One of the most important (and arguably one of the most tedious) tasks when dealing with hazardous substances is the labeling of secondary containers. A story in Sunday's Chicago Tribune of a mother who found a sippy cup filled with poison, left behind by the pest control technician called in to get rid of ants, provides a great reminder to the rest of us why it is one of the most important safety tasks.
The mother in the article has three children under the age of six and was horrified to find ant poison in a bottle with cartoon characters, wrapped in paper. The article quotes her asking, "Why on earth would pesticide be put into a children's sippy cup and brought into a home with three small children, then left there?"
Though the technician was not interviewed, it is easy to believe that the technician never intended to leave the container behind, and that like most workplace incidents, it was an accident. An unintentional consequence of an unforeseen series of events. Nevertheless, like most workplace accidents, it was easily preventable. Prevention begins with preparing for unforeseen events.
In this case, whenever a hazardous substance is placed into a secondary container, even if an employee thinks he or she will be the only one who uses it, he or she should assume that at some point another person will encounter the container and its ingredients. In fact, the Hazard Communication Standard (HCS) is constructed around this idea - that a system must be in place to help identify hazards wherever and whenever they may be encountered in the workplace.
While there are special rules for pesticides under the HCS and they are regulated by the EPA, the rules are essentially the same: if you re-bottle pesticides, it is critical that you have a good secondary label program to ensure the chemicals are properly identified. In the United States, labels and warnings are only required to be printed in English. If your workforce is multi-cultural, however, you may want to consider printing in secondary languages or making use of common pictograms and symbols to more effectively communicate the hazards.
Additionally, if your workplace is in the homes of your customers or the general public could come into contact with the containers, additional measures may be necessary.
Fortunately, no one was hurt in this incident and the resulting publicity, while unflattering for the company, helps remind us of the dangers of not adequately labelling secondary containers.