfers chemicals to a non-original container. They are much simpler — only the product identifier and general hazard information are required.

Do I need a secondary container label on a spray bottle I refill from a labeled drum?

Yes — unless the spray bottle meets the single-shift exemption (1910.1200(f)(8)). Most workplace spray bottles get reused day after day or shared between workers, so the exemption usually does not apply and a label is required.

Can I just write the chemical name on the container with a Sharpie?

Technically the product name plus 'general hazard info' is the minimum compliant content. So writing 'ACETONE — FLAMMABLE' on a container with a permanent marker would satisfy the literal requirement of 1910.1200(f)(6) — assuming workers are trained on what 'flammable' means and the SDS is accessible. But OSHA inspectors expect labels to be legible, durable, and conspicuous. Marker on plastic fades, smears, or gets cleaned off. A printed label is the practical standard.

What about labels in Spanish for non-English-speaking workers?

OSHA requires labels to be in English, but you may add other languages. For workplaces with non-English-speaking workers, OSHA expects training to be conducted in a language workers understand, and bilingual labels are a recommended best practice.

Secondary Container Labels: What OSHA Actually Requires (1910.1200(f)(6))

What Is a Secondary Container Label?

A secondary container is any non-original container that holds a hazardous chemical at your workplace. The most common examples:

A spray bottle filled from a 5-gallon pail of cleaner
A squeeze bottle of solvent at a parts washer
An unmarked jug filled from a 55-gallon drum
A smaller drum decanted from a tote
A dispensing tank filled from a tanker truck

Whenever you take chemical out of its original (manufacturer) container and put it in something else, the new container is a "secondary container" in OSHA's eyes. And in most cases, OSHA requires it to be labeled — under 29 CFR 1910.1200(f)(6), the workplace labeling provision of the Hazard Communication Standard.

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The Actual OSHA Requirement (Plain English)

The full regulatory text of 29 CFR 1910.1200(f)(6) says workplace labels must include either:

(i) Everything required on a primary GHS label (the full 6-element format), OR
(ii) The product identifier plus "words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals."

Most employers use Option 2 because it's much simpler. The label has to identify the chemical and communicate the hazards generally — that's it. It doesn't have to repeat everything from the SDS, because the SDS is also required to be readily accessible to workers.

What "General Hazard Information" Looks Like (Compliant Examples)

OSHA gives employers a lot of flexibility on Option 2. Any of these approaches satisfies the rule:

Approach	Example	When to use it
GHS pictograms	Product name + flame icon + skull icon	Most common — workers already recognize them from primary labels
NFPA 704 hazard diamond	Product name + 4-color diamond with 0–4 ratings	Common in manufacturing; recognized by emergency responders. Generate one free →
HMIS color bar	Product name + colored bar with health/flammability/reactivity numbers	Common in paint, coatings, auto industries
Hazard words alone	"ACETONE — FLAMMABLE — CAUSES EYE IRRITATION"	Simplest; works if training covers what the words mean
In-house symbols	Custom color codes or shapes you've defined	Allowed, but workers must be trained on the meaning
Combination	Product name + GHS pictogram + signal word + NFPA diamond	Belt-and-suspenders; some facilities do this for clarity

The label doesn't have to stand on its own. Per OSHA, it works "in conjunction with the other information immediately available to employees under the hazard communication program." That means the label is allowed to be terse because workers also have:

Mandatory HazCom training that covers what hazard symbols and words mean
An SDS that's readily accessible
Workplace postings about chemical safety

When You Can Skip the Label Entirely

OSHA carved out one narrow exemption: 29 CFR 1910.1200(f)(8), the "immediate use" exemption.

You do not need a label on a secondary container if all three of these conditions are met:

The container is intended only for the immediate use of the employee who transfers the chemical
The chemical stays under the immediate control of that employee for the entire work shift
The container is emptied at the end of the shift

The classic example: a chemist pours a small amount of solvent from a labeled bottle into a beaker, uses it for a single test, rinses the beaker out at the end of the experiment, and walks away with no chemical left in it. That beaker doesn't need a label.

What breaks the exemption: - The container is left unattended (at lunch, in another room, between shifts) - A second worker uses or comes into contact with the container - The chemical remains in the container at the end of the shift

In practice, most workplaces just label everything. Verifying the three conditions is harder than slapping on a label, and the cost of being wrong is an OSHA citation.

Common Misconceptions

"All workplace containers need a full GHS label." False. That's the requirement for primary containers (the original manufacturer-supplied container). Secondary container requirements are much more flexible — you can use a simplified format under (f)(6) Option 2.

"Secondary container labels need GHS pictograms." False. GHS pictograms are one acceptable option. NFPA diamonds, HMIS color bars, plain hazard words, or in-house symbols all satisfy "words, pictures, symbols, or combination thereof." (See OSHA's HCS 2024 final rule for the full text.)

"If a label falls off, the worker is responsible for putting it back." False. OSHA holds the employer responsible for ensuring all secondary containers are labeled — including making sure labels stay on through cleaning, weather, abrasion, and use.

"A handwritten Sharpie label is fine." Maybe — it's compliant in content if it has the product name + general hazard info. But Sharpie fades, smears, and gets cleaned off. Printed adhesive labels are the practical standard. Inspectors will note illegible or worn labels even if the content was originally compliant.

"HCS 2024 changed the secondary container rules." False. OSHA's HCS 2024 final rule (effective May 2024) tightened primary container requirements (small containers, combined packaging, released-for-shipment dates) but did not change the workplace labeling provisions in (f)(6) or (f)(8).

What OSHA Inspectors Look For

When an inspector walks your facility, secondary container labels are one of the easiest violations to spot. They look at:

Are containers labeled at all? Unmarked spray bottles, jugs, or drums are an immediate red flag.
Is the product identifier on the label? It must match what's in your SDS library.
Is hazard information present? Some symbol, word, or color code that conveys the danger.
Is the label legible and conspicuous? Faded, peeling, or hidden labels count as non-compliant.
Are workers trained on what the labels mean? If you use NFPA diamonds, can workers read them? If you use in-house symbols, do they know what each one means?

Each unlabeled or improperly labeled container can be a separate citation. Serious violations under HazCom carry penalties up to $16,550 per violation. An inspection that finds 10 unlabeled spray bottles can produce 10 separate citations.

How to Comply Without Going Crazy

For most SMB workplaces, the practical compliance recipe is:

Inventory every place you transfer chemicals — refilling stations, parts washers, lab benches, shop floors.
Pick a label format and stick with it — most facilities use a simplified GHS-style label (product name + signal word + pictograms + key hazard statement) because it matches what workers already see on the primary container.
Use a printable label generator — a free secondary container label generator gives you a print-ready PDF in seconds. Print them on Avery 5160 or 5163 sheets and stick them on the bottles.
Train workers on the label format — your annual HazCom training should cover what the labels mean, especially if you use NFPA or HMIS systems.
Build re-labeling into your routines — when refilling a spray bottle, check the label is intact. Replace any that are faded.

Print Compliant Labels in 60 Seconds

We built a **free Secondary Container Label Generator** that handles all of this:

Just enter the product name (required) and pick a signal word
Optionally add GHS pictograms (one click each — multi-select)
Add a hazard statement copied from your SDS Section 2 (optional)
Pick a label size — Avery 5160 (1″ × 2.625″), 5163 (2″ × 4″), or 5164 (3.33″ × 4″)
Download a print-ready PDF — no account, no payment

Want NFPA labels for stationary tanks instead? Use the free NFPA 704 Diamond Generator. Want full GHS primary labels? Use the free GHS Label Generator.

When to Move Beyond a Free Tool

Free generators are great for one-off labels and occasional use. But if you're labeling 50+ containers across multiple sites:

Manually entering each chemical's hazard info is slow
SDS revisions don't propagate to your printed labels automatically
You can't print a whole batch at once
There's no audit trail of who labeled what, when

That's where a paid platform like **Tellus EHS** saves time:

Auto-extracts hazards from any SDS PDF you upload
Generates secondary container labels for every chemical in your inventory
Prints in batch on Avery sheets (10, 30, or 6 per page)
Tracks SDS revisions and flags labels that need updating
One platform for primary GHS, secondary container, NFPA, and HMIS labels

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