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Do “not for sale” samples need labeling?
The Hazard Communication Standard currently requires hazardous samples to be labeled, and it will likely remain when HCS is rewritten to accommodate GHS.
The HCS is a right-to-know law and employees have the right to know what they are handling. It doesn’t matter whether it’s for sale or not for sale. If it’s hazardous by OSHA definition, it not only is required to be labeled, but it is required to have an MSDS, too. {29 CFR 1910.1200(f)(1)}