Secondary Container Labeling Toolbox Talk

Hazardous chemicals are often transferred from their original containers into smaller containers for daily use. These secondary containers must be properly labeled so workers can immediately identify the contents and understand the associated hazards. Unlabeled or improperly labeled containers can lead to incorrect chemical use, accidental exposure, dangerous chemical mixing, and delayed emergency response.

This toolbox talk reviews the requirements for secondary container labeling and the safe work practices that help ensure hazardous chemicals remain properly identified throughout their use.

Why This Matters

• Proper labels help workers quickly identify chemical hazards.
• Clear labeling prevents accidental misuse or mixing of chemicals.
• Emergency responders rely on accurate labels during spills and exposures.
• Correct labeling supports compliance with Hazard Communication requirements.
• Properly identified containers reduce the risk of injuries and chemical incidents.

Common Hazards

• Using unlabeled secondary containers.
• Transferring chemicals into containers with incorrect or outdated labels.
• Using food or beverage containers for chemical storage.
• Labels becoming damaged, unreadable, or detached.
• Workers assuming they know a container's contents without verifying the label.
• Mixing incompatible chemicals due to incorrect identification.
• Failure to replace missing or damaged labels promptly.
• Storing secondary containers in unauthorized locations.

Safety Checklist

Before Transferring Chemicals

• Verify the chemical being transferred and review its Safety Data Sheet (SDS) if needed.
• Use only approved containers that are compatible with the chemical.
• Label the secondary container before or immediately after filling it according to company procedures.
• Ensure the label is legible, durable, and securely attached.
• Include the required product identifier and hazard information in accordance with company procedures and applicable regulations.
• Never use food or beverage containers for hazardous chemicals.

During Work

• Verify container labels before each use.
• Keep labels clean, readable, and free from damage.
• Replace missing or illegible labels immediately.
• Store secondary containers in approved locations with compatible chemicals.
• Do not use chemicals from an unlabeled or unidentified container.
• Report improperly labeled containers to your supervisor immediately.

Crew Talking Points

• What information must appear on a secondary container label?
• What should you do if you find an unlabeled chemical container?
• Why should chemicals never be stored in food or beverage containers?
• Where can you find additional hazard information for a chemical?
• Who should be notified if a chemical label is missing or damaged?
• Speak up immediately if you notice an unlabeled container or inaccurate chemical labeling.

Stop Work If

• A secondary container is missing a required label.
• The contents of a container cannot be positively identified.
• A chemical has been transferred into an inappropriate container.
• Required hazard information is unavailable.
• Damaged or leaking containers create an exposure risk.
• You are unsure of a chemical's identity or hazards.

Final Reminder

Every chemical container must be properly identified. Never use or store hazardous chemicals in unlabeled containers, replace damaged labels immediately, and verify container contents before use. Taking a few moments to label a secondary container correctly helps prevent chemical exposures, injuries, and costly mistakes.