What OSHA actually requires on a secondary container
A secondary (workplace) container is any container you fill in-house from a larger, properly labeled container — a spray bottle of degreaser, a refilled solvent can, a transfer bucket, a portable jug. Under 29 CFR 1910.1200(f)(6) the employer must label every one of these so it identifies the chemical and conveys its hazards. Construction is held to the same rule through 29 CFR 1926.59 (adopts 29 CFR 1910.1200).
OSHA gives you exactly two options, and there is no size-based shortcut. The often-cited 100 ml / 3 ml accommodations live in 29 CFR 1910.1200(f)(12) and apply only to the manufacturer's shipped container — never to your in-house secondary containers.
The two (f)(6) labeling options
| Option | What it is | Must include | When to use it |
|---|---|---|---|
| 29 CFR 1910.1200(f)(6)(i) | Full GHS label elements | Product identifier · signal word · hazard statement(s) · precautionary statement(s) · pictogram(s) | Best when you have the SDS handy and want a label identical to the shipped container. |
| 29 CFR 1910.1200(f)(6)(ii) | Identifier + general hazard info | Product identifier · words, pictures, symbols, or a combination giving at least general hazard information | Allowed when the full elements are impractical (e.g. a small transfer can in steady reuse). OSHA judges the whole program case by case: the employer has to show that workers are as aware as a full label would have made them (CPL 02-02-079, (f)(6)). |
The 8 OSHA-required GHS pictograms
OSHA's Appendix C, Figure C.1 lists 8 required hazard symbols. The ninth GHS pictogram — GHS09 (Environment) — is outside OSHA jurisdiction and is voluntary. A square set at a point, black hazard symbol on white background, red frame sufficiently wide (App C C.2.3.1). A red frame with no symbol is prohibited.
| Code | Symbol | Hazard it signals |
|---|---|---|
| GHS01 | Exploding Bomb | Explosive; self-reactive; organic peroxide |
| GHS02 | Flame | Flammable; pyrophoric; self-heating; emits flammable gas |
| GHS03 | Flame Over Circle | Oxidizer |
| GHS04 | Gas Cylinder | Gas under pressure |
| GHS05 | Corrosion | Skin/eye corrosion; corrosive to metals |
| GHS06 | Skull and Crossbones | Acute toxicity (fatal or toxic) |
| GHS07 | Exclamation Mark | Irritant; skin sensitizer; narcotic effects |
| GHS08 | Health Hazard | Carcinogen; respiratory sensitizer; reproductive/target-organ toxicity; aspiration |
Source: 29 CFR 1910.1200 Appendix C, Figure C.1. GHS09 (Environment) is voluntary, not OSHA-required.
Worked examples
1) Acetone in a shop spray bottle (full (f)(6)(i) label). Product identifier Acetone → signal word DANGER → pictograms Flame (GHS02) and Exclamation Mark (GHS07) → hazard statements “Highly flammable liquid and vapor; causes serious eye irritation” → precautions “Keep away from heat/sparks; wear eye protection.” Printed at 100% as one label on Letter paper (179.9 × 132 mm). This mirrors the shipped-container label and satisfies either option.
2) A refilled mop bucket of diluted cleaner (reduced (f)(6)(ii) label). Product identifier Floor Cleaner (diluted) plus the words “Irritant — avoid skin/eye contact” and the Exclamation Mark symbol. That is the product identifier plus general hazard information, which is what (f)(6)(ii) asks for. It meets (f)(6)(ii) if your training lets workers connect it to the full hazard information; OSHA judges that case by case, the employer carries the burden of showing workers are as aware as a full label would have made them, and the safety data sheet does not count as the “other information immediately available” (CPL 02-02-079, (f)(6)). A bucket left for the next shift still needs this label; only a container you fill for your own immediate use this shift is exempt under 29 CFR 1910.1200(f)(8).
What to do next
- Match the SDS. Copy the signal word, pictograms, and H/P statements from the chemical's Safety Data Sheet (Section 2) so the label agrees with it.
- Keep it legible and durable. There is no OSHA size rule, but a faded or torn label is a citation — laminate or use weatherproof stock for jobsite drums.
- Train your crew (1910.1200(h)). Workers must understand the label and pictograms in a language and literacy level they understand — use the bilingual option where appropriate.
- Not sure which container needs a label? Run the secondary container label decision tool first.
Frequently asked questions
What is a secondary (workplace) container label and when do I need one?
A secondary or workplace container is any in-house container a chemical is transferred into — a spray bottle, a refilled drum, a transfer can, a portable bucket. Under 29 CFR 1910.1200(f)(6) the employer must label these containers so each one identifies the chemical and conveys its hazards. Construction adopts the same requirement through 29 CFR 1926.59.
What are the two labeling options under 1910.1200(f)(6)?
OSHA gives employers two choices. Option (f)(6)(i): reproduce the full GHS label elements from the shipped container — product identifier, signal word, hazard statements, precautionary statements, and pictograms. Option (f)(6)(ii): the product identifier plus words, pictures, symbols, or a combination that provide at least general information on the hazards. There are only these two options — there is no size-based 'reduced' tier.
Is there a small-container size cutoff (like 100 ml or 3 ml) for secondary labels?
No. The 100 ml and 3 ml small-container accommodations were added by the HCS 2024 final rule as 29 CFR 1910.1200(f)(12), and they apply ONLY to the SHIPPED container labeled by the manufacturer, importer, or distributor — not to in-house secondary/workplace containers. Workplace containers always follow (f)(6), which has no volume cutoff.
When can I skip the label entirely?
Only under the portable 'immediate use' exception in 29 CFR 1910.1200(f)(8): a chemical transferred from a labeled container into a portable container that is intended only for the immediate use of the employee who performs the transfer, during that work shift. If the container is set down, stored, or used by anyone else, the exception no longer applies and a (f)(6) label is required.
How many GHS pictograms are there and do I need the environment symbol?
OSHA's Appendix C defines eight hazard pictograms (Flame, Flame Over Circle, Exclamation Mark, Exploding Bomb, Corrosion, Gas Cylinder, Health Hazard, Skull and Crossbones) and allocates them per hazard class and category — a label carries the ones its classification calls for, not all eight. The GHS09 environment pictogram (dead fish/tree) is outside OSHA jurisdiction and is voluntary, not required. Each pictogram is a square set on a point with a black symbol on a white background inside a red frame; a red frame with no symbol is prohibited.
Does OSHA require a specific label size?
No. 29 CFR 1910.1200(f)(6) requires the product identifier and hazard information, but OSHA does not mandate label dimensions. Under (f)(10) the label has to be legible, in English, and prominently displayed on the container or readily available in the work area throughout the shift — other languages may be added alongside the English. Durable stock is practical advice, not a rule. This tool names the Avery label size that suits your container; the PDF it makes is one fixed-size label (179.9 × 132 mm) printed at 100% on Letter paper, and the GHS label generator lays labels out on Avery 5163 and 5164 sheets.
Do secondary container labels have to be bilingual (English/Spanish)?
The workplace label must be in English (1910.1200(f)(10)): a label written only in Spanish does not meet the rule, and OSHA's inspection directive cites that case. An employer whose crew speaks another language may add that language alongside the English, never instead of it. Understanding is the job of the training, which must be given in a language and at a literacy level the workers understand (1910.1200(h)(1)). Where Spanish-speaking workers handle the chemical, a bilingual English/Español label is best practice, and this tool mirrors the signal word, pictogram names, and headings into Spanish next to the English.
Can I draw my own hazard symbol or use an emoji on the label?
No. Appendix C, C.2.3.1 requires a black hazard symbol on a white background inside a red frame of sufficient width. Emoji, clip-art, hand-drawn substitutes, and a red frame with no symbol are not compliant. This tool prints the official Appendix C pictogram artwork.
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
OSHA labeling facts verified 2026-10-05. This is a free template for planning, not legal advice — confirm hazard wording against the chemical's SDS before posting a label, and note that State-Plan states may add requirements.
Do I even need a label? →GHS label generator (SDS-driven) →Container → Avery size matcher →29 CFR 1910.1200 (HazCom) →