Chemical Safety

all container of hazardous chemicals leaving the workplace

chemical safetyall container of hazardous chemicals leaving the workplace, if a chemical manufacturer importer or employer

Why “all container of hazardous chemicals leaving the workplace” matters

When people talk about chemical safety, the focus is often inside the facility—labels on secondary containers, accessible Safety Data Sheets (SDS), and training. But serious risk (and compliance exposure) can occur when all container of hazardous chemicals leaving the workplace are not controlled. Chemicals shipped to customers, sent to job sites, transferred to another facility, returned to vendors, or even carried offsite by contractors may still be subject to OSHA’s Hazard Communication Standard (HazCom) and related rules.

Under OSHA HazCom (29 CFR 1910.1200), the primary concept is hazard communication: ensuring that downstream users have accurate information about the chemical hazards and protective measures. If a chemical manufacturer importer or employer is involved in packaging, shipping, or distributing hazardous chemicals, you must pay close attention to labeling, SDS transmission, and recordkeeping expectations.

OSHA’s HazCom Standard: the compliance baseline

OSHA’s Hazard Communication Standard (29 CFR 1910.1200) establishes duties for chemical manufacturers, importers, distributors, and employers. While workplace labeling rules are widely known, HazCom also addresses containers leaving the workplace—especially when they are shipped or otherwise provided to other parties.

Who has responsibilities under 29 CFR 1910.1200?

HazCom assigns roles that can overlap. If a chemical manufacturer importer or employer performs multiple functions (for example, an employer that also repackages a chemical for another site), the responsibilities stack.

  • Chemical manufacturers/importers: must evaluate hazards and provide compliant labels and SDS.
  • Distributors: must ensure containers are labeled and that SDS are provided to downstream customers.
  • Employers: must maintain SDS access, implement a written HazCom program, train employees, and ensure workplace containers are labeled.

Key HazCom elements that apply when containers leave

When hazardous chemical containers leave your control, focus on:

  1. Shipped container labeling (HazCom labeling requirements under 1910.1200(f), including the shipped-container provisions)
  2. SDS provision and accessibility (1910.1200(g))
  3. Employee training and procedures for packaging/handling shipments (1910.1200(h))
  4. Written program and inventory alignment so you know what is going out (1910.1200(e))

If the container is leaving the workplace to be used by others, treat it like a “shipped container” scenario—verify the label and ensure the SDS is provided as required.

Shipped container labeling: what should be on the container?

OSHA’s HazCom standard aligns with the Globally Harmonized System (GHS) and requires specific information on shipped container labels. While workplace labels can be more flexible, shipped containers generally need full HazCom-compliant labels.

A compliant shipped container label typically includes:

  • Product identifier
  • Signal word (e.g., Danger/Warning)
  • Hazard statement(s)
  • Pictogram(s)
  • Precautionary statement(s)
  • Name, address, and telephone number of the responsible party

Common problem: repackaging and relabeling

Facilities often buy chemicals in bulk and transfer them into smaller containers for field work, production lines, or customer orders. If those smaller containers are then shipped offsite, they must be treated as shipped containers with appropriate HazCom labeling.

Practical controls include:

  • Maintain approved label templates for common products
  • Require a label check before any container is staged for shipment
  • Use standardized product identifiers that match the SDS and inventory system

SDS requirements when chemicals are shipped or transferred

HazCom requires that SDS be provided to downstream users. In practice, this often means ensuring an SDS accompanies the initial shipment or is otherwise transmitted so the recipient has it.

What “providing the SDS” should look like

Depending on how your supply chain operates, SDS sharing may occur through:

  • Printed SDS included with the shipment
  • Electronic SDS delivery (if your process ensures the recipient actually receives it)
  • Customer portals or systems (again, ensure the downstream user can access it)

OSHA’s requirement is about ensuring the information is supplied, not merely stored on your server.

Where SwiftSDS helps

A recurring challenge is keeping SDS current and ensuring the SDS matches the product being shipped (especially when vendors update formulations or revise SDS). SwiftSDS supports SDS management by centralizing documents in a secure cloud library and making them easy to retrieve during shipping, staging, or customer support.

With SwiftSDS, you can:

  • Maintain a centralized SDS library so shipping teams don’t hunt through binders
  • Align product identifiers with SDS to reduce mis-shipments and mislabeling
  • Provide fast access on the dock or in the field with mobile access

Special scenarios: transfers, returns, and offsite work

“All container of hazardous chemicals leaving the workplace” includes more than customer shipments. Consider these common scenarios and the HazCom controls they require.

Inter-facility transfers

If you send chemicals from Plant A to Plant B, you still want the receiving site to have:

  • Proper shipped-container labels
  • The correct SDS (and revision)
  • Clear handling and storage instructions

Using SwiftSDS chemical inventory management, you can track chemical locations and improve visibility into what is moving where—helping prevent orphan containers or unidentified materials.

Job-site and contractor takeoff

When employees or contractors take chemicals to a job site, treat the outbound container as leaving your controlled workplace environment. Controls to consider:

  • Ensure the container is labeled and legible
  • Ensure the SDS is available to the crew electronically or as a printed copy
  • Confirm the crew has been trained on hazards and emergency response

Returns to vendors and waste shipments

Returned product or hazardous waste can create confusion—especially if labels are damaged or containers have been opened. While waste shipments may fall under other regulatory frameworks, from a workplace perspective you still need to protect employees who handle and stage these containers.

At minimum:

  • Keep containers closed and compatible
  • Maintain clear identification (no mystery containers)
  • Ensure employees can access relevant SDS during handling and emergency response

Building a simple outbound-container compliance checklist

To reduce risk and support OSHA compliance, implement an outbound container procedure that integrates HazCom, training, and documentation.

Recommended checklist for outbound hazardous chemical containers

  1. Verify the chemical identity matches the order, inventory record, and SDS.
  2. Confirm the shipped-container label is complete, legible, and firmly attached.
  3. Confirm SDS availability/provision for the recipient (first shipment or as required by your process).
  4. Inspect the container condition (no leaks, damage, corrosion, or improper closures).
  5. Document the shipment/transfer (date, product identifier, quantity, destination).
  6. Train affected employees—shipping, warehouse, and field teams—on these steps (1910.1200(h)).

A container leaving the workplace should never be a “best guess.” If you can’t identify it and match it to an SDS, stop the process and escalate.

Keeping your HazCom program aligned with outbound movement

OSHA also requires a written hazard communication program (1910.1200(e)). If your written program only addresses in-plant labeling and SDS binders, it may not reflect real operational risk.

Update your HazCom program to include:

  • Who is responsible for label verification on outbound shipments
  • How SDS are provided to customers/receiving sites
  • How inter-facility transfers are handled
  • How contractors and job-site deployments are supported
  • How you manage updates when SDS revisions occur

SwiftSDS can support these program elements by making SDS distribution and version control easier to manage across departments and locations.

Conclusion: safer shipments start with better SDS and labeling controls

Managing all container of hazardous chemicals leaving the workplace is a practical chemical safety issue and a HazCom compliance issue. If a chemical manufacturer importer or employer is involved in packaging, shipping, distributing, or transferring hazardous chemicals, your process should ensure shipped-container labels are correct, SDS are provided, and employees are trained to execute consistent checks.

Want to simplify your outbound chemical compliance workflow? Centralize your SDS, improve inventory visibility, and give teams instant mobile access with SwiftSDS.

Call to action: Explore how SwiftSDS can strengthen your HazCom program and streamline SDS access across shipping, warehouses, and job sites—visit SwiftSDS SDS Management to schedule a demo or learn more.