What OSHA requires on a secondary container label
A secondary (workplace) container is any container a chemical is transferred into from its original labeled container — a spray bottle, bucket, squeeze bottle, or unlabeled drum. Under 29 CFR 1910.1200(f)(6) (construction adopts the standard through 29 CFR 1926.59) you have two compliant options:
- (f)(6)(i) — the full GHS label: product identifier, signal word, pictogram(s), and hazard & precautionary statements (the same elements as the shipped-container label).
- (f)(6)(ii) — the alternative: the product identifier plus words, pictures, symbols, or a combination that provide at least general information on the hazards.
This generator builds the full (f)(6)(i) label whenever the data supplies every element and the chosen size carries every statement. When a statement does not fit, the label prints “+N more — see SDS”, its footer cites (f)(6)(ii) instead, and the screen tells you — a statement is never dropped silently (App C.2.2.1 requires all applicable hazard statements on a full label). There is no volume or size cutoff and no "simplified" tier for secondary containers — two options only. no volume/size cutoff. the ≤100 ml / ≤3 ml 'simplified'/'product-id-only' tiers are not in (f)(6).
What OSHA's inspection directive adds for in-house labels
OSHA CPL 02-02-079, Ch. X.F.4 (Workplace Labels) (the HCS 2024 edition, effective May 19, 2026) tells compliance officers what an employer may leave off an (f)(6)(ii) label: “The workplace (i.e., in-house) label does not need to include the pictogram or a description of the pictogram.” and “Precautionary statements and hazard statements may be used on the in-house labels but are not required.” What stays mandatory is the product identifier and words, pictures or symbols that give at least general information on the hazards, backed by training that lets workers connect the two — and the directive says how that alternative is judged: “OSHA will make a plant-specific determination of the effectiveness of the complete program when an inspection is conducted.” A full (f)(6)(i) label is not judged case by case. That is why this tool builds it, even though the standard lets you do less.
Language: English is required, Spanish is added
29 CFR 1910.1200(f)(10) settles the question employers ask most: “The employer shall ensure that workplace labels or other forms of warning are legible, in English, and prominently displayed on the container, or readily available in the work area throughout each work shift. Employers having employees who speak other languages may add the information in their language to the material presented, as long as the information is presented in English as well.”
So there is no “Spanish label” option here. The label is always in English; ticking Add Spanish prints the Spanish signal word (Peligro / Atención), the Spanish headings and every statement that has a built-in Spanish text next to the English. Codes with no Spanish text are listed on screen and print in English only. A workplace label written only in Spanish is cited under (f)(10) — OSHA's HazCom directive tells inspectors to cite in-house labeling that is “written only in a language other than English”. The training half of the language question is a different rule: see Does OSHA require SDSs in Spanish?
Pictogram precedence the tool applies (App C.2.1)
Appendix C.2.1 is mandatory and it removes one symbol in three situations. The tool reads the H-codes on the label to know what the exclamation mark is being used for, and applies:
- C.2.1.2 “If the skull and crossbones pictogram is included, the exclamation mark pictogram shall not appear where it is used for acute toxicity;”
- C.2.1.3 “If the corrosive pictogram is included, the exclamation mark pictogram shall not appear where it is used for skin or eye irritation;”
- C.2.1.4 “If the health hazard pictogram is included for respiratory sensitization, the exclamation mark pictogram shall not appear where it is used for skin sensitization or for skin or eye irritation.”
The exclamation mark stays whenever another of its uses survives — acetone keeps it for H336 (drowsiness or dizziness) even though its eye-irritation use would be displaced by a corrosion symbol. When a rule fires the screen names it, so nothing disappears from the label without a citation. Only one signal word is ever printed (C.2.1.1), and a pictogram appears once (C.2.3.4).
Four sizes, and what happens when statements do not fit
4" × 2" (Avery 5163, 10 per sheet) · 4" × 3⅓" (Avery 5164, 6 per sheet) · 4" × 6" (thermal / shipping stock) · 8½" × 11" full-sheet placard for drums and totes. The container size you pick suggests a format. A quart of acetone fits a 4" × 2" completely; a multi-hazard mixture with a dozen H and P statements does not, and the tool says so rather than trimming the list — choose the next size up, or post the (f)(6)(ii) label with the SDS immediately available. The product identifier is a field you confirm, not a database nickname: 29 CFR 1910.1200(c) requires it to cross-reference the inventory, the label and the SDS.
Required label elements at a glance
| Element | When required | Detail | Cite |
|---|---|---|---|
| Product identifier | Always | Name/identity that matches the SDS and the chemical inventory. | 29 CFR 1910.1200(f)(6) |
| Signal word | Full label (f)(6)(i) | "Danger" (more severe) or "Warning" — one per label, from the most severe class. | 29 CFR 1910.1200 App C C.2.1.1 |
| Pictogram(s) | Full label (f)(6)(i) | Black symbol on white inside a red frame; 8 OSHA-required symbols (GHS09 voluntary). | 29 CFR 1910.1200 App C C.2.3 |
| Hazard statement(s) | Full label (f)(6)(i) | All applicable H-statements for the chemical's classified hazards. | 29 CFR 1910.1200 App C C.2.2 |
| Precautionary statement(s) | Full label (f)(6)(i) | Prevention, response, storage, and disposal P-statements. | 29 CFR 1910.1200 App C C.2.4 |
| General hazard information | Alternative (f)(6)(ii) | Product identifier + words/pictures/symbols giving at least general hazard info. | 29 CFR 1910.1200(f)(6)(ii) |
On a full (f)(6)(i) label the pictogram is a black hazard symbol on a white background inside a red frame (App C C.2.3.1), and one of the eight Figure C.1 symbols (App C C.2.3.2). Emoji, clip-art, and a red frame with no symbol are not compliant. On an in-house label under (f)(6)(ii), the inspection directive accepts a black border — “If a pictogram is used, it can be used with a black border. This is acceptable ONLY for in-house labels.” — and warns that symbols “must not contradict the pictograms”.
The 8 OSHA-required pictograms (GHS09 is voluntary)
OSHA requires 8 pictograms (Appendix C, Figure C.1): Flame, Flame Over Circle, Exclamation Mark, Exploding Bomb, Corrosion, Gas Cylinder, Health Hazard, Skull and Crossbones. The ninth GHS symbol — GHS09 (Environment) — is not in app c; outside osha jurisdiction; voluntary. This tool orders the eight required symbols first and clearly flags GHS09 as voluntary so it never crowds a required symbol off the label.
Worked examples
Acetone (CAS 67-64-1) in a 32 oz spray bottle. The EU harmonised entry 606-001-00-8 fills signal word Danger; pictograms GHS02 (Flame) and GHS07 (Exclamation Mark); hazard statements H225, H319, H336; precautionary statements such as P210 and P233. All five (f)(6)(i) elements are present, so the label is compliant once verified against the acetone SDS.
Sodium hydroxide solution (CAS 1310-73-2) in a labeled mixing bucket. The EU harmonised entry 011-002-00-6 fills signal word Danger, pictogram GHS05 (Corrosion) and hazard statement H314. If Section 2 of your SDS also lists H290 (may be corrosive to metals), add it: the label follows the SDS for your product. Because the bucket is filled at the start of a shift and used by one worker, it could alternatively qualify for the immediate-use exception (29 CFR 1910.1200(f)(8)) — but the moment it is set aside or handed off, it needs the full label.
When HCS 2024 reaches your secondary containers
The date is in the standard, not in a blog post. 29 CFR 1910.1200(j)(2)(ii) and (j)(3)(ii): “For substances, all employers shall, as necessary, update any alternative workplace labeling used under paragraph (f)(6) of this section, update the hazard communication program required by paragraph (h)(1) of this section, and provide any additional employee training in accordance with paragraph (h)(3) of this section for newly identified physical hazard, or health hazards or other hazards covered under this section no later than November 20, 2026.” For mixtures the same sentence ends on May 19, 2028. Read the words as necessary with the directive's trigger — “Employers must update workplace labels by November 20, 2026 for substances and May 19, 2028 for mixtures when there are classification changes from the manufacturer, importer or distributor.” — and the rule is simple: a relabel is owed when the new SDS or shipped label changes the classification, not by the calendar alone. These are the dates in force after the four-month extension of January 15, 2026; State Plan states set their own. Find yours with the HCS 2024 Deadline Lookup and plan the work with the Relabel Action Planner.
And one duty does not wait for that date at all. Once a revised SDS reaches you with a new or upgraded hazard, 29 CFR 1910.1200(f)(11)(i) starts a 6-month clock on the labels themselves — “Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information.” — and it names chemical manufacturers, importers, distributors, or employers, so your in-house labels are covered. Note the window: the 3-month rule people quote is 29 CFR 1910.1200(g)(5), it covers the safety data sheet, and it binds the chemical manufacturer, importer or employer preparing the safety data sheet — not the employer who merely receives sheets. Reprint with the Relabel Action Planner and this generator.
What to do next
- Verify against the SDS. Confirm the signal word, pictograms, and H/P statements match Section 2 of the manufacturer's Safety Data Sheet for your exact product.
- Keep SDSs accessible. Workers must be able to reach the SDS during their shift (29 CFR 1910.1200(g)).
- Label every secondary container that is not for immediate use, and re-label any container whose contents change.
- Train your team on label elements and pictogram meaning (29 CFR 1910.1200(h)).
Frequently asked questions
What must an OSHA secondary container label include?
Under 29 CFR 1910.1200(f)(6) you have two options. Option (f)(6)(i): the full GHS label — product identifier, signal word, hazard statement(s), pictogram(s), and precautionary statement(s). Option (f)(6)(ii): the product identifier plus words, pictures, symbols, or a combination that give at least general information on the hazards. This generator builds the full (f)(6)(i) label when every element is present and every statement fits the chosen size; when one does not, it prints “+N more — see SDS”, cites (f)(6)(ii) in the footer, and tells you on screen — it never drops a statement silently.
What product name goes on the label?
The product identifier, as defined in 29 CFR 1910.1200(c): the name or number used for the chemical on the label or in the SDS, which must cross-reference the chemical inventory, the label and the SDS. The database name the tool finds (e.g. “Acetone”) is only a starting point — type the name exactly as Section 1 of your SDS gives it (e.g. “Klean-Strip Acetone”) so the three documents match.
Why did the tool drop the exclamation mark pictogram?
Because Appendix C.2.1 says so. If the skull and crossbones is on the label, the exclamation mark shall not appear where it is used for acute toxicity (C.2.1.2); if the corrosion pictogram is on the label, the exclamation mark shall not appear for skin or eye irritation (C.2.1.3); and if the health hazard pictogram is there for respiratory sensitization, the exclamation mark shall not appear for skin sensitization or irritation (C.2.1.4). The tool reads the H-codes on the label to know what the exclamation mark is used for, keeps it whenever another of its uses remains (for example H336, drowsiness), and tells you which rule applied.
Is there a size limit below which a secondary container needs no full label?
No. Paragraph (f)(6) has no volume or size cutoff and no 'simplified' or 'product-identifier-only' tier — every secondary container gets a label. The 100 mL and 3 mL small-container accommodations people sometimes cite live in 1910.1200(f)(12) and apply ONLY to the manufacturer's shipped container under (f)(1), not to in-house workplace/secondary containers.
How many GHS pictograms does OSHA require?
Eight. OSHA's Appendix C, Figure C.1 lists eight required hazard symbols (Flame, Flame Over Circle, Exclamation Mark, Exploding Bomb, Corrosion, Gas Cylinder, Health Hazard, and Skull and Crossbones). The ninth GHS pictogram, GHS09 (Environment), is outside OSHA's jurisdiction and is voluntary — this tool flags it as voluntary and never lets it crowd out a required symbol.
Can I draw or print my own hazard symbol instead of the official one?
Not on a full (f)(6)(i) label. Appendix C.2.3.1 requires a black hazard symbol on a white background inside a red frame of sufficient width, and C.2.3.2 allows only the eight Figure C.1 symbols — emoji, clip-art, hand-drawn substitutes, and a red frame with no symbol are out. On an in-house label under the (f)(6)(ii) alternative, OSHA's inspection directive (CPL 02-02-079) is looser on the frame — “If a pictogram is used, it can be used with a black border. This is acceptable ONLY for in-house labels.” — but not on the meaning: “If symbols are used they must not contradict the pictograms, or use of the wrong symbol for a given hazard (e.g., using the symbol for oxidizers to signify carcinogens).” This generator prints the official Appendix C artwork with the red frame, so the label is right under either option.
Do I have to put pictograms and hazard statements on a secondary container at all?
Not under option (f)(6)(ii), and OSHA's inspection directive says so in plain words: “The workplace (i.e., in-house) label does not need to include the pictogram or a description of the pictogram.” and “Precautionary statements and hazard statements may be used on the in-house labels but are not required.” What (f)(6)(ii) still requires is the product identifier plus words, pictures or symbols that give at least general information on the hazards, backed by training that lets workers connect the two. The directive also says how that alternative is judged — “OSHA will make a plant-specific determination of the effectiveness of the complete program when an inspection is conducted.” — a case-by-case call. A full (f)(6)(i) label is not judged case by case, which is why this generator builds it.
Is the immediate-use container exception real?
Yes. Under 1910.1200(f)(8), a portable container into which a chemical is transferred from a properly labeled container does not need a label if it is intended only for the immediate use of the employee who makes the transfer during that work shift. If the container is set aside, stored, or used by another worker, it must be labeled.
When is the construction (1926) version cited?
Construction adopts the general-industry Hazard Communication Standard by reference through 29 CFR 1926.59, so the substantive requirements in 1910.1200 — including the (f)(6) labeling rules — apply on construction sites.
Is there a deadline to update my secondary container labels under HCS 2024?
Yes, and it is in the standard itself. 29 CFR 1910.1200(j)(2)(ii) and (j)(3)(ii): employers shall, “as necessary, update any alternative workplace labeling used under paragraph (f)(6)” no later than November 20, 2026 for substances and May 19, 2028 for mixtures. OSHA's inspection directive spells out the trigger: “Employers must update workplace labels by November 20, 2026 for substances and May 19, 2028 for mixtures when there are classification changes from the manufacturer, importer or distributor.” So the clock runs from a changed classification reaching you on a new SDS or shipped label — a container whose hazards did not change needs no reprint. These are the dates in force after the four-month extension of January 15, 2026 (FR Doc. 2026-00653); State Plan states set their own, so check the HCS 2024 Deadline Lookup for yours.
Where does the hazard data come from, and do I still need the SDS?
From one named source: the EU harmonised classification (Regulation (EC) No 1272/2008, Annex VI) as PubChem publishes it, with the entry's index and name on screen. When the EU has not harmonised a substance, nothing is pre-filled and you build the label from Section 2 of the SDS. In the US the manufacturer or importer classifies (29 CFR 1910.1200(d)(1)) and puts the hazards in Section 2 of its SDS ((g)(2)(ii)), so the label follows that sheet for the exact product, and the SDS stays accessible to workers.
Can I make Spanish labels?
You can add Spanish, not replace the English. 29 CFR 1910.1200(f)(10) requires workplace labels to be legible and in English, and lets employers with employees who speak other languages add the information in their language “as long as the information is presented in English as well”. Tick “Add Spanish” and the label prints English with the Spanish signal word (Peligro / Atención), headings and statements alongside it. Any H/P code with no built-in Spanish text is listed on screen and prints in English only. A Spanish-only workplace label is a citation under (f)(10), so the tool does not offer one.
What label sizes and stock does this produce?
Four print-ready sizes: 4" × 2" (Avery 5163-compatible, 10 per US Letter sheet), 4" × 3⅓" (Avery 5164-compatible, 6 per sheet), 4" × 6" for thermal or shipping-label stock, and a full 8½" × 11" placard for drums and totes. The container size you pick suggests a format; a bigger label carries every statement in full. Use the Container Size Matcher to check what physically fits your bottle or drum, and print on chemical-resistant stock.
Is this tool free?
Yes — the GHS label generator is free with no signup. For managing hundreds of chemicals with automatic SDS tracking, inventory, and multi-site support, HazComFast plans start at $69/mo with a free plan that never expires.
Sources & verification
- https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200
- https://www.ecfr.gov/current/title-29/section-1910.1200
- https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppC
- https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB
- https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.106
- https://www.federalregister.gov/documents/2024/05/20/2024-08568/hazard-communication-standard
GHS/HCS classification facts verified 2026-10-05 against eCFR, OSHA.gov, and the Federal Register; the workplace-label paragraphs quoted above ((c), (f)(6), (f)(10), Appendix C.2.1–C.3) re-read verbatim on 2026-08-29 at the eCFR. OSHA's inspection directive CPL 02-02-079 read in the official PDF on 2026-08-29. Pictogram artwork is the official Appendix C Figure C.1 set. This tool produces a label for you to verify against your SDS before posting. Not legal advice. State-Plan states may have additional requirements.
Container Size Matcher →Chemical Inventory Template →HazCom Program Generator →OSHA 1910.1200 (full standard) →