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GHS Small Container Safety Rules did the boss cover this item!

Ok the GHS bottle is a lot smaller than the normal label so where do I put the label or can I skinny this down a little!  GHS hazard communication labels must include six critical elements:

  • A product identifier (as used on the SDS);
  • The name, address, and telephone number of the chemical manufacturer, importer, or other responsible party;
  • A signal word;
  • Pictograms;
  • Hazard statements; and
  • Precautionary statements.

OHS has been firm that container size is not an excuse for not using GHS labels.In a series of by  industry, OHS has suggested alternate labeling options for containers too small for traditional glue-on labels. Manufacturers can use pull-out labels, fold-back labels, attached tags, or other methods to make sure the container is labeled in compliance with GHS standards.If the manufacturer can show that the above options are not feasible, OHS allows for an abbreviated label on a small shipped container, provided the outside packaging displays the elements required by the Provincial and State Legislation in both the USA and Canada.   It is difficult to label small containers given the fact that there is a lot of info that needs to be included on a GHS label and the outer surface area of the containers is always limited. Luckily, many countries allow some GHS label elements (i.e. hazard statements or precautionary statements) to be omitted from a label for small containers. For countries that do not allow simplified labels (i.e., the United States), the use of tags or fold-out labels may be the only solution. If some elements have been omitted, it is always a good practice to include “please refer to SDSs for more info” on the simplified GHS label.

USA

  • Labels must be legible and prominently displayed;
  • No definition of small containers and no exemptions;
  • More reading: GHS in USA No simplified labels for small package

Canada

  • Small container: <=100ml;
  • Precautionary or hazard statements can be omitted;

Special Rules on Labelling in Canada WHMIS 2015

  • Small capacity containers (100 ml or less): precautionary or hazard statements not required;
  • Small capacity containers (3 ml or less): labels not required during their use stage;
  • Bulk shipment and unpackaged hazardous products: labels not required;
  • In transit products or export-only: WHIMS labels and SDSs are not required;
  • Other special rules for lab samples and complex mixtures. [Ref]

Outer Container: For hazardous products packaged in multi-containers, the outer container does not require a WHMIS label if:

1) the inner container label is visible and legible through the outer container, or

2) the outer container has a label that complies with the Transportation of Dangerous Goods Regulations (TDG regulations). Small Capacity Containers (100 ml or less): Small volume containers are not required to have precautionary or hazard statements on the label. Small Capacity Containers (3 ml or less): Hazardous products packaged in a container of 3 ml or less where the label interferes with the normal use of the product are required to have a label that remains durable and legible only while in transport and storage.

Secondary Container Labeling

Secondary containers are usually smaller than primary containers like, spray bottles, jugs, or jars. They usually hold chemicals that are transferred to from a primary container. Secondary containers must comply with GHS labeling requirements except when the following criteria are met:

  • The material is used within the work shift of the individual who makes the transfer
  • The worker who made the transfer is in the work area the entire time during use
  • The container stays in within the work area and in the possession of the worker who filled the container
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