Is an empty bottle of salad dressing really an appropriate container for alcohol spray?
Yes, it’s acceptable for workers to pour or “decant” hazardous substances from their original containers into smaller, more manageable ones. But as this picture from the Naval Safety Center illustrates, using food containers such as salad dressing bottles to hold hazardous substances isn’t appropriate or safe. And the piece of masking tape stuck to this bottle doesn’t count as a proper workplace label!
Containers of hazardous substances must have proper WHMIS labels on them to ensure that workers know exactly what substance is in the container, any hazards it poses and the proper precautions to take when using it. Without an appropriate label, a worker won’t know what PPE he should use or whether he should, say, keep the substance away from heat, sparks or open flames.
The dangers posed by decanted hazardous substances with improper labels is heightened when the containers they’re in had been used to hold food or drink. Workers may believe the contents are still ingestible—with serious and sometimes fatal consequences.
Example #1: A supervisor for a janitorial company poured a floor cleaning chemical from a properly labelled commercial container into a water bottle and left the bottle on a table for a worker. But the supervisor didn’t label the water bottle. The worker found the bottle, assumed it was filled with water and drank from it. He coughed up blood, vomited and briefly lost consciousness. The company pleaded guilty to failing to ensure that the floor cleaner was transferred into a container with a proper workplace label and was fined $60,000 [Hurley Corp., Govt. News Release, Feb. 18, 2011].
Example #2: A worker found a liquor bottle filled with methanol windshield washer fluid. But the bottle still had the liquor label on it. He and a co-worker drank from the bottle; one took the bottle home and finished it. He later died from methanol poisoning. The company pleaded guilty to failing to acquaint a worker with a hazard in the handling, storage or use of a liquid chemical agent and was fined $175,000 [Brewers Retail Inc., Govt. News Release, Feb. 15, 2013].
Hazardous Substance Decanting Requirements
Under WHMIS, so-called “controlled products” must have either a:
- Supplier label provided by the company that sold, imported or distributed the product; or
- Workplace label provided by the employer.
A workplace label is needed in several circumstances, most notably when a controlled product is “decanted” or transferred from the supplier’s container into another, often smaller container. In that case, the employer must affix a workplace label to the second container. But a workplace label isn’t required if all of the decanted product is required for immediate use or if:
- The decanted product is under the control of and is used exclusively by the worker who filled the smaller container;
- The decanted product is used only during the shift in which it was decanted; and
- The contents of the smaller container are clearly identified.
A workplace label must generally include:
- A product identifier, such as the product’s brand name, supplier’s code name or number, chemical name, common or generic name or trade name;
- Safe use and handling information; and
- Whether an MSDS for the product is available.
The piece of tape labeled “alcohol spray” stuck on the salad dressing bottle in the picture clearly doesn’t satisfy these requirements. As a result, a worker could grab the bottle, spray it on his lunch and start eating before he realizes that something’s terribly wrong with the salad dressing.
So it’s important to train workers on the proper steps to take when transferring a hazardous substance into another container.
However, remember that the WHMIS requirements are going to change when Canada implements the GHS. On June 29, 2013, the Canada Gazette published a notice that Health Canada was seeking comments on a proposal to repeal and replace the Controlled Products Regulations under the Hazardous Products Act and make other changes to related laws to implement the GHS in Canada. The deadline for comments was Sept. 15, 2013.
The final regulations have yet to be released. But it’s believed the government will finalize the changes to the key laws and regulations by Spring 2014. Then it’ll be up to the provinces and territories to amend their corresponding OHS laws by June 2015.
To get a preview of what hazardous substance labels may look like under GHS in Canada, check out this poster.
And for more information on labels and other WHMIS requirements, and updates on the progress of the implementation of GHS in Canada, go to the OHS Insider’s WHMIS/GHS Compliance Centre.