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Do I have to label every single bottle of medication with hazard labels?

The HCS requires that all containers of hazardous chemicals be properly labeled. Although it makes sense to most people that chemical containers should be labeled, we often override this "sense" because of familiarity with the chemical and the bottle. Spray bottles of table wash, disinfectant, alcohol, etc. must still be labeled to avoid confusion, especially if the containers are similar. It's not appropriate to rely on the employee's discretion to tell the difference between a weak solution of chlorhexadine and light blue window cleaner. If you do not remove or deface the manufacturer's label, then no additional labels are required.

Since we often purchase materials in bulk supplies, it is usually necessary to transfer the chemical from the original container to another one for use. This is known as a secondary container. Since the label is the primary means of informing employees of the contents, it is crucial that a label be used on EVERY secondary container, regardless of it's size or severity of the chemical.

If the person who fills the secondary container is the only person who will use the product AND the entire contents of the product will be used during that person's work day, then there is no special requirements for labeling; that worker knows what chemical is in the container and has read the original container's label.

If the secondary container will be used by more than the person who filled it, or it will be used over several work days, then a label must be placed on the container. The information necessary on the label will differ depending on whether the container leaves the practice.

Double labeling is not required

When materials are received from the distributor or manufacturer, whether that be a bottle of injectable medication or a five gallon bucket of dog shampoo, there should be a factory-applied label on the container. It is not necessary to apply additional labels to this container once it reaches the hospital!

Some practices will place additional labels on the primary container to aid employees in distinguishing between similar bottles without having to read the label; different varieties of a flea shampoo may have different colored tags or stickers attached directly to the bottles in order to "color code" them to the colors of the smaller, secondary containers in use throughout the hospital. Although this is very useful in many situations, it is NOT required by OSHA.

 More on chemical labeling