Overview
- Chemical containers, including compressed gas cylinders, are not adequately labeled (labels are missing, illegible, or incomplete).
- Differing requirements
- Laboratory chemicals that are not spent (OSHA Lab Standard)
- Non-Laboratory chemicals that are not spent (OSHA Haz Com Standard)
- Wastes
With a few exceptions, chemical containers in a laboratory must be labeled. This requirement derives from NFPA standards, OSHA standards, and even Hazardous Waste regulations. NFPA requires “all original and subsequent containers of hazardous chemicals, except those being used in ongoing experiments” to be labeled. OSHA’s laboratory standard specifically addresses only original manufacturers' containers. Under RCRA (Resource Conservation & Recovery Act), agency auditors typically look at unlabeled containers as being unwanted. This means that the chemical is not needed and is being stored in lieu of disposal. This violates RCRA regulations.
Interestingly, if a laboratory worker cannot immediately tell a RCRA regulator what is in an unlabeled container and what it will be used for, then the regulator will cite this as a violation. The violation will be written as a “failure to make a waste determination.” So, even if it is later learned that the container held only water, for example, the violation will likely remain. UNL has adopted labeling requirements that will satisfy all of the regulations/standards. It is important to understand that the labeling requirements differ between laboratories and non-laboratories, because OSHA’s HazCom and Laboratory Standards differ. The labeling requirements also differ between usable chemicals and spent/waste chemicals.
This next few sections will describe the labeling requirements for laboratory chemicals that are not spent. Labeling of waste containers is described later, in the portion of the training pertaining to the Waste Management section of the checklist. With few exceptions, which are described later, assume that all types of chemical containers must be labeled - glass and plastic bottles, flasks, compressed gas cylinders, boxes, bags, vials, test tubes, etc. The exceptions, as we’ll discuss later, are not based on the physical structure of the container, but rather on the use of the container.