Do Consumer Products Need Secondary Containment in a Workplace? 


Author: Angela Wheeler, CIH CSP

Published on: Oct 15, 2025

Do you need secondary containment for consumer products like household cleaning chemicals used in a work environment?

Key Assumptions:

• Where are you operating? If you are in the US HazCom rules applies. If you are in Canada, WHMIS regulations apply.
• Your site has a SDS binder, and staff are trained in chemical handling and consumer product labelling.
• The items are consumer products or household chemicals used in a workplace.

General Rule of Thumb:

Secondary containment is typically required when a product poses a significant hazard, is stored in large volumes, or could result in a dangerous spill if released.

If the product is:

• Used as intended, rather than repeatedly, for an extended time or in a professional application,
• In consumer-sized quantities
• Properly labelled and listed in your SDS binder

...then secondary containment is usually not required. But check the SDS to confirm.

Let’s look at a few examples:

Aerosol Air Fresheners

• Contain flammable propellants (often butane or propane).
• Label and SDS will list flammable gas or aerosol hazard.
• Secondary containment not required for small quantities (single cans in bathrooms/offices).
• Precautions: Store away from heat sources. File the SDS is in your binder.

Verdict: Secondary containment is not needed if used as a consumer product.

Cleaning Wipes (e.g., Clorox, Lysol)

• Treated as consumer cleaning products under WHMIS unless used in industrial-scale quantities.
• Label and SDS may show eye or skin irritant hazard.
• Wipes are not liquid-filled containers, and the chemical content presents a low-risk for spills.

Verdict: Secondary containment unnecessary. Keep SDS on file.

Crafting Materials (Paints, Glues, Shaving Cream, etc.)

• Paints and adhesives can be flammable, irritants, or environmental hazards.
• Materials collected in craft supply bins would qualify as secondary containment—great!
• Smaller, single containers in a multipurpose room (e.g. one can of Gillette Foamy Shave Cream) are likely low risk.
• Gillette Foamy is an aerosol—contains flammable gas.

Verdict:

• Yes to secondary containment for a collection of similar materials (already done).
• No for personal-use products in well-ventilated rooms.
• File SDSs if available.

Hand Sanitizers

• Almost all contain ethanol or isopropanol which are flammable liquids.
• GHS classifies them under flammable liquids (Category 2 or 3).
• Large quantities (e.g. bulk jugs, refill packs) require secondary containment and careful storage.
• Individual-use bottles or wall dispensers? Low risk.

Verdict:

• Yes, if you’re storing significant volumes in one location.
• No, for individual bottles.
• Label and SDS required under WHMIS/HazCom.

Special Case: Multiple Uses Across Site

This is common and sometimes causes confusion.

Best practice: If the same hazardous product is used in multiple areas, and especially if it is decanted or stored in bulk in even one of them:

• Maintain SDS in the Master binder.
• Ensure each storage area has proper labelling and access to the SDS (can be digital).
• Secondary containment is needed where the risk of a spill, leak, or environmental release is unacceptable.

Summary Table

Final Thoughts

You're thinking along the right lines—the decision to use secondary containment is based on increased risk. If the quantity, application, and conditions increase, consider secondary containment. For your situation:

• You're doing great keeping SDSs and using containment where it makes sense.
• Continue to assess each product individually: if a single bottle of hand sanitizer does not need containment, but a supply closet with multiple litres of hazardous material should be evaluated more carefully.
• Documenting your thought process when containment is not used—this shows due diligence when an inspector or auditor asks.

The regulatory landscape is always changing. The WHMIS/Hazcom exemption for consumer product is under review. Worker training and competency with hazardous products, SDS and labelling is the best defence against exposures, reactions, spills and releases.