Secondary containers: the "soft-drink bottle" problem

A drum of degreaser arrives fully labelled. Someone pours some into a water bottle to take to the workshop. The bottle has no label, or still carries a drinks brand. A week later, someone else drinks from it, or mixes it with something incompatible.

This is the secondary container problem, and it is entirely preventable.

The rules

• Never use food or drink containers for chemicals: no soda bottles, water bottles, mugs or cooking pots.
• Use containers made for the chemical. They must be compatible with it, resistant to breaking (avoid glass where possible), with a tight cap, and preferably UN-rated for anything flammable or corrosive.
• Label every secondary container before it is filled. As a minimum:
  • the product name, exactly as on the original label;
  • the GHS pictogram(s);
  • the signal word ("Danger" or "Warning");
  • the main hazard statements;
  • the date it was filled, and for peroxide-forming chemicals, the date opened.
• Keep the original label intact on the primary container, and replace any label that is damaged or fading.
• Decant in the right place, using pumps or dispensing taps over a drip tray, never by free pouring from large drums. For flammable liquids, bond and earth both containers.
• Fill only what you need, in the smallest practical quantity, and return or dispose of any surplus the same day.

Why labels matter legally. Under the Hazardous Chemicals Regulations, 2024, every container of a hazardous chemical must carry a GHS label. Failing to label is also an offence under s. 161 of the National Environment Act Cap. 181. An unlabelled bottle on a workbench is a regulatory breach as well as a safety hazard.

Inspection questions

• Are any food or drink containers in use for chemicals?
• Does every container in the area say what is in it?
• Are decanting points fitted with trays, pumps and pre-printed labels?

What to do

• Stock pre-printed GHS labels for the chemicals you decant most often.
• Supply proper dispensing bottles, so workers are not tempted to use drinks containers.
• Include a secondary container check in every store and workshop inspection.

How INRC can help

INRC’s occupational health and safety inspections include decanting points and workshops, not only the main store, and our training shows workers how to decant and label safely. Contact us to discuss your site.

This article is general guidance, not legal advice. Check current legislation and regulations for your specific project.