Is it compliant if an OSHA hazard communication (HazCom) label is placed ONLY on the outer box (not the inner containers of hazardous chemical products) for chemical storage at a warehouse?

Hazard Communication standard (HCS) subparagraph 29 CFR 1910.1200(f)(1) requires covered employers to ensure that each shipped container holding a hazardous chemical and leaving the workplace is labeled, tagged, or marked in accordance with paragraphs (f)(1)(i)-(vi). However, sealed containers of hazardous chemical products that are boxed, but are temporarily stored at a warehouse, may be labeled in accordance with a different subparagraph 29 CFR 1910.1200(f)(6). Subparagraph (f)(6) is about in-house workplace HazCom labeling and is more relaxed than the shipping label requirements at subparagraph (f)(1).

For this type of operation, if the unlabeled individual containers are kept in a sealed box with an HCS-compliant label (i.e., in accordance with paragraph (f)(6)) while in the warehouse, there is no requirement to affix an HCS-compliant label to each individual container. Once the outer box is opened even while in the warehouse, then an HCS-compliant label must be affixed to each individual container of hazardous chemical product in accordance with the shipping label requirement at 1910.1200(f)(1).

In addition, consider whether your warehouse operation falls under the HCS requirements of 29 CFR 1910.1200(b)(4). Source: 5/5/2017 OSHA letter of interpretation.