When chemicals or hazardous materials are transferred from a parent container to a secondary container, OSHA requires the secondary container to be labeled. This secondary container label should contain all of the safety information from the parent container, so that workplace hazards are clearly communicated to everyone.
Ever since we launched our GHS Workplace Labels, which are designed for this exact purpose, we have received calls from customers about exactly what they need to be labeling and how. Recently, one customer asked, “What about water? Does that have to be labeled too? And how should I mark the InSite Workplace Label?”
The short answer is “no”.
Water is not required by OSHA to be labeled. Only workplace chemicals are required by OSHA HAZCOM standards to have a secondary container label.
The long answer is that there are certain situations where the presence of water can become a hazard.
It may seem like a harmless liquid, but it can become dangerous when it comes in contact with other materials. If there are water reactive chemicals present, water should be labeled as a matter of safe workplace practice.
Lye, or sodium hydroxide, is a great example of a substance that changes when water contact occurs. Lye has a variety of industrial uses, and one of the most well known is for making soap. When lye comes in contact with water, it generates heat that can cause severe burns. Workplaces that house water reactive chemicals should label containers of water to prevent accidents and/or cross contamination.
Another potential danger that can be caused by the presence of water is electrical shock. It is a good safety practice to label workplace containers, even water.
The way to mark the secondary container label when it contains water would be to write in “water” for the product ID. For the signal word, write “N/A”. Mark out all of the unessential pictograms with a chisel tip marker to prevent confusion. Use the “Special Hazard / Precautionary Information” section of the label to address any potential hazards that the water could create. If there are no hazards present, then leave the hazard section of the label blank. The “PPE Code” box should be marked with “N/A”.