4.1 - Learning outcomes
- Distinguish between the different types of product labels
- List the contents of a supplier label
- Describe when a workplace label is required
- Assess what you know about product labels
You’ve likely noticed that each hazardous product is identified with a label. Would you be able to distinguish between different types of labels? Would you know whether it’s a supplier label or a workplace label?
Once you’ve discovered the type of label attached to a specific hazardous product, how can you decode the information? What information should be on a supplier label? What information should be on a workplace label?
There are implications of improperly labelled containers or containers with missing labels. For example, in 2017 at the University of Ottawa, a lab manager was following up on a lab safety inspection that had identified inappropriately stored bottles of chemicals in a cabinet under a sink. While doing so, he found some empty bottles that appeared to be for methanol and collected them for recycling. He tilted each of the bottles to confirm they were empty.
Unfortunately, one of them was not and some of the contents—an orange liquid—spilled out onto the floor, splashing onto the manager’s feet. It was clear that the liquid was not methanol because of the orange colour but it did not have any other identifying characteristics. Fortunately, the manager was not injured, but the outcome could have been serious.
Proper labelling of these containers—whether original or waste containers—would have ensured the necessary information was available in order to respond safely and appropriately.
4.2 - General label requirements
WHMIS 2015 defines label as “a group of written, printed or graphic information elements that relate to a hazardous product. The label is to be affixed to, printed on or attached to the hazardous product or the container in which the hazardous product is packaged.”
- Every hazardous product container must be labeled. This includes each container in a shipment.
- Supplier labels must remain on the container while any of the product remains in the container. If a label becomes illegible or is removed, the label must be replaced with a workplace label.
- A container received without a proper label must have a workplace label affixed to it.
When a hazardous product enters a uOttawa workplace, it is usually already labelled by the supplier. In this case, no additional labels are required.
Transferring a product into a different container is sometimes necessary for practicality. In this case, the product user needs to create a new label, known as a workplace label. When all laboratory users have received proper training, fewer workplace labelling requirements apply to analytical standard solutions, solutions prepared for teaching laboratories, products that result from synthesis and products created in the laboratory for research and development (simplified labels can be used).
See section 4.7 for the requirements for a workplace label.
Labels produced in the workplace may include additional information (symbols of required personal protective equipment, hazard pictograms, etc.). Refer to table 1 for an overview of label requirements.
|Less than 100 mL
|Precautionary / Hazard Statement(s)
4.3 - Supplier labels
The product label serves as one of the primary sources of information about the contents of a container. It is vital that the information depicted is properly understood by end users. The label must be bilingual (French/English) and legible. If the supplier label becomes damaged or unreadable for any reason, the label must be replaced with a workplace label. The following label example identifies the components of a WHMIS supplier label.
Recall the conditions for updating an SDS that were described in module 2: if there is significant new data, the supplier of the hazardous product is required to update labels within 180 days of becoming aware of the significant new data. Like the SDS, if a product is sold during this 180-day grace period without an updated supplier label, the supplier must provide the buyer (i.e., the employer) with the significant new data in writing and the date on which the data became available. Suppliers are not required to inform past buyers of a hazardous product that significant new data is available. If users at uOttawa become aware of such new information, they should advise their supervisor.
4.4 - Supplier label – Interactive activity
The following supplier label exercise will allow you to analyze a typical WHMIS supplier label.