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Selling it

Which labeling regime you are in

Updated

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This is the question that decides your labeling, and it has a clean answer: who opens the container.

Your workplace: hazard communication

If a container of hazardous chemical is in your workplace, the hazard communication standard applies. A shipped container carries the product identifier, a signal word of Danger or Warning, hazard statements, pictograms, precautionary statements, and the name, US address and US telephone number of the responsible party, prominently and in English.

A consumer’s house: the FHSA

If you sell the chemical itself to a consumer, the Federal Hazardous Substances Act reaches it, and a strong sensitizer is explicitly within its definition of a hazardous substance. That is a different set of requirements aimed at somebody with no training and no data sheet.

Which is why reselling a kit is a bigger step than it looks

Buying resin in bulk and decanting it into branded kits moves you from being a user to being a supplier of a hazardous substance to households. That is a real regulatory position, and it is one people arrive at by degrees without noticing.

Selling finished castings is neither

A fully cured coaster is an article, not a chemical, and the chemical labeling regimes do not reach it. Most makers in this craft are here, and it is worth knowing that is where the line sits.

Decanted containers at your own bench

The moment you pour resin into an unlabeled working bottle, the hazard information is gone. Labeling it with at least the product and the hazard is required where the standard applies and is simply sensible where it is not. Somebody else will pick that bottle up one day.

Supply the data sheet when you supply the chemical

If you sell the chemical onward in any form, the sheet travels with it. A kit sold without one leaves the buyer with no way to know what gloves to wear.

References

29 CFR 1910.1200, Hazard Communication. Paragraph (f) sets what a shipped container must carry: product identifier, signal word, hazard statements, pictograms, precautionary statements and the name, US address and US telephone number of the responsible party. Paragraph (g) requires a safety data sheet, in sixteen numbered sections. law.cornell.edu
16 CFR 1500.3, definitions under the Federal Hazardous Substances Act, which reaches products sold to consumers. A hazardous substance includes a “strong sensitizer”, defined as “a substance which will cause on normal living tissue through an allergic or photodynamic process a hypersensitivity which becomes evident on reapplication of the same substance.” law.cornell.edu
16 CFR 1500, the labeling requirements that follow from that definition for a hazardous substance in a container intended for household use. law.cornell.edu
Written from federal regulation and published safety guidance, not from a laboratory. Epoxy sensitization is permanent and cumulative, and nothing here is a substitute for the safety data sheet for the specific product you are using or for a conversation with your state about what you may sell. Read the SDS for your resin, not a summary of somebody else’s.