A compliance consulting firm described a company that uses internal communication methods — words, pictures, product identification numbers, NFPA, HMIS, or DOT identifiers — to identify hazardous chemicals moved between locations within the same building and between company properties. The methods are documented in the company's hazard communication plan, and trained personnel maintain custody during transport. The question: do the workplace labeling options in 29 CFR 1910.1200(f)(6) and (f)(7) apply to these moves?
For intra-plant moves, yes. OSHA said hazardous chemicals transported within the same building intra-plant qualify as being in the same workplace, so the alternative workplace labeling systems permitted under paragraph (f)(6) may be used.
For moves between buildings or properties, no. OSHA stated that any container leaving the workplace is a 'shipped container' and must comply with the labeling requirements in paragraph (f)(1) — the full label with all required HCS elements — regardless of the fact that both sites belong to the same company (29 CFR 1910.1200(f)(1)).
OSHA also clarified that paragraph (f)(7) is not a fallback here: it applies only to stationary process containers.