Decanting Disinfectant: Is a Handwritten Label Enough?
At a 180-room hotel, a housekeeper fills a 750 mL spray bottle from a 4 L supplier-labelled container of a chlorine-based washroom disinfectant. She writes 'Bleach - do not drink' on the spray bottle with a permanent marker and leaves it on her cart. Her shift ends with the bottle half full. The next shift's housekeeper, who has not used the product before, picks it up. The 4 L container's supplier label has corrosion and environment pictograms, the signal word Danger, and the statement 'Causes severe skin burns and eye damage. Very toxic to aquatic life.' The hotel's WHMIS procedure says only that 'containers must be labelled.' The spray bottle has no reference to the SDS, and the housekeeping office keeps the SDS in a locked cabinet to which supervisors have keys.
1. Is the handwritten 'Bleach - do not drink' label acceptable as a workplace label? Explain.
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No. A workplace label for a hazardous product transferred into another container must give the product identifier, information for safe handling, and a statement that the SDS is available. 'Bleach - do not drink' may identify the product in a rough way and gives one warning, but it does not tell the next worker how to handle it safely, what protective equipment to use, what to do if it splashes on skin or eyes, or where to find the SDS. The label is also handwritten and may smear or fade. The hotel should use a durable workplace label that names the product, summarizes the key precautions, and states that the SDS is available. The supplier's hazard information, such as the corrosion hazard, should inform the safe-handling content.
2. Does the immediate-use exception apply to this spray bottle? What facts would change your answer?
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The exception does not apply here. WHMIS 2015 allows a workplace label to be omitted only in a narrow transfer situation, generally where the worker who transfers the product uses it immediately and does not leave it for others. This bottle was left half full at the end of the shift and picked up by a different worker who had not used the product before, so it was not immediate use by the transferring worker. The exception would be closer to applying if the same housekeeper had filled the bottle, used it immediately for the task, and then emptied or cleaned it, with no other worker exposed. Even then, the employer should have a clear procedure. Because the bottle remains in service, a workplace label is required.
3. What about the original 4 L container and SDS access?
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The 4 L container must keep its supplier label legible. If that label becomes damaged or unreadable, the employer must replace it with a workplace label rather than leaving the container unidentified. Separately, the SDS must be readily available to workers who use or may be exposed to the product. Keeping it in a locked office that only supervisors can open does not satisfy that duty if housekeepers cannot get to it promptly. The hotel should make the SDS accessible in the work area or through an immediately available electronic system, and workers should be trained in how to use it. The procedure that says only 'containers must be labelled' is too general to guide this situation.