Question 1

What is a secondary container label?

Accepted Answer

A secondary container is any non-original workplace container that holds a hazardous chemical — for example a spray bottle, parts washer reservoir, drum, or unmarked jug filled from a larger drum. OSHA 29 CFR 1910.1200(f)(6) requires every secondary container to be labeled with the product identifier and at least general information about the chemical hazards.

Question 2

When can I skip a secondary container label?

Accepted Answer

OSHA HCS 2024 has a narrow exemption: a secondary container does NOT need a label if (1) only one employee uses the chemical, (2) it stays under the immediate control of that employee for the entire shift, and (3) it is emptied or returned to its original container at the end of the shift. In every other case — including any time it is left unattended or used by a second worker — a label is required.

Question 3

What information is required on the label?

Accepted Answer

OSHA requires (i) the product identifier and (ii) words, pictures, symbols, or any combination thereof providing at least general information about the hazards. Most facilities include the product name, signal word (Danger or Warning), GHS pictograms, and key hazard statements (H-codes from SDS Section 2). The free generator includes all of these.

Question 4

Is this different from a primary GHS label?

Accepted Answer

Yes. The full primary GHS label (29 CFR 1910.1200(f)(1)) is what manufacturers put on the original chemical container — it includes supplier identification, full precautionary statements, and other elements. Secondary container labels (1910.1200(f)(6)) are simpler — only product identifier + general hazard info is required. Use the GHS Label Generator for full primary labels.

Question 5

Are GHS pictograms required on secondary container labels?

Accepted Answer

No — GHS pictograms (red diamonds) are not strictly required on secondary container labels per 29 CFR 1910.1200(f)(6). The actual requirement is "words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards." Acceptable alternatives include NFPA 704 diamonds, HMIS color bars, hazard words like "FLAMMABLE" or "CAUSES BURNS," custom symbols/color codes, or any combination — as long as workers are trained on what they mean and the SDS is readily accessible. The full pictogram-with-red-border requirement applies only to primary container labels (1910.1200(f)(1)) put on by the manufacturer. That said, most facilities use GHS pictograms anyway because workers already recognize them from the primary container labels.

Question 6

What approaches satisfy OSHA workplace label requirements?

Accepted Answer

Per 1910.1200(f)(6), any of these are compliant when paired with worker HazCom training and accessible SDSs: (1) GHS pictograms with signal word and hazard statements (most common); (2) NFPA 704 hazard diamond with health/flammability/reactivity/special ratings; (3) HMIS color bar; (4) Plain hazard words (e.g. "FLAMMABLE — KEEP FROM HEAT"); (5) Custom in-house symbols or color codes; (6) Just product identifier and a single descriptor like "TOXIC". The label does not have to be a standalone source of truth — it works "in conjunction with" the broader HazCom program.

Question 7

Is this tool free?

Accepted Answer

Yes. Generate and download as many secondary container labels as you need with no account, no payment, no usage limits.

Free Secondary Container Label Generator

Live Preview

Need other label types?

Labeling 50+ secondary containers?