Kim's answer shows up the difference between the manufacturer requirements and the workplace employer requirements. The manufacturer is under no obligation with label the containers in the test kit (29 CFR 1910.1200(f)(5) =96 because they will (correctly) take the stand that the kit is the product being supplied to the workplace and that no container within the kit is intended to leave the workplace. The labeling of the contents of the kit then become the responsibility of the employer (29 CFR 1910.1200(f)(6).

I personally don't think we're going to see manufacturers labels on kit components. The GHS requirements, as with previous HazCom requirements are not really that onerous on the chemical manufacturers. If they had been, I think they'd have never seen the light of day.

Dave

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Kim Gates
Sent: Wednesday, May 8, 2013 11:41 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] GHS labelling of kit components

Each individual container in the test kit needs to be labeled with the new requirements.

Kim Gates
Laboratory Safety Specialist
Environmental Health & Safety
Stony Brook University
Stony Brook, NY 11794-6200
Kim.Gates**At_Symbol_Here**stonybrook.edu
631-632-3032
FAX: 631-632-9683
EH&S Web site: http://www.stonybrook.edu/ehs/lab/

Please note my name and email have changed.

On Wed, May 8, 2013 at 12:53 PM, Ralph B. Stuart <rstuart**At_Symbol_Here**cornell.edu> wrote:

I did a GHS training for a lab audience today and someone asked whether the GHS requirements will apply to the components of test kits. They said that the safety documentation with these kits tends to be skimpy and that it would be helpful to have GHS pictograms on the components. I hadn't thought about this question before and was wondering if people on DCHAS-L have experience with answering it.

Thanks for any help with this.

- Ralph


Ralph Stuart CIH
Chemical Hygiene Officer
Department of Environmental Health and Safety
Cornell University

rstuart**At_Symbol_Here**cornell.edu