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What is the best labeling system to use for secondary containers of hazardous chemicals?

When a chemical is purchased, it is received in a container with an appropriate label. This label displays, among other things, the name of the product and any appropriate warnings. As long as the original label remains intact and readable, there is no need for any action on your part.

If any existing label becomes unreadable or if the product is transferred to other containers for dilution, storage or use, then you must add a label to these "secondary containers." The Hazardous Materials Identification Guide (HMIG) system of labeling secondary containers is ideal for this purpose because of its simplicity and ability to communicate a lot of information in a small space. The figure above is an example of a completed HMIG label.  Click here for more information on ordering our veterinary-specific HMIG labels!

No matter what the chemical or style of the container, the two pieces of information that must be present on secondary container labels are (1) the identification of the chemical, and (2) all appropriate warnings. For all the products presently used in a veterinary practice the four phrases below are applicable and are pre-printed on the labels:

• Avoid contact with eyes
• Do not ingest.
• Avoid prolonged contact with skin.
• Do not inhale fumes.

If any additional warnings must be used for non-routine products, then they should be written out on new labels.

Determining the Hazard Ratings

Any chemical can be a hazard in one of three ways:

• To the health of someone (e.g., carcinogen, toxic, corrosive) - blue section of label,
• By means of physical characteristics (e.g., flammable) - red section of label , or
• Because it may react with other common chemicals (like water) to produce a hazard (e.g., hydrogen gas) - yellow section of label.

Within each of these categories, the danger can be very minimal or it can be extreme. In the HMIG system, the five numbers 0-4 represent the degree of danger: 0 is minimally hazardous and 4 is extremely hazardous. Based on information on the products label and MSDS as well as the way in which it is used at the practice, you must assign a hazard rating for each of the three categories (Health - Flammability - Reactivity). Don’t worry about making a mistake because there are no absolutely right or wrong answers for this - the interpretation is entirely yours!

Many manufacturer’s will assign a HMIG rating for the product directly on the MSDS - these are easy, but remember, you have the right to "downgrade" the severity based on the way it is used in

the practice. For instance, a chemical may have a Health Hazard rating of 3 when it is concentrated, but at the working strength, it may have a Health Hazard rating of 1. Don’t be afraid to use your judgement on products that are diluted significantly for use. Remember the MSDS was written primarily for the factory worker who is probably exposed to the concentrated form of the chemical!

The next step is to determine what procedures and/or personal protective equipment must be observed. The HMIG system uses a series of letters in the white block to denote this precaution. In some instances it is appropriate to "extrapolate" in this area. What we mean by this that you should use an "A" to denote "keep out of your eyes and if you will be using this product in such a way that it may splash in your eyes, then you should use safety goggles."

As you can see, you have a lot of flexibility in labeling as long as the user gets two pieces of information from the label: "What’s in the bottle and what hazard should I be aware of!" Of course, you must post a copy of the included Hazard Materials Information Guide poster somewhere in the hospital where the entire staff can understand the system. Although there is no exact answer for a given chemical because of the diversity of each workplace, the table below contains some suggestions for some of the common chemicals found in a veterinary practice.

Getting them to stick!

Here’s some tips for making labels stick better and last longer:

• thoroughly wash & dry the outside of the bottle before applying the label to remove any residue that will interfere with the adhesive.
• Place clear acetate tape (package sealing tape) completely over the label so that it forms a tight "seal" at least ¼ to ½ inch around the label.
• Place the label on the top or side of the container opposite the pouring or filling spout (when applicable).

For those containers that defy an adhesive label, consider making the label into a "tag" by covering both sides of the label with several layers of clear acetate tape before attaching to the container. Punch a hole in the label and attach it with a rubber band or piece of string.

It is also acceptable to "color code" bottles of identical chemicals and have a "key" label on a wall poster or other visible place. For instance, spray paint all the shampoo/dip dilution bottles a different color corresponding to their contents, then make a poster that explains the colors and the applicable information.

** Note: Formaldehyde is a potential human carcinogen and the phrase "Potential Carcinogen"
should be added to the label when it is placed on the container.

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The information on these pages is excerpted from
The Veterinary Safety & Health Digest,
Copyright 2003 Philip J. Seibert, Jr., CVT  All Rights Reserved
No part of this publication may be reproduced for distribution without prior permission from the publisher.