Small Container Label Updates in the Proposed HCS
Written By: Atanu Das on Wednesday, September 1, 2021
The Notice of Proposed Rulemaking to amend the Standard has carved out an exception for using small labels based on container capacity. Specifically, where a manufacturer can demonstrate that it is not feasible to use pull-out or other labels containing full label elements required by the Standard the following may apply:
For containers less than or equal to 100 ml, the label must have at a minimum:
- Product identifier
- Pictogram(s)
- Signal word
- Manufacturer name and phone number; and
- A statement that the full label information for the hazardous chemical is provided on the immediate outer package.
The Agency has additional exceptions for containers less than or equal to 3 ml capacity and allows the manufacturer to forgo labels as long the product identifier is on the product. For both of the above cases, the immediate outer package of these containers must include the full label information already required in the regulation. The label cannot be removed or defaced. The outer package must also include a statement that the small container(s) inside must be stored in the immediate outer package bearing the complete label when not in use.
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