Hand Dip Bowls - Do they need to be labeled?

We use stainless steel bowls that our employees fill, dump, refill throughout the day for our hand sanitizer at point of use and the question I have is whether or not these have to be labeled?  At the point of fill, we have the jugs and station labeled with contents but we don't have a long-lasting approach to label each individual bowl - is this a requirement? 

Any insight is appreciated! 

Yes it's usually a big issue for auditors when they come along something that's not labeled in an audit. Usually you'll have something written up for how you label containers and you have to be following that. In some cases, I've seen it written right in the program that a certain colored container is going to be carrying certain product but you have to have that written up and be able to show that you've trained your employees to put nothing except that chemical/sanitizer in that specific container. They're your programs just make sure you can prove they work. I'd play it safe and have maintenance put a hole in the bowl and zip-tie a label on there securely to keep from any non-compliance.

Dear stsqf,

IMEX this is usually a simple Policy issue. All containers for chemicals have to be labelled.

There are numerous examples of disasters which have occurred in the absence of such a Policy, ie an SOP regarding the monitoring / verification of correct  labelling should also exist. (The Procedure to go with the Policy.)

As an example, i can confirm that storing Ca(OCl)2 sanitizer alongside Sodium Metabisulfite is definitely not  recommended from a Safety POV. (> Fire).

Assuming you use the "bowls" at specified locations, it is also usual to define these points on a mapped Production area layout. Many standards demand such information.

Rgds / Charles.C

Yes, label them, but do it the easy way - tell your chemical rep you need labels and slap them on.   Or spray paint and letter stencils that say "Hand dip station".  Or something like these -  http://www.complianc...NHE-13118.shtml

Yes, label them, but do it the easy way - tell your chemical rep you need labels and slap them on.   Or spray paint and letter stencils that say "Hand dip station".  Or something like these -  http://www.complianc...NHE-13118.shtml

Labelling in-use dispensers/applicators has been discussed here before. It sounds easy but in practice often isn't.

Some  basic label/tag requirements may include being (a) "specific" to the chemical contents, eg product/function/concentration, (b) non-food-interactive and © robust eg not disintegrate/dissolve. IMEX many methods fail one or more of (a-c).

Probably not relevant to the present OP but for some applications, a warning symbol may also be necessary, eg caustic NaOH for cleaning oil fryers.

Rgds / Charles.C

PS - slightly OT - i noticed a few quite informative treatises on Cleaning/Sanitizing while browsing for this thread, may be of interest to someone. (First one has a SOP matrix which I think someone partially quoted in another recent scheduling thread).

CS1 - ECOLAB.pdf   4.9MB   28 downloads

CS2 - Cleaning in Food Processing Plants, DeLAVAL.pdf   2.51MB   25 downloads

CS3 - Cleaning and Sanitizing, Dyson.pdf   2.01MB   26 downloads

Thank you all for your input - as Charles C. stated it is often easier said then done in labeling these in-use containers and that is why I came to the experts here!  The labels from the supplier are easy enough to slap on and that's what we will more than likely move forward with but these will deteriorate fairly quickly with the continual water and chemical. 

(And yes, those are some informative attachments - thanks Charles C.!)

I am looking at this from another perspective.  How about getting rid of the bowls of hand sanitizer and replacing them with a wall dispenser using an alcohol based sanitizer.  Or even a QUAT based.

I have found that hand dips can lose their efficacy with exposure to soils from peoples hands (even if they should be cleaned before sanitizing) and other organic materials.

It would also be easier to label a dispenser that would stay in one location.

Taking this from a food safety issue to an OSHA issue, any time that you put a chemical into a secondary container, then that container must be labeled with the name of the chemical, and the appropriate hazard information (like signal word, pictograms, or other information needed to handle it correctly) if that container is not going to be in the continuous possession of the person who dispensed it.

If you want to keep the sanitizers in bowls, I would permanently label the bowls to be compliant with this regulation (which is the GHS, Globally Harmonized Standard regulation) so that they are always in compliance.

To follow up on Charles C's astute observation, if there is a chance for chemical interactions between the two, then that warning needs to be on the bowls. 

Actually, since OSHA has the force of law, it trumps food safety standards any time.  :)

I had instituted red spray bottles which are NOT labelled but I have posters regarding their contents on the walls and notice boards. It is written in the chemical control and personal hygiene policies that hand sanitiser is presented in red spray bottles. This has totally eliminated the requirement for labels which magically disapparate the nanosecond before the auditor appears on the production floor. This has passed the ministry of BRC thus far.