Answer Library / Chemicals & HazCom OSHA letter · 2019-07-25

Can we ship unlabeled chemical containers between our own facilities and label them later?

Quick answer

No. OSHA requires that each container of hazardous chemicals leaving the workplace be labeled, tagged, or marked before it leaves the originating facility, even for intra-company shipments (29 CFR 1910.1200(f)(1)). The bulk-shipment accommodation only applies to large primary containers like tanker trucks or rail cars with no intermediate containment.

A chemical manufacturer packaged buffer and reagent chemicals in tiny plastic "powder pillows" (under 5 ml) and used OSHA's small-package practical accommodation, printing the product identifier, signal word, pictogram, company name, and phone number on each pillow. Facing capacity constraints, the company wanted to ship unlabeled pillows in bulk to a second company facility, where they would be labeled before going out to customers. It asked OSHA whether HCS labels could wait until after the intra-company shipment.

OSHA said no. Under the Hazard Communication Standard, employers must ensure "each container of hazardous chemicals leaving the workplace is labeled, tagged, or marked" per 29 CFR 1910.1200(f)(1)(i)-(vi). The small-package accommodation can be applied to immediate containers only when the outside packaging carries all applicable label elements before leaving the originating facility, so shipping unlabeled immediate containers between plants is not compliant.

The company had pointed to joint DOT/OSHA guidance that allows DOT labels on exterior shipping containers for bulk shipments, but OSHA explained that this only covers "bulk shipments of hazardous chemicals that are loaded into large primary containers (i.e., tanker trucks or rail car) that have no intermediate form of containment." Because the powder pillows are immediate or intermediate containers, each one requires compliant HCS labeling before shipment.

29 CFR 1910.1200(f)(1)(i)-(iv)29 CFR 1910.1200(f)(1)(i)-(vi)
Source: OSHA Standard Interpretation letter, 2019-07-25 — read the official letter on osha.gov →
Interpretation letters explain how OSHA applies its rules to specific situations. Always verify current requirements — regulations and enforcement policies change.

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