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Ask an Expert: Are My Secondary Labels GHS Compliant?
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By Andi Leistico

As long as the hazard of the chemical has not changed an old format of secondary labels will meet GHS guidelines.Recently, an Account Manager at Dalco asked if we were prepared to handle a heavy amount of secondary label requests due to the recent GHS deadline of June 1st, 2016.

Don’t panic! You will all be glad to know that according to the compliance department of one of our key vendor partners, secondary labels do not need to be updated by any deadline.  All current secondary labels will meet the new GHS compliance standards unless the actual hazardous material has changed. 


Question:
  Are customers required to change out secondary labels to meet the new GHS standards?  Are we, as a distributor required to send out only GHS compliant secondary labels after the June 2016 deadline or are we okay to use up our pre-GHS stock?

Answer:
"Employers are only required to change secondary container labels if the hazard of the product has changed.  In most cases our use dilutions were not hazardous before and are not now under GHS.  So, in most cases the old label will be fine.  

As indicated in the OSHA guidance, workplace labels are not required to have full GHS labeling with the new pictograms.  So, even for a Ready-to-Use product where the product might be hazardous (ie: it was corrosive before and still is now), the old label is still fine.  But, if it was simply an irritant before, with no PPE required, and now it is considered corrosive to eyes or skin, with PPE required, they will have to update the label to accurately reflect the hazard information on the primary label. These requirements will be the same after June 2016 when customers are required to have their Hazard Communications Programs updated." – John Heyer, SealedAir Diversey Care


This indicates that unless the product’s hazards have changed under the new GHS standards, the old secondary label will be in compliance for diluted product that comes from a newly labeled concentrate product. Make sure to double check all of your new SDS documents for any changes in chemical hazards and PPE requirements.

All that being said, in the case that someone specifically wants to have the newest secondary labels, we can provide those.  Just contact your Dalco account representative and we can have them ordered.

So, now you have the full scoop.  For any other GHS related questions don’t hesitate to contact us at Dalco or you can visit our GHS resource page for more links and information.


Have an industry related question? Dalco can help you answer it, contact us with our Ask an Expert form or our customer service chat line.

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