Why Labeling Matters
Proper labeling of IBC totes isn't just good practice — it's a legal requirement in most commercial and industrial settings. OSHA, DOT, EPA, and FDA all have specific labeling regulations that apply to IBC containers depending on their contents and use. Fines for labeling violations can reach $15,000+ per violation under OSHA, and criminal penalties are possible for DOT violations involving hazardous materials.
OSHA Hazard Communication (HazCom)
Under OSHA's Hazard Communication Standard (29 CFR 1910.1200), every container of hazardous chemicals in the workplace must be labeled with: the product identifier (chemical name), appropriate hazard warnings, the name and address of the chemical manufacturer or responsible party. For IBC totes received from suppliers, the original manufacturer's label must be maintained. For workplace containers filled from bulk supply, employers must provide labels with at minimum the product identifier and hazard reference.
GHS Labeling Elements
The Globally Harmonized System (GHS) standardizes chemical labeling worldwide. GHS labels on IBC totes must include: product identifier, signal word (Danger or Warning), hazard pictograms (the red-bordered diamond symbols), hazard statements (describing the nature of the hazard), precautionary statements (how to handle safely), and supplier identification. All six elements are required for shipped containers.
DOT Hazmat Placarding
For IBC totes containing DOT-regulated hazardous materials in transport, additional requirements include: UN identification number marked on the container, proper shipping name, hazard class label, and packing group designation. When loading IBC totes containing hazmat onto a vehicle, the vehicle itself must display DOT placards corresponding to the hazard class of the contents.
Removing Old Labels
When repurposing used IBC totes for different contents, it's essential to completely remove or cover previous labels to prevent confusion and potential safety incidents. All traces of the previous product's labeling must be eliminated before new labels are applied. At Oklahoma IBC, all reconditioned totes are delivered with previous labels removed as part of our reconditioning process.
Best Practices
Use weather-resistant label materials for outdoor IBC totes. Replace labels immediately when they become illegible. Maintain a master label template for each product stored in IBC totes. Include the date of filling on every label. For food-grade totes, include allergen information if applicable. Train all personnel on label reading and significance. Conduct quarterly label audits to ensure ongoing compliance.