Response: No. The practical accommodation you suggest does not comply with the practical accommodation developed by OSHA. OSHA understands your concern that HCS 2012 labels contain more information, which may be difficult to include on small shipped containers. As such, OSHA developed a practical accommodation to address situations where the full HCS 2012 required labeling information cannot be provided through the use of pull-out labels, fold back labels, tags or other methods.

OSHA's practical accommodation requires the shipped small containers such as, syringes or tubes (i.e., the actual container holding the hazardous chemical), to contain, at a minimum, the following information:

• Product identifier,
• Appropriate pictograms,
• Manufacturer's name and phone number,
• Signal word,
• A statement indicating the full label information for the chemical is provided on the outside package.

Additionally, the outside packaging, at a minimum, must comply with the following:

• All the applicable label elements, as defined in 29 CFR 1910.1200(f)(1).
• The outside package must be clearly marked to ensure the complete label elements are visible and it must clearly inform users that the small container must be stored in the outer container bearing the complete label. The complete label must be maintained on the outer package (e.g., not torn, defaced, destroyed).
• The manufacturer must ensure that any alternative labeling used does not conflict with any other standards. As such, the outside packaging must not present a hazard while the material is being stored.

The outside packaging described above is the object (e.g., bag, box) that the immediate product container is placed into; it does not refer to the exterior shipping container. In no case is it acceptable to only label the outside packaging; the immediate container must be labeled. To provide the most information possible, OSHA encourages manufacturers, distributors, and importers to add as much information as feasible to the small shipped container labels.

Based on the requirements listed above, the practical accommodation you propose would not meet OSHA's requirements, because it fails to include hazard statements, signal words, and precautionary statements on the label. Rather than referencing the SDS, in cases where it is infeasible to include hazard statements, signal words, and precautionary statements directly on the immediate container's label, you would be permitted to provide this information on the outer packaging, so long as a statement indicating where the full label information can be found is included on the immediate container.