GHS Labeling Requirements question

Because we are a very small cleaning company, and we clean and reuse drums/containers, with the new requirements, do we need to have actual stickers, or can we print out our own labels and package them in poly and secure them to the containers?
OR does anyone have a forum they can recommend specifically for GHS (Globally Harmonized System of Classification and Labelling of Chemicals)?
Thanks!

Buy em or make em nobody cares as long as they're correct.

A forum? Yep....www.osha.gov will give ya everything you need, just follow the links it supplies

https://www.osha.gov/dsg/hazcom/ghs.html

https://www.osha.gov/dsg/hazcom/global.html

There is a TON of info on the links Randy gave...so much it may be hard to find what you are looking for.

To answer your specific question...it is my understanding that the USA OSHA spin on GHS labeling (after talking with OSHA) is that the label must be affixed to the container. In a poly pouch is NOT good enough.

Whether you make it of buy it is not important...as long as it meets the requirements.
Pay special attention to the black and red colors...it is pretty detailed.
Having a red color where it is not supposed to be can make you non-compliant.

All the same, please consider this answer as an answer on an internet forum...go check it out for yourself at osha.gov.

From the definitions found here: https://www.osha.gov/dsg/hazcom/ghs.html

"Label means an appropriate group of written, printed or graphic information elements concerning a hazardous product, selected as relevant to the target sector(s), that is affixed to, printed on, or attached to the immediate container of a hazardous product, or to the outside packaging of a hazardous product."

If the system you describe is "attached to the immediate container" then it should be ok.

Scott Catron said:

If the system you describe is "attached to the immediate container" then it should be ok.

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Which, of course, will be determined by the person who shows up after the fact to audit you and be subject to their judgement.

It's OK though, they are from the government and they are here to help.

Ninja said:

Which, of course, will be determined by the person who shows up after the fact to audit you and be subject to their judgement.

Click to expand...

Not sure how much judgement is involved with "attached to the immediate container." Either it's attached or it isn't.

I haven't found guidance documents that would address this sort of situation. Maybe there's a question about this in a response to the original notice in the federal register? I'll have to hunt.

Scott Catron said:

Not sure how much judgement is involved with "attached to the immediate container." Either it's attached or it isn't.

Click to expand...

Yup. That was my initial take as well...and I sorta scratched my head at the general response of "The poly pouch is attached to the container, the label in it is not".

At the end of the day, I don't figure there will be much in the way of issues unless they are pretty gross diversions. Time will tell.