Secondary Container Labels

Management & Operations
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I’m sharing this post from the PWRA Facebook group. I thought the information was really good.

Jonathan Sturgill shared a link.

54 mins

Washers,
I’m new to the pressure washing industry, but I think my previous experience can help members of this group. My background is mainly environmental and safety related. The reason for this post is to make those who may not be aware of a recent regulation passed by the Occupation Safety and Health Administration (OSHA) requiring proper labels on any containers holding chemicals. For washers who make batches using hazardous chemicals, for example, you have a large container of Sodium Hypochlorite (SH) at the shop and rather than transport that large container, you fill a 5-gallon container with that SH and take it with you to the job site. Once the chemical, in this case the SH, is poured from
its original container into the second container, the container must be labeled with:
• Name, Address and Telephone Number
• Product Identifier (Name of chemical, found on the primary container label)
• Signal Word (“Danger” or “Warning” are used to emphasize hazards and indicate the relative level of severity of the hazard)
• Hazard Statement(s) (Hazard statements are standardized and assigned phrases that describe the hazard(s) as determined by hazard classification)
• Precautionary Statement(s) (Precautionary information supplements the hazard information by briefly providing measures to be taken to minimize or prevent adverse effects from physical, health or environmental hazards)
• Pictogram(s) (Pictograms include the harmonized hazard symbols plus other graphic elements, such as borders, background patterns or colors which are intended to convey specific information.)

Below is a sample label
https://www.xosafety.com/pr…/ghs-secondary-container-labels…

The labeling of all containers requirement applies to all hazardous chemicals removed from their primary containers and transferred to another container.

Below is a link to a fact sheet with additional information on proper labeling and a second link to the full guidance document to answer any additional questions.
https://www.osha.gov/Publications/OSHA3636.pdf
https://www.osha.gov/dsg/hazcom/ghsguideoct05.pdf

Additionally, since most of our work sites are mobile (trucks or trailers), the Safety Data Sheets (SDSs) for all of the chemicals used at the work site must be readily available for the employees to review the safety information. I recommend creating a binder with the SDSs and leave it in your truck/trailer. As new chemicals are added, ensure its SDS is added to the binder.

If you were pulled over by the Department of Transportation (DOT) or inspected by OSHA and your chemicals are missing an SDS or proper labeling, you could potentially be fined. I want the money to stay in your pocket!

I’m not trying to scare any of the members of this group, I just want to make you’re aware that regulations exist for our safety and the safety of our employees.

If you have any questions or if there is anything I can help you understand better, please don’t hesitate to reach out. I live by the motto “you don’t know what you don’t know” and I think these groups work great because we have people from various backgrounds that just want to succeed in the Washing
Industry.

https://www.xosafety.com/products/ghs-secondary-container-labels?variant=28101478217&fbclid=IwAR0ESwjtfwYlk8kBchm1T-LfpTHPWa22fuyU9z0Va0-syZ8Ws4ZJlOARyD4

8 Likes
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Excellent post.
Reminds me of the Continual Improvement Process (CIP), or Kaizen:

"* Feedback: The core principle of CIP is the (self) reflection of processes.

  • Efficiency: The purpose of CIP is the identification, reduction, and elimination of suboptimal processes.
  • Evolution: The emphasis of CIP is on incremental, continual steps rather than giant leaps.

Key features of kaizen include:

  • Improvements are based on many small changes rather than the radical changes that might arise from Research and Development
  • As the ideas come from the workers themselves, they are less likely to be radically different, and therefore easier to implement
  • Small improvements are less likely to require major capital investment than major process changes
  • The ideas come from the talents of the existing workforce, as opposed to using research, consultants or equipment – any of which could be very expensive
  • All employees should continually be seeking ways to improve their own performance
  • It helps encourage workers to take ownership for their work, and can help reinforce team working, thereby improving worker motivation.

The elements above are the more tactical elements of CIP. The more strategic elements include deciding how to increase the value of the delivery process output to the customer (effectiveness) and how much flexibility is valuable in the process to meet changing needs."

Source Wikipedia.

I think we usually try to improve our rigs here at the PWRA, but being purposeful about it helps you understand that’s your goal and its the professional thing to do, for safety, quality, and ensample.

My local SH purveyor gives out free stickers to put on our tanks, in fact they offer them often, although it does not have those pictograms.

Thank you for sharing these links

2 Likes
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Not a bad price on those stickers, have looked at uline and like these better. Though I wish they were slightly larger, those will be hard to write on.