A.  Label Requirements

The Federal Hazard Communication Standard requires that all chemicals sold to ESF contain the following:  the identity of the chemical, the appropriate warnings, the name and address of the manufacturer.  These labels should not be removed or defaced.  If a chemical is in its original container, there are no other label requirements.

All chemical containers (regardless of hazard) must be labeled during use and storage.  A chemical that has been transferred from its original container to another must be labeled with the name of the chemical and manufacturer, the date on original container, hazard warning and person responsible.

Each Laboratory Director is designated to ensure that all hazardous chemicals used in their areas are properly labeled.  The hazard warning can be words, pictures, or symbols that provide an immediate understanding of the primary health and/or physical hazard(s) of the material, and the appropriate personal protective equipment to be used while handling the chemical.  The Laboratory Director is responsible for reviewing the relevant hazards of the chemical and ensuring that the labels are updated.

The National Fire Protection Association (NFPA) diamond labeling system is being used by various chemical manufacturers and may appear on Material Safety Data Sheets.  With minimal training, the type and extent of the hazard is easily recognizable.

Each diamond of a NFPA label addresses a specific area of concern for an individual chemical’s classification.  The blue diamond is devoted to health effects, the red diamond concerns flammability, the yellow diamond represents reactivity, and the white diamond is reserved for special information.

A Numerical Code is used to represent the extent of the hazard for each of the chemical classifications.  The scale ranges from 0 to 4.  The rating 0 is non-hazardous, 1 is slightly hazardous, 2 is moderately hazardous, 3 is significantly hazardous, and 4 is highly hazardous.

The labels for use at ESF are available from the Chemical Hygiene Officer and Central Supply. They include the NFPA diamond label and a “Hazardous Waste” label.  The NFPA label provides a convenient way to ensure easily recognized information on the physical and health effects of the chemical and recommended personal protective equipment.  Additional space is reserved for special warnings or instructions.  Both types of labels are displayed below.

Color Hazard Codes                                          Numeric Hazard Codes

Blue = Health Effects                                           0 = Non-Hazardous
Red = Flammability                                             1 = Slightly
Yellow = Reactivity                                              2 - Moderately
White = Special Information                                 3 = Significantly
                                                                         4 = Highly


B.  Labeling Exemptions and Alternatives

There are four situations that are exempted from or allow alternatives to, the labeling requirement:  (1) containers labeled under other federal laws, (2) portable containers, (3) laboratories, and (4) stationary containers.

1.  Containers Labeled Under Other Federal Laws:


Agency                                               Authority                                 Jurisdiction       

Environmental                      Federal Environmental       Insecticides, Fungicides
Protection Agency                Pesticide Control Act          Rodenticides
                                                (formerly FIFRA)

Consumer Product             Federal Hazardous             Packaging and labeling
Safety Commission           Substances Labeling Act   of food, drugs, cosmetics
                                                                                and medical devices

Bureau of Alcohol,               Federal Alcohol                    Distilled beverages,
Tobacco, and Firearms      Administration Act               wine, and malt beverages
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

2.  Portable Containers

Portable containers into which hazardous chemicals are transferred from labeled containers and which are intended only for the immediate use of the employee performing the transfer are exempt from the labeling requirements of the College.  Hazardous chemicals left in portable containers beyond the employee’s work shift must be labeled according to the standard.  This labeling exemption is intended to prevent the ineffective use of labels for certain activities, such as the few ounces of a pesticide or fertilizer placed in a hand-held spray applicator.  However, labels may be appropriate for any container where confusion may subsequently occur if it is not properly labeled.

3.  Laboratories

Laboratories receive different treatment in terms of the College’s labeling requirements.  The issue of what and when to label becomes more complicated in a laboratory since more than one chemical is often combined to create stock solutions, buffers, washing solutions, and other specialized reagents.  In most cases it is easiest to refer to these mixtures by using a cryptic code.

Since personnel outside of this laboratory are not going to be aware of these codes, provisions have been made to post a code sheet within the laboratory (see Appendix C).  Whenever a code is used, it must be noted on the list.  Codes no longer used can be crossed off the list.

Laboratories only - containers such as test tubes, flasks, beakers, and Petri plates need not be labeled with an identity and hazard warning.  However, good scientific method dictates that labeling and record keeping be kept current.

4.  Stationary Containers and Vessels

Alternative methods of labeling such as signs, placards, and other written forms of warning, are permitted in lieu of affixing labels to individual stationary process containers.  Sometimes, stationary containers (e.g., reaction vessels, storage tanks) may be used for several different materials.  It is not necessary to re-label the container each time the contents change.  Signs, placards or batch/process sheets can be placed or posted in close proximity to the container.  The alternative method of labeling must provide the same information as a label--the substance identity and the primary hazard(s).  Moreover, affected employees must be informed (as part of their hazard communication training) of the alternative labeling methods used in their work areas.


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