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MICHIGAN STATE UNIVERSITY LABELING POLICY

Scope And Application

The Right to Know Law requires any container that contains hazardous materials to be labeled. Labels are to provide immediate information on the identity of chemical constituents of a container, and the inherent danger. Assure that incoming bottles are properly labeled; in general, bottles from the manufacturer are properly labeled. However, if the manufacturer's container is not properly labeled, or if chemicals are transferred to a secondary container, the container must be labeled with the constituents, and hazards, including acute or chronic, and/or well-known hazards.

In order to facilitate and maintain the proper labeling procedure, the Office of Radiation, Chemical and Biological Safety has established a labeling policy.

The labeling policy does not apply to chemicals in the following categories:

1. Any pesticide as defined in the Federal Insecticide, Fungicide, and Rodenticide Act when subject to the labeling requirements of that Act.
2. Any chemical substance or mixture as defined in the Toxic Substances Control Act when subject to the labeling requirements of that Act.
3. Any food, food additive, color additive, drug, cosmetic or medical or veterinary device or product, including materials intended for use as ingredients in such products (e.g. flavors and fragrances) as defined in the Federal Food, Drug and Cosmetic Act or the Virus-Serum-Toxin Act when they are subject to the labeling requirements under those Acts.
4. Any alcohol beverage intended for nonindustrial use when subject to the labeling requirements of the Federal Alcohol Administration Act.
5. Any consumer product or hazardous substance as those terms are defined in the Consumer Products Safety Act and Federal Hazardous Substances Act when subject to standards, labeling requirements or regulations issued under those acts.
6. Agricultural or vegetable seed treated with pesticides and labeled in accordance with the Federal Seed Act.

Labeling Requirements

1. No hazardous chemicals and/or substances will be accepted for use at Michigan State University, or shipped to any other location unless they are clearly labeled with the following information:
   1. The identity of the hazardous material and proper safety precautions, and
   2. The appropriate hazard warnings as outlined in the Federal Right to Know Standard.
2. All hazardous chemical labels must be clearly legible, in English, and prominently displayed on the container.
3. If a chemical being labeled is subject to any special regulatory provisions - such as Michigan class "A" carcinogen, then the chemical must be labeled in accordance with the provision.
4. For any process that might create a health hazard during the normal completion of a given task (welding, for instance) the label can be replaced by a sign, placard or batch ticket indicating the identity and nature of the hazard. These warnings must be readily visible to employees during the work shift.
5. Stationary process containers, such as tanks, may be identified with sign, placards, process sheets, batch tickets or other written materials instead of actually affixing labels to process containers. The sign or placard must convey the same information that a label would and be visible to employees throughout the work shift.
6. Any portable vessel containing hazardous chemicals that will not be used on the work shift during which the container was filled, must be labeled with the appropriate hazard information.
7. All prepared solutions must be labeled.
8. All labels are subject to review by the ORCBS to update information and to determine whether the label conveys the appropriate amount of information to meet RTK law requirements.
9. No label may be removed or defaced unless a substitute is immediately provided. Employees must not remove or deface any label without express consent from a supervisor or the ORCBS. The OSHA Compliance Directive states that, before any product can be used, the proper label must be present. Any container without a label must be reported by the employee to his/her supervisor (supervisors with procedural questions should direct inquiries to the Office of Radiation, Chemical and Biological Safety at 355-0153).
10. The identity on the container label must read exactly as it does on the MSDS. If a trade name is used on the MSDS, then a trade name should be on the label. If the chemical name is used on the MSDS, then the container should be labeled accordingly.
11. Pipes must be labeled, by either label or placard, of the hazards of any chemicals in pipes or pipe systems.

Unlabeled containers

If unlabeled containers are found, determine the contents and place a proper label on the container. If this cannot be done, refer to the MSU Hazardous Waste Disposal Guide for proper disposal procedures of unlabeled containers. Supervisors should notify ORCBS immediately if attempts at labeling an unknown container fail. A container of an unknown and unlabeled chemical should be labeled or properly disposed of immediately.

Waste Containers

All hazardous chemical waste should be segregated and labeled according to the MSU Waste Disposal Guide. Special attention should be given to the following areas:

1. Waste containers for non-contaminated glass must be labeled (label as "Broken Glass") and kept separate from other non-contaminated waste.

2. Upon initial waste collection, attach a dated MSU Materials Pick Up tag and label containers with the words "Hazardous Waste".

3. Once a chemical has been dated and labeled as a hazardous waste, it may not be accumulated for more than 90 days. Please request a hazardous waste pick-up from the ORCBS once the 90 day storage limit is approached.

For more specific information regarding hazardous wastes, reference the MSU Waste Disposal Guide.

Material safety data sheets

Right to Know Table Contents