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chrissedgwick88  
#1 Posted : 10 February 2022 11:58:18(UTC)
Rank: Forum user
chrissedgwick88

Good afternoon :)

This will seem one of the most basic questions so forgive me, I'm looking specifically for a legal stance on it and I can't seem to find it.

When handling chemicals within our manufacturing facility. Is there a requirement to label items such as bottles that contain a substance that has been decanted from a drum or larger container, that is already labelled?

For example, an employee decants a chemical from a drum. The drum has the correct labelling on under CLP. The employee uses a this bottle, say 50ml within the taks he is carrying out. He may not use all of its contents and so the remainder will be used next time. Another example may be that, we decant multiple 50ml bottle to store. These substances are not supplied to anyone externally and are just used for production.

My question is is there a requirement for these containers to be labelled the same as the original drum i.e. under CLP Regs? If so, does that apply to all substances, even if they do not contain hazardous properties?

I hope all of this makes sense and apologies for the basic question - I have a feeling they should be labelled, I just want to understand any legal requirement.

Many thanks,

Chris. 

A Kurdziel  
#2 Posted : 10 February 2022 12:26:26(UTC)
Rank: Super forum user
A Kurdziel

Right regulation 12 of  COSHH includes a requirement to provide (a) details of the substances hazardous to health to which the employee is liable to be exposed . Now it does not say specifically how these details are to be conveyed to employees but rather than rely on the language of dance let’s say you could argue that the best way to provide this information would be through the use of labels and to make sure it was clear the labels should approximate to the standard ones under CLP. Now imagine what would happen if there was an incident caused by an employee using the wrong substance because it was in poorly labelled container. If the HSE inspector suggested that proper labelling may have prevented an accident you should not be telling them that labelling of decanted substances  is not a strict legal requirement. They would turn around and tell you that it is reasonably  practicable to do this and therefore you should do this.   

Edited by user 10 February 2022 13:25:52(UTC)  | Reason: missing w rds

thanks 1 user thanked A Kurdziel for this useful post.
Kate on 10/02/2022(UTC)
Roundtuit  
#3 Posted : 10 February 2022 12:54:25(UTC)
Rank: Super forum user
Roundtuit

I remember right back at the outset of COSHH having to trawl through the back of laboratory cupboards in order to generate an inventory made all the more difficult by so many small jars with either no label or faded hand writing.

CLP requires all supply containers to be labelled and it would be a poor employer who permitted unidentified packages in the workplace - there are still companies out there where it is common to find some quite nasty substances in old coffee jars because the wide neck is convenient.

There is however a dispensation in the regulation for smaller supply packages including concepts such as fold out labels - consolidated text:

http://publications.europa.eu/resource/cellar/e3f31046-b274-11eb-8aca-01aa75ed71a1.0013.02/DOC_1

ECHA guidance is a bit easier to follow:

https://echa.europa.eu/documents/10162/2324906/clp_labelling_en.pdf/89628d94-573a-4024-86cc-0b4052a74d65

Internally I would have the product name - for identification, signal word and pictogram(s) for employee awareness although rather than filling 50ml containers I would probably look at alternative handling such as a Winchester c/w metered dispenser at point of use.

Roundtuit  
#4 Posted : 10 February 2022 12:54:25(UTC)
Rank: Super forum user
Roundtuit

I remember right back at the outset of COSHH having to trawl through the back of laboratory cupboards in order to generate an inventory made all the more difficult by so many small jars with either no label or faded hand writing.

CLP requires all supply containers to be labelled and it would be a poor employer who permitted unidentified packages in the workplace - there are still companies out there where it is common to find some quite nasty substances in old coffee jars because the wide neck is convenient.

There is however a dispensation in the regulation for smaller supply packages including concepts such as fold out labels - consolidated text:

http://publications.europa.eu/resource/cellar/e3f31046-b274-11eb-8aca-01aa75ed71a1.0013.02/DOC_1

ECHA guidance is a bit easier to follow:

https://echa.europa.eu/documents/10162/2324906/clp_labelling_en.pdf/89628d94-573a-4024-86cc-0b4052a74d65

Internally I would have the product name - for identification, signal word and pictogram(s) for employee awareness although rather than filling 50ml containers I would probably look at alternative handling such as a Winchester c/w metered dispenser at point of use.

chrissedgwick88  
#5 Posted : 10 February 2022 16:09:43(UTC)
Rank: Forum user
chrissedgwick88

Thanks for the responses. They do confirm what I first thought..

I wondered if this same methodology would extend to laboratory then, where there would be multiple examples of chemicals in much smallers containers or batches that have been created by a chemist or taken from a larger container? We have an R&D facility on site too and this is where this would apply.

Roundtuit  
#6 Posted : 10 February 2022 16:13:27(UTC)
Rank: Super forum user
Roundtuit

Decent labelling on all containers of substances such as test reagents is Good Laboratory Practice - your R&D lead should be instilling this in the workforce.

thanks 2 users thanked Roundtuit for this useful post.
chrissedgwick88 on 11/02/2022(UTC), chrissedgwick88 on 11/02/2022(UTC)
Roundtuit  
#7 Posted : 10 February 2022 16:13:27(UTC)
Rank: Super forum user
Roundtuit

Decent labelling on all containers of substances such as test reagents is Good Laboratory Practice - your R&D lead should be instilling this in the workforce.

thanks 2 users thanked Roundtuit for this useful post.
chrissedgwick88 on 11/02/2022(UTC), chrissedgwick88 on 11/02/2022(UTC)
Kate  
#8 Posted : 10 February 2022 16:19:45(UTC)
Rank: Super forum user
Kate

When I worked in labs, it was just standard practice to label (at least with its name) anything that we decanted into a bottle and put aside for later use. We wouldn't though normally label a beaker that we decanted something into for immediate use on the bench.

There are packs of little GHS hazard stickers you can get from laboratory suppliers if you want to indicate the hazards as well as the name.  I consider this a good practice.  

One of the problems if you are using solvents is that they have a tendency to get on to the labels and dissolve either the ink or the glue.  You need the right kind of label to prevent this.  You can get purpose-made, pre-labelled squeezy bottles for common solvents like acetone.

thanks 2 users thanked Kate for this useful post.
chrissedgwick88 on 11/02/2022(UTC), andrewcl on 03/03/2022(UTC)
chrissedgwick88  
#9 Posted : 11 February 2022 11:42:05(UTC)
Rank: Forum user
chrissedgwick88

Thank you for all the replies - very helpful.

Holliday42333  
#10 Posted : 11 February 2022 14:18:57(UTC)
Rank: Super forum user
Holliday42333

Like Kate, when years ago I worked in a laboratory (Aerosol R&D) we had about 1500 containers (mainly jam jar type) of decanted substances.

All were labelled with a number (that matched the MSDS file) and name of the substance made of the old fashioned Dymo raised letter tape so the solvent issue Kate mentions was eliminated/reduced.  The, good old, black on orange hazard labels were also attached.

This was 30 years ago.

A Kurdziel  
#11 Posted : 11 February 2022 16:47:13(UTC)
Rank: Super forum user
A Kurdziel

Poor labelling in labs is one of my bug bears:

Things like

  • reagent X4- utterly meaningless
  • “Mine do not touch”- whose is that?
  • No date when it was made sometimes not even clear what century
  • Using the wrong container eg a volumetric flask which is expensive ,easily broken and has a stopper not a screw cap
  • The label is handwritten with ballpoint pen on a piece of paper that will run if  exposed to a single drop of water let alone soaked with any common solvent but don’t worry it wasn’t legible to begin with!

 

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