Sample/Standard labelling rull

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Paul Swain
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Sample/Standard labelling rull

I need help on a question regarding labelling. I was of a belief that there was a rule which stated that if a solution was under the control of the analyst the container did not need to be labelled. I thought it was from OSHA, but it could have been an 'Urban legend' since I have not found it written in any standard that I have looked.
The reason for this question is that my Director wants us to label the trays we use to carry our prepared sample even though each flask containing the prepared sample is already labelled with all the important information. I am looking for something I can use to state that this would be a no-value requirement. Especially since the sample bottles are labelled and they are under constant supervision of the analyst who are performing the analysis.

DocJackman's picture
I am not certain where you

I am not certain where you might have read something that would indicate that a sample need not be labeled if it is in the custody of an analyst. It would be way too easy to mix up samples if that were the case. In my laboratories, I like to have the lids and bottles labeled so that there is less opportunity to cross-contaminate samples by placing the wrong lid on a sample. In our labs we have several analysts check out samples from the repository. Other analysts may need one or more of those samples before the analyst who checked them out has finished with them. He will look to see who checked out the sample(s) he needs and will then go to the station of the analyst who has them. If that analyst is dealing with samples having different types of preservation, it is good to have the trays color coded or in some other manner identified so that the samples can be readily identified rather than having to sort through several unidentified sample sets. The second analyst is also required to sign the internal chain of custody, even though he will have taken his aliquots from samples checked out to another analyst. These chains of custody can be VERY important.

I don't know if your lab has similar circumstances, but it is conceivable that there may be a reason for the requirement that you are not yet aware of. If the Director is approachable, it wouldn't hurt to simply ask the reason for your own edification. There probably is one.

Paul Swain
Paul Swain's picture


Thank you for the quick reply. I should have mentioned that these are aliquots of samples (1:10 dilution) and not the actual sample.
We are a small internal lab, usually there are only two people in the lab working at one time and each are working on one specific analysis wiith only handful of samples. The sample bottles are labelled with all the needed information. What he wants is to have the carrying tray labelled also. The reason is that since the permament secondary containers are labelled so should the temporary ones.

Tony Rook
Tony Rook's picture
Hello Che wizard

Hello Che wizard

Here a few excerpts from the standardized regulations within Canada:

Canadian Centre for Occupational Health and Safety - Workplace Hazardous Material Information System (WHMIS) Labeling

Why label stuff?

Labels are important because they are the first alert there
may be hazards associated with using the product covered by
WHMIS legislation. The labels also tell what precautions to
take when using the product. In addition, labels also inform
the person that there is a Material Safety Data Sheet (MSDS)
available which contains more detailed information on the

Who is responsible for labelling?

Suppliers are responsible for labelling WHMIS-controlled
products that they provide to customers. Employers and
sometimes employees are all responsible for labelling or
relabelling products in the workplace, as directed in
occupational health and safety legislation. This includes
labelling controlled products with workplace labels, decanted
products, laboratory chemicals or piping and bulk containers
where a controlled product is being held or is flowing.

What happens if I put the material in a different container?

You must use a workplace label on the container. There are
two special cases when a workplace label is not necessary.
When a controlled material is poured into a container and it is
going to be used immediately, no label is required. Also, if the
material is "under the control of the person who decanted it"
(which means if the person who poured it will be the only one
using it) and if the material is all used during one shift, just
the product identifier (name) is required. However, if the
material is not used right away or if more than one person
will be in control of the material, a workplace label is
required. Your company may have special rules about
labelling containers so you should ask about labelling policies.

Are workplace labels necessary if the material is in a pipe or
reaction vessel?

Not necessarily. Pipes and reaction vessels may be marked in
other ways such a colour coding, or placards. However, it is
the employers duty to train workers how to recognize and
interpret the markings used in your workplace.

Are labels different if I work in a laboratory?

Sometimes. Laboratory samples of controlled products that
are less than 10 kilograms do not have to have a WHMIS
label as long as there is a label which states the following in
both English and French:

* the product identifier (name),
* the chemical identity or generic chemical identity of an
ingredient of the controlled product, if known,
* the supplier identification
* the statement "Hazardous Laboratory Sample. For hazard
information or in an emergency, call..." and an emergency
telephone number must be provided.

Tony Rook
Tony Rook's picture
And here are some references

And here are some references from standardized labeling regulations within the USA:

A Guide toThe Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

Here are some relevant excerpts from the GHS document....

1.1 What is the GHS?

The GHS is an acronym for The Globally Harmonized
System of Classification and Labeling of Chemicals. The
GHS is a system for standardizing and harmonizing the
classification and labeling of chemicals. It is a logical
and comprehensive approach to:

* Defining health, physical and environmental hazards
of chemicals;
* Creating classification processes that use available
data on chemicals for comparison with the defined
hazard criteria; and
* Communicating hazard information, as well as
protective measures, on labels and Safety Data
Sheets (SDS).

Figure 1.1 GHS Document ("Purple Book")

Globally Harmonized System (GHS) of Chemical Classification and Labeling

Many countries already have regulatory systems in place for these types of requirements. These systems may be similar in content and approach, but their differences are significant enough to require multiple classifications, labels and safety data sheets for the same product when marketed in different countries, or even in the same country when parts of the life cycle are covered by different regulatory authorities. This leads to inconsistent protection for those potentially exposed to the chemicals, as well as creating extensive regulatory burdens on companies producing chemicals. For example, in the United.States (U.S.) there are requirements for classification and labeling of chemicals for the Consumer Product Safety Commission, the Department of Transportation, the Environmental Protection Agency, and the Occupational Safety and Health Administration.

The GHS itself is not a regulation or a standard. The GHS Document (referred to as "The Purple Book", shown in Figure 1.1) establishes agreed hazard classification and communication provisions with explanatory information on how to apply the system. The elements in the GHS supply a mechanism to meet the basic requirement of any hazard communication system, which is to decide if the chemical product produced and/or supplied is hazardous and to prepare a label and/or Safety Data Sheet as appropriate. Regulatory authorities in countries adopting the GHS will thus take the agreed criteria and provisions, and implement them through their own regulatory process and procedures rather than simply incorporating the text of the GHS into their national requirements.The GHS Document thus provides countries with the regulatory building blocks to develop or modify existing national programs that address classification of hazards and transmittal of information about those hazards and associated protective measures. This helps to ensure the safe use of chemicals as they move through the product life cycle from "cradle to grave."

2.2 Will all hazardous chemicals require a GHS label and
Safety Data Sheet?

Product Lifecycle The need for GHS labels and/or Safety Data Sheets is expected to vary by product category or stage in the chemical's lifecycle from research/production to end use. The sequence of lifecycle events is shown in Figure 2.2. For example, pharmaceuticals, food additives, cosmetics and pesticide residues in food will not be covered by the GHS at the point of consumption, but will be covered where workers may be exposed (workplaces), and in transport. Also, the medical use of human or veterinary pharmaceuticals is generally addressed in package inserts and is not part of existing hazard communication systems. Similarly, foods are generally not labeled under existing hazard communication systems. The exact requirements for labels and Safety Data Sheets will continue to be defined in national regulations. However, national requirements are expected to be consistent with the detailed discussion of scope provided in Chapter 1.1 of the GHS document.

Fig 2.2

Tony Rook
Tony Rook's picture
... and here is a reference

... and here is a reference for the standardized OSHA regulations Appendix E - Employer Compliance:

Guidelines for Employer Compliance (Advisory) - 1910.1200 App E

The Hazard Communication Standard (HCS) is based on a simple concept - that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working. They also need to know what protective measures are available to prevent adverse effects from occurring. The HCS is designed to provide employees with the information they need.

Knowledge acquired under the HCS will help employers provide safer workplaces for their employees. When employers have information about the chemicals being used, they can take steps to reduce exposures, substitute less hazardous materials, and establish proper work practices. These efforts will help prevent the occurrence of work-related illnesses and injuries caused by chemicals.

The HCS addresses the issues of evaluating and communicating hazards to workers. Evaluation of chemical hazards involves a number of technical concepts, and is a process that requires the professional judgment of experienced experts. That's why the HCS is designed so that employers who simply use chemicals, rather than produce or import them, are not required to evaluate the hazards of those chemicals. Hazard determination is the responsibility of the producers and importers of the materials. Producers and importers of chemicals are then required to provide the hazard information to employers that purchase their products.

Employers that don't produce or import chemicals need only focus on those parts of the rule that deal with establishing a workplace program and communicating information to their workers. This appendix is a general guide for such employers to help them determine what's required under the rule. It does not supplant or substitute for the regulatory provisions, but rather provides a simplified outline of the steps an average employer would follow to meet those requirements.

Tony Rook
Tony Rook's picture
And here is the reference for

And here is the reference for the Hazard Communication Standard by OSHA

[url=]Regulations (Standards - 29 CFR) Hazard Communication. - 1910.1200 [/url]

Below are several excerpts that should be helpful to you.



The purpose of this section is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training.


Laboratory employers that ship hazardous chemicals are considered to be either a chemical manufacturer or a distributor under this rule, and thus must ensure that any containers of hazardous chemicals leaving the laboratory are labeled in accordance with paragraph (f)(1) of this section, and that a material safety data sheet is provided to distributors and other employers in accordance with paragraphs (g)(6) and (g)(7) of this section.


Except as provided in paragraphs (f)(6) and (f)(7) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information:


Identity of the hazardous chemical(s) contained therein; and,


Appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.



The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(5) of this section to be on a label. The written materials shall be readily accessible to the employees in their work area throughout each work shift.


The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. For purposes of this section, drugs which are dispensed by a pharmacy to a health care provider for direct administration to a patient are exempted from labeling

Paul Swain
Paul Swain's picture
Ho Toni,

Ho Toni,
Thank you for the time and information time. There is some great information and I will probably incorporate some of it to updated our OI.

What I should have stated in my question is "Is it necessary to label temporary secondary containers with the information that is already on the samples bottles when the container does not enclose/encase the sample. The tray in question is 30 cm (L) x 6 cm (w) x 5 cm (H) and the flasks are 10 cm (h) x 5 cm (Dia.)

Tony Rook
Tony Rook's picture
Che wizard:

Che wizard:

From what I can tell by the regulations, the answer to your question would be:

No, the secondary container (i.e. test tube rack or other carrying-type container) is NOT mandated to be labeled by OSHA regulations.

These issues are often left up to the individual preferences of the lab. The way that my lab deals with this, is by not actually labeling each individual dilution tube, but instead placing on label on the rack.

So, again it comes down to the preference of the institution, do you prefer to label every individual primary container or one label for the secondary container or rack.

Since labeling every dilution test tube with description content is repetitive (and often time-consuming), we have chosen to simply label the racks holding the dilution tubes.

Hope this helps clear things up a bit more.


Paul Swain
Paul Swain's picture


Thank you for the clarification.