Under the new GHS regulations, when I dilute my chemical packets into bottles, do I need to have a label with pictograms on my bottle?

According to OSHA, as long as employees have immediate access to all information about the hazards of the chemical, and as long as secondary container labels do not conflict or confuse GHS pictograms or signal words, employers can use a workplace labeling system that includes any of the following label methods:

•Process sheets
•Batch tickets
•Operating procedures
•Other written materials to identify hazardous materials – Allen Randolph, vice president sales, Aqua Chempacs, Feasterville-Trevose, Pennsylvania

Generally not. Most use-solutions are not sufficiently hazardous to be classified at a level requiring pictograms for eye irritation or toxicity. Most use-solutions are benign enough to be unclassified under GHS. Use-solution acidity at or below pH 2 or alkalinity at or above pH 11 is the exception, and then a pictogram would be required. – John B. Everitt, president, Stearns Packaging Corporation, Madison, Wisconsin

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