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DEPARTMENT OF OCCUPATIONAL SAFETY AND HEALTH

MINISTRY OF HUMAN RESOURCES


MALAYSIA

ASEAN-OSHNET/UNITAR-ILO REGIONAL WORKSHOP


ON THE DRAFT ASEAN GUIDELINES ON CLASSIFICATION,
LABELING AND PACKAGING (CLP) OF CHEMICALS
REPORT

With the financial support of the Government of Switzerland and the European Union.

6-8 March 2006


Grand Seasons Hotel
Kuala Lumpur
Malaysia
No. Content Page
1.0 Background 1
2.0 Objective 1
3.0 Workshop Organisation 2
4.0 Launching Ceremony 3
5.0 Workshop Session 3
6.0 Closing Ceremony 7
7.0 Resolutions on the Draft Asean Guidelines on the Classification, 8
Labelling & Safety Data Sheet
8.0 Workshop Conclusion 9
9.0 Workshop Recommendation 9
10.0 Acknowledgment 9
11.0 ASEAN OSHNET Workshop Report prepared 10
12.0 Appendix 1 : Opening Speech by Deputy Secretary of Ministry of 11
Human Resources, Malaysia
13.0 Appendix 2 : Speech by Director General of DOSH 16
14.0 Appendix 3 : Speech by Executive Director ASEAN OSHNET 19
Secretariat Malaysia
15.0 Appendix 4 : Summary of presentation papers 26
Presentation 1 : Introduction to GHS 26
Presentation 2 : Physical Hazard Classification 28
Presentation 3 : Classification of health hazards 31
Presentation 4 : Classification of Environment Aquatic Hazards 31
Presentation 5 : Classification of Mixture 34
Presentation 6 : Data Sources for Classification Purposes 35
Presentation 7 : GHS Implementation and Tools for it in Japan 38
Presentation 8 : GHS Labelling 41
Presentation 9 : Hazard communication – Safety Data Sheets 43
Presentation 10 : New Zealand Experience GHS 44
16.0 Appendix 5 : Program for ASEAN OSHNET Workshop 47

ASEAN OSHNET Workshop i


No. Content Page
17.0 Appendix 6 : Question and answer 50
18.0 Appendix 7: List of Speaker/Chairman/Facilitator 55
19.0 Appendix 8: List of Participant of ASEAN OSHNET Workshop on 56
6-8 March 2006
20.0 Appendix 9: List of Secretariat of the ASEAN OSHNET 57
Workshop
21.0 Appendix 10: Curriculum Vitae of the Presenter From 58
UNITAR/ILO (Burkhard Wagner)
22.0 Appendix 11 : Curriculum Vitae of the Presenter From 59
UNITAR/ILO (Wayne Creaser)
21.0 Appendix 12 : Curriculum Vitae of the Presenter From Japan 60
(Hiroshi Jonai)
22.0 Appendix 13 : Curriculum Vitae of the Presenter From New 61
Zealand (Barry Dyer)
23.0 Appendix 14 : Exercise 1 (Classification of a Substance ) 62
24.0 Appendix 15 : Exercise 2 (Classification of a Mixture) 64

23.0 Appendix 16 : Assignment on Classification 68

24.0 Appendix 17 : Assignment on Labelling 71

25.0 Appendix 18 : Assignment on Safety Data Sheet 75

26.0 Appendix 19 : Draft ASEAN Guidelines on Chemical 77


Classification, Labelling & Safety Data Sheet 2006

ASEAN OSHNET Workshop ii


1.0 Background

The globally Harmonised System (GHS) is the vehicle being promoted by both
the United Nations (UN) and the Asia Pacific Economic Conference (APEC) for
worldwide harmonisation of rules regarding classification and labelling of chemicals.
The GHS is common approach for definition and classification of hazards and a
system to ensure consistent worldwide hazard communication, through uniform
hazard information on labels and safety data sheet. It provides the underlying
infrastructure for establishment of national comprehensive chemical safety programs.
In ASEAN, there are ten nations with different classification & hazard communication,
systems in place. The result is increased cost of doing business between ASEAN
nations from reclassification & rebelling to meet each national requirements.
Therefore, there is urgent need to discuss among government authorities in ASEAN
the need to harmonise the different systems through the adoption of an ASEAN
guideline on chemical classification, labelling and safety data sheet based on the
international accepted Globally Harmonised System for hazard classification and
labelling, in short the GHS.

2.0 Objective

The main goal of the workshop is to bring together key representatives from
governments of the ASEAN to discuss strategies and capacities in implementing the
GHS at the regional level. The objectives of the workshop are as follow:

1. To provide the awareness & insight on the GHS to workshop participants from
the 10 ASEAN countries;
2. To acquire knowledge in understanding the GHS;
3. To share experiences in implementing the GHS in the ASEAN countries;
4. To deliberate and discuss on the principles and the content and formulating of
the proposed ASEAN Guidelines on Chemical Classification, Labelling and
Safety Data Sheet.

ASEAN OSHNET Workshop 1


3.0 Workshop Organisation

This three (3) days workshop was organised under the ASEAN OSHNET as a
project under programme area of Standards [Malaysia] where it located in Agenda
Item number seven (7) naming by Status Report on the Implementation of the
Activities under the ASEAN OSHNET Plan of Action. This project has been decided
on 6th ASEAN OSHNET Coordinating Board Meeting on 17-18 March 2005 at Ha
Long, Quang Ninh, Vietnam. The workshop was served for the Asean Country. The
countries that participated this workshop are Brunei, Cambodia, Indonesia, Laos,
Myanmar, Singapore, Thailand, Vietnam and Malaysia as a host country. The
Philippines did not participated in this workshop.
There four (4) resource persons on GHS that contributed to this workshop,
were Dr. Burkhard Wagner from Germany, and Mr. Wayne Creaser from Australia as
a representative of UNITAR-ILO. Prof. Dr. Hiroshi Jonai from Japan represented the
experience of implementation GHS on Japan. Mr. Barry Dyer from New Zealand
represented the experience of implementation GHS. Please refer to Appendix 10, 11,
12 and 13 on their curriculum vitae.
The list of ASEAN OSHENET Workshop participants is shown in Appendix 8.
List of speakers, chairman of session and facilitators is given in Appendix 7 and the
list of workshop’s secretariat is in Appendix 9.
The UNITAR and ILO supported this workshop by sending two (2) experts and
allocating a financial contribution of USD10,000 (RM37,000) to financially support the
main bulk of the workshop expenses of USD13,650 (RM50,500). The difference was
paid for the Malaysian Government.

ASEAN OSHNET Workshop 2


4.0 Launching Ceremony
The launching ceremony of ASEAN OSHNET Workshop was officiated by Mr.
Adzmi Mohd Sani, Deputy Secretary of Ministry of Human Resources Malaysia. This
ceremony was also attended by Ir. Abu Bakar Che’ Man, Director General of the
Department of Occupational Safety and Health (DOSH) and Ir. Dr. Johari Basri,
Executive Director of ASEAN OSHNET Secretariat. Please refer to Appendix 1, 2 and
for their welcoming and opening speeches. About 70 persons attended the opening
ceremony including 22 participants from ASEAN and 11 Senior Officers from DOSH.

5.0 Workshop Session


The workshop programme is given in Appendix 5. The summary of the
presentation are shown below. There are two (2) exercises held in day two (2). Please
refer Appendix 14 and 15. Group assignments are located in Appendix 16, 17 and 18.
These assignment based on the draft of Asean Guidelines on Chemical Classification,
Labelling and Safety Data Sheet 2006. Refer to Appendix 19.

PRESENTATION 1
INTRODUCTION TO GHS
By Wayne Creaser
Mr Wayne Creaser talked about the introduction of GHS which include the
history, scope and application of GHS. He also touched about the key elements and
GHS implementation in Australia.

PRESENTATION 2
HYSICAL HAZARD CLASSIFICATION
By Burkhard Wagner
Mr Burkhard Wagner, expert from UNITAR and originally from Germany talked
about the Physical Hazard Classification. In his speech, he explained the definitions of
gas, solid and liquid. He also explained about the definitions of explosives substances,
flammable gases, flammable aerosols, oxidizing gases, flammable liquids, flammable
solids, oxidizing liquids, oxidizing solids, organics peroxides and corrosive to metal.

ASEAN OSHNET Workshop 3


PRESENTATION 3
CLASSIFICATION OF HEALTH HAZARDS
By Wayne Creaser
In the third presentation, Mr Wayne Creaser briefly talked about the
Classification of Health Hazards. In this presentation, he explained that health hazards
can be can be categorized into various hazard categories, i.e. acute toxicity, skin
corrosion or irritation, serious eye damage or eye irritation, respiratory or skin
sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity, specific
target organ systemic toxicity (single exposure), specific target organ systemic toxicity
(repeated exposure) and aspiration hazard.

PRESENTATION 4
CLASSIFICATION OF ENVIRONMENTAL AQUATIC HAZARDS
By Burkhard Wagner
Mr Burkhard Wagner talked about the Classification of Environmental Aquatic
Hazards. In his presentation, he explained the Data Elements for Classification such
as acute aquatic toxicity, bioaccumulation potential, rapid degradability and chronic
toxicity, and also provides the definitions of these terminologies.

PRESENTATION 5
CLASSIFICATION OF MIXTURES
By Wayne Creaser
Mr Wayne Creaser explained the classification criteria for mixtures based on
the classification criteria for substances, taking into consideration any impurities,
additives or individual constituents of a substance that exceed the cut-off
value/concentration limit for a given hazard class. He explained that if the data are not
available for the mixture itself, bridging principles such as dilution, batching,
concentration of mixtures of the highest category within one hazard class, interpolation
within one toxicity category, substantially similar mixtures and aerosolized mixtures
should be applied.

ASEAN OSHNET Workshop 4


PRESENTATION 6
DATA SOURCES FOR CLASSIFICATION PURPOSES
By Burkhard Wagner
The data sources for classification purposes are the tools to classify the
chemical from any sources. In this presentation, Dr Wagner explained data quality and
good laboratory practices. He also discussed about the weight of and data quality
scoring guide. Data are categorized into six (6) categories.

PRESENTATION 7
GHS IMPLEMENTATION AND TOOLS FOR IT IN JAPAN
By Hiroshi JONAI
Prof. Hiroshi Jonai is a GHS expert from Japan who had willingly participated in
this workshop to share Japan’s experiences in implementing the GHS. He briefly
explained the current regulations for chemical control and hazard communication in
Japan. He also touched about the issues in the GHS implementation such as big
coverage of substances and mixtures under GHS, collection of hazard data of
chemicals, not regulated by laws or regulations, independent hazard communication
system not related to risk management and clearance of duplication of label elements.
In Japan, GHS implementation includes GHS committee consisted of every Ministry
concerned (MHLW, METI, MoE, MIC, MAFF, MLIT and MOFA) established 2001,
translation of GHS Text into Japanese: First revised version is available from the web-
site of METI, MoE and MHLW), seminars on GHS (>2,000 participants) and
pamphlets for raising awareness.

PRESENTATION 8
GHS LABELLING
By Wayne Creaser
Mr Wayne Creaser talked about the importance of labelling in which the
comprehensibility of hazard communication elements is the key elements to inform the
public about chemical hazards. The guiding principles are (a) information should be
conveyed in more than one way, (b) comprehensibility should take account of existing
information (literature, studies and data), (c) phrases indicating degree of hazard
should be consistent across different hazard types, (d) words and phrases should
retain comprehensibility when translated into other languages, (e) format and colour of
ASEAN OSHNET Workshop 5
the label elements, and (f) SDS format should be standardized. Information required
on a GHS label are pictograms, signal words, hazard statements, precautionary
statements and pictograms, product identifier and supplier information.

PRESENTATION 9
HAZARD COMMUNICATION – SAFETY DATA SHEETS
By Wayne Creaser
Mr. Wayne Creaser emphasized the role of safety data sheets in providing
comprehensive information of a substance/mixture for use in workplace, the
information provided enables the employer to develop worker protection measures
specific to the workplace and to consider measures to protect the environment. SDS
also should be provided for all substances/mixtures meeting GHS harmonized criteria
for physical, health and environmental hazards, in the concentration exceeding cut-off
values. The 16-section format of SDS are identification, hazard(s) identification,
composition/information on ingredients, first-aid measures, fire-fighting measures,
accidental release measures, handling and storage, exposure controls/personal
protection, physical and chemical properties, stability and reactivity, toxicological
information, ecological information, disposal considerations, transport information,
regulatory information and other information.

PRESENTATION 10
NEW ZEALAND EXPERIENCE IN GHS
By Barry Dyer
Mr. Barry Dyer, from New Zealand shared the New Zealand industry experience in
implementing GHS. He talked about the basic requirements that are reflected in New
Zealand’s international obligations, industry best practice, performance based and the
commonality with Australia. He also talked about New Zealand’s national performance
standards, professional qualifications for enforcement officers, test certifiers and
approved handlers, quality assurance accreditation for test certifiers and trainers, and
training courses using reference material and training aids. Finally, he talked about the
compliance tools used in New Zealand.

ASEAN OSHNET Workshop 6


6.0 Closing Ceremony
Ir. Zainuddin Abdullah, Deputy Director General of DOSH officiated the closing
ceremony of ASEAN OSHNET Workshop. He also handed over certificates of
attendance to all the participants. The Deputy Director General in his closing remarks
thanked the organizing committee for their successful organization of the workshop.
He thanked the UNITAR/ILO for their support & contributions. He also thanked all the
experts that have contributed to the success of the workshop.

ASEAN OSHNET Workshop 7


7.0 Resolutions on the Draft Asean Guidelines on the Classification, Labelling &
Safety Data Sheet
7.0.1 General
1. Consumer chemicals will not be excluded if it is to be used at the place of
work rather than for domestic purposes.
2. Hazardous chemicals to be defined in the guidelines
3. To clarify & refined on the definition of ‘articles’
4. To include provision on training.
5. Technical guidance required for certain issues such as classification.
6. Promotion of guidelines by ASEAN-OSHNET and member countries.
7. Purpose of guidelines to be clarified.
8. Schedule 1 to be consistent with GHS

7.0.2 Classification
1. Classification duty only on the manufacturer, formulator & the importer.
2. Classification to be reviewed periodically or when there is new and
significant information
3. The definition and/or registration of the competent classifier to be left to the
legal requirements of each country

7.0.3 Labelling
1. Precedence of symbols for physical hazards to be deleted
2. Labelling sizes not to be included in this guidelines unless it has been
determined by the UN expert sub-committee.
3. Sample labels to be included
4. Format and positioning of label elements to be addressed in guidelines.
5. Selection of precautionary statements to be included.
6. Cut-off limits for labelling to be consistent with SDS

7.0.4 Safety Data Sheet


1. To delete chapter on SDS except where countries have options.
2. Confidential Business Information, CBI to be excluded, for countries to define.
3. Translation to be done by competent person

ASEAN OSHNET Workshop 8


8.0 Workshop Conclusion
The workshop was successfully run as planned according to the programme and
concludes with the resolutions on the draft Asean Guidelines on the Classifications,
Labelling & Safety Data Sheet.

9.0 Workshop Recommendation


The draft guideline will be finalized and submitted to the ASEAN Coordinating
Board Meeting for their deliberation and endorsement.

10.0 Acknowledgment
The organizing committee would like to thank all of the following countries,
organizations and individuals that have contributed in a way or the other toward the
success of this workshop:
a) UNITAR/ILO and donor countries
b) ASEAN OSHNET Secretariat
i) Government of Brunei Darussalam
ii) Government of Cambodia
iii) Republic of Indonesia
iv) Democratic Republic of Laos
v) Republic of Myanmar
vi) Republic of Singapore
vii) Thailand
viii) Vietnam
c) UNITAR experts – Dr. Burkhard Wagner and Mr. Wayne Creaser
d) Prof. Dr. Hiroshi Jonai from Japan
e) Mr. Barry Dyer from New Zealand Chemical Industrial Council
f) Grand Season Hotel, Kuala Lumpur
g) Prime Ministers Department
h) Ministry of Human Resources Malaysia
i) Ministry of Agriculture & Agro based Product
j) MTUC
k) CICM
l) Department of Occupational Safety and Health Malaysia (DOSH)
m) National Institute of Occupational Safety and Health Malaysia (NIOSH)
ASEAN OSHNET Workshop 9
11.0 ASEAN OSHNET Workshop
Report prepared by:

(KASMAN NASIR) (AZMIR ISMAIL)


Assistant Director Assistant Director
DOSH, DOSH,
Malaysia Malaysia

Reviewed by:

(HAJI ANUAR MOHD MOKHTAR)


Director
Chemical Management Division,
Department of Occupational Safety and Health,
Malaysia

Approved by:

(IR ZAINUDDIN ABDULLAH)


Deputy Director General (Operation)
Chemical Management Division,
Department of Occupational Safety and Health,
Malaysia

ASEAN OSHNET Workshop 10


Appendix 1
OPENING SPEECH
Datuk Abdul Rahman Bakar
Deputy Minister of Human Resource, Malaysia
Read by Mr. Adzmi Mohd Sani
Deputy Secretary of Ministry of Human Resources, Malaysia

ASEAN OSHNET Workshop on the Draft ASEAN Guidelines on Classification,


Labeling and Packaging (CLP) Chemical

6th March 2006 ( Monday), 9.00 am


Grand Seasons Hotel, Kuala Lumpur

Good morning and welcome to Kuala Lumpur, Malaysia,

First and foremost, I wish to express my gratitude and heartiest thanks to the
organizing committee for inviting me to give a few words and officially open the
ASEAN OSHNET Workshop on the Draft ASEAN Guidelines on Classification,
Labelling and Packaging (CLP) Chemical. I hope that all ASEAN delegations will take
this opportunity not only to exchange ideas and opinions but also to visit the beautiful
of Kuala Lumpur, the heart of Malaysia.

Ladies and gentlemen,

Chemicals have become a part of our life, sustaining many our activities, preventing
and controlling disease and increase productivity. However, sometimes these
chemicals can turn dangerous, becoming hazardous to human health and safety,
properties and the environment when handled improperly. In order to safely use
chemical and mitigate the incidences of injury or poisoning or diseases arising from
the use of chemicals, the information concerning their hazards should be effectively
communicated to workers and public.

ASEAN OSHNET Workshop 11


Many existing national and regional chemical hazards communication systems are
similar in intent (they are designing to protect people from experiencing adverse
effect), there are significant differences in their specific provisions with regard to the
criteria used to classify chemicals, the warning phrases and symbols or other hazard
communication components used to convey the information. The result is a patchwork
of sometimes conflicting and diverse national and international requirements.

Ladies and gentlemen,

The Globally Harmonised System of Classification and Labelling of Chemicals, in


short GHS is a common and coherent approach to defining and classifying hazards
and a system to ensure consistent worldwide communication through uniform hazard
information on labels and safety data sheet. It provides the underlying infrastructure
for establishment of national, comprehensive chemical safety programs. There will be
4 key sectors affected by the GHS Implementation at the National level, i.e. the
industrial workplace; the agricultural sector; the transport sector and consumer
products.

The establishment of an international structure for harmonizing classification and


labelling systems for chemicals would have a beneficial impact on chemical trade, on
the exchange of information related to chemicals, on the cost of risk assessment and
management of chemicals, and ultimately on the protection of workers, the general
public and the environment.

Ladies and gentlemen,

I was informed that the GHS was developed as a result of Agenda 21, agreed in 1992
at the United Nation Conference on the Environment & Development (UNCED) held in
Rio de Janeiro, Brazil. From this conference, six programme areas were established
to strengthen national and international effort related to environmentally sound
management of chemicals. Agreements in this conference were endorsed by the
United Nations General Assembly.

ASEAN OSHNET Workshop 12


I believe, an important driving factor for creation of the GHS is the similarity in the
hazards communication systems with regards to the criteria used to classify the
chemicals, the warning phrases and symbols or other hazard communication
components used to convey the information. Failing to standardised lead to
conflicting and diverse national and international requirements.

These are due to the variations in classification criteria where the same chemical may
be classified as having different degrees of hazard, and thus require different warning
statements. It all depends on the classification system being applied in a given
situation. Inevitably, symbols and terminology also vary from system to system. For
example, a chemical in one country may be classified as being flammable for purpose
of transport, but not for workplace use. Or it may be considered carcinogenic in one
country, but not in another.

Ladies and gentlemen,

I glad to note that most of the ASEAN countries indicated their intent to implement the
GHS. This is based on survey report prepared by UNITAR/Ministry of environment
Japan ASIA-Pacific Regional GHS that was initiated in 2004. Nine out of the 10
ASEAN countries already have chemical classification systems in at least one sector
out of the 4 covered under GHS. A few countries like Malaysia, Indonesia and
Thailand are in the stage of preparing for establishing new legislation or administrative
procedures.

Through the ASEAN OSHNET Coordinating Board Meeting in 2002, Malaysia was
entrusted to develop as ASEAN guidelines on Classification, Labelling & Packaging.
This guideline was initially to be based on the Malaysian Occupational Safety & Health
(Classification, Packaging & Labelling of Hazardous Chemicals) Regulations 1997 and
its guidelines. Later on, a workshop held to discuss the guideline was held in Malaysia
in 2002 concluded that the guidelines should be based on the GHS as the
implementation of the GHS worldwide was inevitable in the future.

The proposal of the workshop to adopt GHS as the basis for these guidelines was
endorsed by ASEAN-OSHNET Coordinating Board in 2003. Before the details of the
ASEAN OSHNET Workshop 13
guidelines could be discussed, the workshop participants will be trained on the
essentials of GHS and UNITAR was invited to give technical inputs on the GHS. I
would like to thank the UNITAR for its willingness to collaborate with ASEAN-OSHNET
on GHS training for officials from ASEAN in this workshop.

Ladies and gentlemen,

As for the government of Malaysia, the system on hazard classification and


communication has been introduced to Malaysia by our Ministry of International Trade
and Industries (MITI) who had attended 2002 APEC Ministers meeting which all APEX
members ought to work towards GHS implementation by 2006. MITI has taken the
step to coordinate steps toward National GHS implementation by forming The National
Coordinating Committee for GHS Implementation early of this year. This inter-agency
Coordinating Committee comprises representatives from relevant government
agencies and is chaired by a senior official from the Ministry of International Trade and
Industry. This should pave the way for inter-agency cooperation and harmonization of
chemical hazard communication systems in Malaysia with the GHS.

Under the Ministry of Human Resource, the Department of Occupational Safety and
Health committed to adopt the GHS as the basis in the existing legislations. The
existing regulatory mechanism can be utilized to accommodate the GHS by amending
the existing relevant legislations such as Occupational Safety and Health
(Classification, Packaging and Labelling of hazardous Chemicals) Regulations 1997.

Ladies and gentlemen,

On behalf on the government of Malaysia, I am obliged with the participating ASEAN


countries towards the development of ASEAN guidelines on Classification, Labelling
and Packaging Chemical to adopt GHS as basis. I hope that the workshop will come
to the consensual decision from ASEAN participants on the proposed draft whether to
adopt full GHS Classification and/or for individual nation to determine building block
to be adopted in your respective legislation.

Ladies and Gentlemen,


ASEAN OSHNET Workshop 14
To conclude, I would like to express my heartiest appreciation to all of you for your
support and experiences shared in this workshop. Special thanks to United Nation,
Institute for Training and Research, (UNITAR)/International Labor Organization (ILO)
and ASEAN OSHNET Secretariat.

With that, I officially declared the ASEAN OSHNET Workshop on the Draft ASEAN
Guidelines on Classification, Labelling and Packaging (CLP) Chemical open.

Thank you.

ASEAN OSHNET Workshop 15


Appendix 2
Speech by
Ir Haji Abu Bakar Che Man
Director General
Department of Occupational Safety and Health Malaysia

ASEAN OSHNET Workshop on the Draft ASEAN Guidelines on Classification,


Labelling and Packaging (CLP) Chemical

6th March 2006 ( Monday), 9.00 am


Grand Seasons Hotel, Kuala Lumpur

Yg. Bhg En Adzmi Mohd Sani


Deputy Secretary General, Ministry of Human Resources, Malaysia,

Yg. Bhg. Dato’ Dr Ir. Johari Basri


Executive Director ASEAN OSHNET Secretariat,

Mr. Wayne Creaser


Senior Special Fellow, Department of Employment and Workplace Relation,

Distinguished Speakers:

Distinguished guests,

Participants from ASEAN countries,

Ladies and Gentlemen,

On behalf of the organizing committee, I wish to express my appreciation to Yang


Bhg. En Adzmi Mohd Sani, Deputy Secretary General of Ministry Of Human
Resources, for his consent to deliver an opening address for this ASEAN OSHNET
ASEAN OSHNET Workshop 16
Workshop on the Draft ASEAN Guidelines on Classification, Labeling and
Packaging (CLP) of Chemicals.

I would also like to welcome all participants from ASEAN member countries for your
presence in this workshop. The organizing committee hopes that your presence will
contribute in realizing our aim to streamline the ASEAN member countries legislation
and guidelines on classification, labeling and packing of chemicals with the Globally
Harmonized System.

Ladies and Gentlemen,

The Globally Harmonized System or the GHS implementation and chemical hazard
communication has emerged as one of the top priority of chemical management in the
ASEAN region. Majority of the ASEAN member countries reported that one of the
causes of occupational and environmental health illnesses is due to the lack of
comprehensive hazard communication elements in the legislative system of the
countries.
I am happy to note that the World Summit for Sustainable Development has initiated
the WSSD Global Partnership for capacity Building to implement the Globally
Harmonized System (GHS). UNITAR/ILO was the focal point for this capacity building
programme, which are funded by the European Commission and the Government of
Switzerland. This particular workshop is one of the regional capacity-building activities
focused for ASEAN member countries. Before this workshop, there were three other
country-based pilot projects that have been organized in Indonesia, Thailand, and The
Philippines.

The Department of Occupational Safety and Health (DOSH), Ministry of Human


Resources Malaysia is honored to have been given the opportunity to organize this
workshop, supported by the ASEAN OSHNET Secretariat and the United Nation
Institute of Training and Research (UNITAR).

The objectives of the workshop are:

to acquire knowledge and further understanding on the Globally Harmonized System;


ASEAN OSHNET Workshop 17
to share experiences in implementing the GHS in the respective ASEAN member
countries ; and

to discuss the proposed draft on ASEAN Guidelines on the Classification, Labelling


and Packaging of chemicals based on the GHS.

Ladies and Gentlemen,

This 3-days workshop will consist of presentation by experts from UNITAR, Australia
and Japan on subjects related to GHS. There will also be a presentation and
discussion on the proposed draft of ASEAN Guidelines on Classification, Labeling and
packing of chemicals by Department of Occupational Safety and Health, Malaysia.
The organizing committee is grateful and honored to have Mr. Buckhard Wagner from
UNITAR, Mr. Wayne Creaser from Australia, Mr. Hiroshi Jonai from Japan and Mr.
Barry Dyer from New Zealand as expert speakers for this workshop. All of us truly
appreciate your presence and contribution to the workshop.

Ladies and Gentlemen,

To conclude, on behalf of the organizing committee I would like to express my


heartiest appreciation to the UNITAR/ILO for their financial support and most
importantly coordinating the presence of fellow experts on GHS for this workshop. I
would also wish to thank the ASEAN OSHNET Secretariat for their valuable support in
coordinating participation of delegates from ASEAN member countries. I hope this
workshop, in our own way, will contribute towards the ultimate goal of ensuring that
chemical hazards information is made in a harmonized and comprehensible format in
and to countries around the world.

Thank you.

ASEAN OSHNET Workshop 18


Appendix 3
Speech by
Dato’ Ir. Dr. Johari Basri
ASEAN OSHNET Secretariat Malaysia

ASEAN-OSHNET Secretariat

ASEAN-OSHNET/UNITAR-ILO Workshop on ASEAN Guidelines for


Classification, Labelling and Packaging of Chemicals
Welcome Address
Dato’ Ir Dr. Johari Basri
Executive Director, ASEAN-OSHNET Secretariat, Malaysia
Executive Director, National Institute of Occupational Safety and Health (NIOSH),
Malaysia

Yang Berusaha Encik Azmi Mohd. Sani, Deputy Secretary General, Ministry of Human
Resources, Malaysia;

Yang Berusaha Ir Hj. Abu Bakar Che Man, Director General, Department of
Occupational Safety and Health, Malaysia;

Technical Experts from The United Nations Institute and Research (UNITAR)

Our Dear Friends from ASEAN-OSHNET Member Countries;

Colleagues from the Ministry of Human Resources;

Guests; and

Ladies and Gentlemen;

First of all, on behalf of ASEAN-OSHNET Secretariat, I would like to congratulate the


Department of Department of Occupational Safety and Health, Malaysia, especially
ASEAN OSHNET Workshop 19
the Workshop Organising Committee, for having worked very hard in order to
successfully organise and host this ASEAN-OSHNET/UNITAR-ILO Workshop on
ASEAN Guidelines for Classification, Labelling and Packaging of Chemicals, which
has brought us all together with our friends from all over South East Asia today. I am
convinced that the organisation of this Workshop has taken not a little amount of
effort, energy, commitment and sacrifice, and I am sure all of us in the whole ASEAN-
OSHNET organisation can be proud of you all for that. I would also like to convey our
gratitude to the United Nations Institute for Training and Research (UNITAR) for: (1)
having provided a generous amount of funding to support this Workshop; and (2)
having provided expert technical support in the form of subject specialists speaking
and teaching on UNITAR’s behalf. Last but not least, I would like also to commend all
ASEAN-OSHNET Member Countries for having made the effort to participate in this
Workshop. We regret though that Laos and Philippines are unable to be with us today.

Ladies and Gentlemen;

South East Asia has always been a region of harmony and cooperation. In this region,
community interests almost always prevail over those of the individual. Rugged
unilateral individualism, especially one that tends to be at odds with the interests of the
wider community, is a rarity, very much the exception rather than the norm.
Everywhere ― in the corporate boardrooms, in the city streets, in the rural paddy
fields ― people are always helping one another make something new, something
good and something useful that will make a positive difference in their lives. They
continually support one another in their toil, in both fair and foul weather, in their
struggle for existence and survival.

When it is time to plant the paddy seedlings, for example, you only have to tell one
neighbour and the whole village will come running to help out. Time for the harvest?
Just pass the message on to the next village. A death in the family? The folks around
you will come bringing plenty of aid and comfort ― without you having to call them. A
wedding in the area? The womenfolk will just team up, pooling materials, resources
and expertise and cooking in concert to prepare food for the feast.

ASEAN OSHNET Workshop 20


In the coastal areas, fishermen that have cast a large net into the sea just have to yell
for helping hands from everybody nearby. There is always an exuberant mustering of
a force strong enough to pull in the main ropes and haul the catch ashore. Alongside
the big brawny men of the sea, old folks, women and even children pitch in to heave
and tug to a man’s counting. When the catch is huge and spirited, the effort to land it
grows in the same proportion. Passers by are invited to join in and often they happily
do.

Different forms of collaboration thus occur out of the natural penchant for cooperation
and harmony among South East Asians. They have taken place throughout all of
South East Asia under various names. They are called “gotong royong” in Malay-
speaking Nusantara (the Malay Archipelago, i.e. Indonesia, Malaysia and Brunei),
“samakhee” in Laos and Thailand, “la lahn dum la rach” in Vietnam, “phyi khaing phyu”
in Myanmar, “saburosthor” in Cambodia, “bayanihan” in the Philippines and “chai sam
hup chop” among South East Asians of Cantonese descent. It is this common spirit
that has been, still is and should always be the driving force for ASEAN regional
cooperation and integration, and it is what we in ASEAN-OSHNET should harness
and exploit for the good of workers all over South East Asia.

Ladies and Gentlemen;


The word ‘harmony’ too, for instance, has an interesting development. It comes from
the Greek ‘harmos’, meaning joint. Thus, when many different things are joined
together in perfect fit, or many different people or groups of people work together in
perfect coordination, they are both said to be ‘in harmony’. Thus, for any collaborative
venture to work best, harmony must first exist. In the musical sense, for example,
when good harmony is present in a concert, beautiful music is produced.

Harmony exists in nature in various forms and to various degrees. However, civilised
societies cannot leave it to nature ― including human nature ― the responsibility for
building and maintaining harmony between people, between nations or even between
regions, or we run the risk of having whatever harmony existing reduced to the lowest
level, i.e. the law of the jungle, as has occurred many times in the past.

ASEAN OSHNET Workshop 21


Harmony, therefore, has been a very important principle in ASEAN, and will always
remain so. In the political and trade realms, harmonisation of standards and rules
among member countries has been instrumental in bringing ASEAN collectively to
where it is today. In the face of globalisation and its attendant challenges,
harmonisation efforts are taking on a level of commitment and urgency such as has
never been seen before.

In relation to this, the field of OSH is not spared too, and the need for harmonisation
has reached new levels of importance and must therefore be properly and duly
addressed. ASEAN-OSHNET, therefore, as the main platform for ASEAN cooperation
in OSH, thus has its own special role to play with regard to harmonisation. In the
aspect of chemical safety, for example, this ASEAN-OSHNET/UNITAR-ILO Workshop
on ASEAN Guidelines for Classification, Labelling and Packaging of Chemicals, as I
understand it, is intended to produce a set of regional Guidelines consistent with the
UN-advocated Globally Harmonised System for Classification, Labelling and
Packaging of Chemicals (GHS) for use throughout the entire ASEAN region. These
Guidelines, when finalised and completed, will then be used by all ASEAN countries to
guide them in drawing up their own national regulations on classification, labelling and
packaging of hazardous chemicals. The Guidelines are expected to cover not only
workplace chemical-related safety and health, but also be comprehensive enough to
address the same concerns in the agriculture, transport and consumer sectors, for
which another Workshop is being held at national level later this week.

Ladies and Gentlemen;


ASEAN has now become a major player in international trade, and trading in the
international marketplace has its own challenges. Trade barriers of different forms can
arise due to factors such as regulatory restrictions, conformity assessment
requirements and also due to differences in product standards. Individual nations
impose technical regulations and associated product standards based on their own
domestic social and economic considerations. When domestic conditions between
different nations differ, their regulations and standards will often tend to differ too.
Manufacturers, suppliers, importers and exporters of regulated products who are
engaged in international trade then have to comply with these different regulations and
standards.
ASEAN OSHNET Workshop 22
In situations where difficulties are encountered in complying or demonstrating
compliance through conformity assessment systems, regulations and associated
product standards can inadvertently give rise to technical barriers to free trade. Very
often when these occur, they are due the differences in regulations and standards
between nations. Many experts envisage that barriers can be significantly reduced, if
not eliminated altogether, by adopting a common set of internationally aligned or
harmonised regulations or standards. It is to fulfil this very important function that
universal standards organisations such as the International Organisation for
Standardisation (ISO) and the International Electrotechnical Commission (IEC) have
been established.

International Standards are widely adopted at the national or regional level and
applied by multinational manufacturers, service providers, trade organisations,
purchasers, consumers, government agencies, testing laboratories and other
interested parties. Since these standards generally reflect the best experiences of
industry, researchers, consumers and regulators worldwide, and cover common needs
in a wide range of countries, they constitute one of the important bases for the
removal of technical barriers to international trade.

Ladies and Gentlemen;


The national use of voluntary international standards has not progressed to the same
level in all sectors. For instance, OSH standards, although often adopted by
developing countries from those of leading developed countries, have generally been
substantially modified and altered to suit domestic conditions. Only in relatively recent
years has there been significant activity in the development of international standards
in the OSH sector. One important result of such activity is the Occupational Safety and
Health Management System (OSH-MS) initiated and developed by the ILO, which has
now been adopted and adapted by several countries. In Malaysia, for instance, it has
been modified and made into a Malaysian National Standard titled Occupational
Safety and Health Management System Guidelines, i.e. MS 1722: 2003.

Among the likely future priorities of ASEAN-OSHNET that we all should consider,
therefore, is to secure a strong commitment towards integration and harmonisation of
ASEAN OSHNET Workshop 23
OSH standards, including regulations, codes and guidelines, and OSH-related
standards for products and services. This would both help move OSH among ASEAN
countries to a higher plane as well as remove OSH-related technical barriers to
international trade. It could also possibly help facilitate increased regional trade and
cooperation in OSH products, expertise and services, which can only work in favour of
OSH capacity and capability enhancement in the region.

In this respect, therefore, the proposed “ASEAN Guidelines on Classification,


Labelling and Packaging and of Chemicals” ― one of several current ASEAN-
OSHNET projects ― which are expected to incorporate the principles contained in the
Globally Harmonised System for Classification, Labelling and Packaging of Chemicals
(GHS), is a most excellent example of this new thinking.

Ladies and Gentlemen;


On ASEAN-OSHNET in general, I would like to convey my concern about the
commitment of some ASEAN-OSHNET Member Countries to ASEAN-OSHNET
activities, such as ASEAN-OSHNET Workshops. I would like to remind Member
Countries that they may need to revitalise their commitment to these ASEAN-
OSHNET activities, in order to sustain the growth, development and even relevance of
ASEAN-OSHNET. Not all Host Countries have easy access to funding, and even the
ASEAN-OSHNET Secretariat itself has not been that successful in sourcing for funds,
although we believe and hope we are getting better at it.

The point is, it’s not that easy to make people part with their money. In that sense,
therefore, we all have to take our hats off to UNITAR. In relation to that, with due
respect and while acknowledging the problems that may be faced by some Member
Countries, I would like to urge all Member Countries in general to make a special effort
to renew their pledge to the principle of cost sharing that has previously been agreed
by all. Nevertheless, having said that, any Member Country wishing to host any
ASEAN-OSHNET activity is still most welcome to seek the assistance of ASEAN-
OSHNET Secretariat to facilitate the sourcing of funding, giving ample, very ample
advance notice, and ASEAN-OSHNET Secretariat will still collaborate with Host
Countries to try our best together to support Member Countries facing difficulty
attending.
ASEAN OSHNET Workshop 24
Ladies and Gentlemen;
This ASEAN-OSHNET/UNITAR-ILO Workshop on ASEAN Guidelines for
Classification, Labelling and Packaging of Chemicals, I am sure, is most timely and
will I hope eventually provide us all with the right strategy to align and harmonise our
currently vastly diverse national rules on classification, labelling and packaging of
chemicals in ASEAN. This I hope will minimise the adverse effects of such diversity on
international trade while also addressing their implications on work safety and health.
At the same time, this Workshop would also provide all participants as well as some
others among us the opportunity to engage in mutually enriching social, educational
and cultural exchange among themselves.

I hope all participants will devote all their attention to the matters being discussed and
deliberated on over the next three days, so that at the end of the Workshop they can
go back home all the richer and all the better-equipped in information, knowledge and
wisdom, which they can then apply for the improvement of workplace safety and
health in their respective countries. On the other hand, like the man said, “All work and
no play makes Jack a dull boy”. So, needless to say, besides the academic stuff, I
hope all of you will spend the other parts of your time here mixing around, getting to
know one another, making friends, building networks etc., all for the sake of ASEAN
cooperation and integration, especially in the field of Occupational Safety and Health.

Speaking of play, making friends and building networks, ASEAN-OSHNET


Secretariat/NIOSH Malaysia are jointly organising an ASEAN-OSHNET Friendship
Dinner, at NIOSH Malaysia premises, at 7.30 p.m. on Thursday, 9th March 2006, just
a day after this Workshop ends. Therefore, I would like to use this opportunity to
welcome and invite you all to attend this Dinner. We have also planned a special post-
workshop programme for Workshop Participants, comprising a NIOSH Malaysia
Corporate Visit, Priority Training Needs Discussion and “Cruise Tasik” (Putrajaya Lake
Cruise). I understand some participants have already made arrangements to return
home on Wednesday, 8th March 2006. However, I hope they will make an effort to
extend their stay by one more day if possible, for us all to gather together, talk, work
and play, all for the sake of ASEAN cooperation and integration. With that, I would like
to end. Thank you.
ASEAN OSHNET Workshop 25
Appendix 4
Summary of presentation papers.
Presentation 1 : Introduction to GHS
By Wayne Creaser
™ Introduction to GHS was the first presentation at the ASEAN OSHNET
Workshop. It touch about the history, scope and application of the Globally
Harmonized System of Classification and Labelling of Chemicals (GHS), key
elements of GHS and GHS implementation in Australia
History
1992 UNCED Agreement, endorsed by the UN General Assembly:
A globally-harmonised hazard classification and compatible labelling
system, including material safety data sheets and easily understandable
symbols, should be available, if feasible, by the year 2000
Scope
The Globally Harmonized System of Classification and Labelling of Chemicals:
• Is a comprehensive tool that harmonises chemical classification and hazard
communication
• Covers all hazardous chemical substances, dilute solutions and mixtures
• Classification based on the hazard properties of the chemical
Principles of Harmonisation
• The level of protection should not be reduced as a result of harmonisation.
• The scope includes both hazard classification criteria and hazard
communication tools (labels, MSDS).
• Changes in all existing systems will be required.
• The GHS does not include requirements for testing.
• Target audiences include consumers, workers, transport workers and
emergency responders.
• In relation to chemical hazard communication, Confidential Business
Information (CBI) should be protected.

ASEAN OSHNET Workshop 26


The Benefits of Harmonization
Countries, international organisations, chemical producers and users of chemicals
all benefit to :
• Enhanced protection of humans and environment
• Facilitate international trade in chemicals
• Reduce need for testing and evaluation
• Assist countries and international organisations in the sound
management of chemicals
Key Elements of the GHS
• THE GHS ELEMENTS INCLUDE:
• CLASSIFICATION CRITERIA
• Physicochemical
• Health (acute and chronic)
• Environmental
• Mixtures
• HAZARD COMMUNICATION
• Labels
• Safety Data Sheets
• Education & Training
International Implementation
• Implementation internationally aimed for 2008
• New version of the GHS released in August 2005
• SDS guidance (new Appendix)
• New precautionary statements
• Some new and revised classification criteria
• Editorial amendments
Australian Implementation
• Working to be in a position to implement by 2008
• Development of a single regulatory framework for the control of
workplace chemicals
• Amalgamate current frameworks
• Achieve consistency across jurisdictions
• Implement the GHS
• New SDS and labelling codes of practice
ASEAN OSHNET Workshop 27
• Implementation of the GHS important for mutual recognition of chemicals with
New Zealand
• Alignment and its timing with key chemical trading partners important
Implementation Issues
• Need to manage transition to new framework
• Common legislative requirements and timing
• Education (label elements)
• Phase in period when current and new requirements will be accepted
• Allow recognition of GHS prior to formal commencement

Presentation 2 : Physical Hazard Classification


By Burkhard Wagner
Definitions
• Gas: Vapour pressure at 50°C >300 kPa or completely gaseous at 20°C
and 101.3kPa
• Liquid: Not a gas, but initial melting point ≤20°C
• Solid: All others
Same criteria applied to Substances & Preparations
Explosives
Substances and preparations capable by chemical reaction of producing gas at
such a temperature, pressure and speed as to cause damage to people and
surroundings including:
• Articles containing such substance and preparations
• Pyrotechnic substances/articles
Guidance
Screening procedure:
• presence of specific chemical groups
• oxygen balance
• exothermic decomposition energy and onset
• concentration of inorganic oxidizing substances

Flammable Gases
Definition:
ASEAN OSHNET Workshop 28
• Gases having a flammable range with air at 20°C and 101.3 kPa
Category 1: Extremely flammable gases
• Gases ignitable when in mixture of ≤ 13% in air or having a flammable
range with air of ≥12 %.
Category 2: flammable gases
• Gases other then those of category 1 (but with a flammable range with air at
20°C and 101.3 kPa)
Flammable Aerosols
To classify aerosols as flammable, the following characteristics/results of
testing need to be considered:
• Concentration of flammable components
(all liquids, gases, solids according to GHS criteria)
• Heat of combustion *
• Ignition distance test **
• Enclosed space ignition test *
• Foam test (for foam aerosols) **
*mainly transport/storage
** mainly worker/consumer

Aerosols are:
• Non flammable, if concentration of flammable components ≤ 1% and heat of
combustion is < 20 kJ/g.
• Extremely flammable, if concentration of flammable components >85% and
heat of combustion is ≥ 30 kJ/g to avoid excessive testing.
All other flammable aerosols are assigned on the basis of the test results to:
• Category 1: Extremely flammable aerosols
• Category 2: Flammable aerosols
There is a clear sequence of testing provided.
Note: If product is not tested, classify it in Category 1.

Oxidizing Gases
Definition: Gases which may, generally by providing oxygen, cause or
contribute to the combustion of other material more than air does
Gases Under Pressure
• Gases contained in a receptacle at a pressure ≥ 280 kPa at 20°C or as a
refrigerated liquid

ASEAN OSHNET Workshop 29


• This definition covers four types of gases or gas mixtures to cope with
effects of pressure or freezing which may lead to serious dammage to
people/surroundings or death of people independently from other hazards
gases may posess
Flammable Liquids
Liquids with a flash point ≤ 93°C
Flammable liquids are classified in one of 4 Categories according to:
• Flash point
• Initial boiling point
Flammable Solids
Definition: Solids which are readily combustible (can be easily ignited by brief
contact with ignition source and flame spreads rapidly) and may
cause or contribute to fire through friction.
• To be classified in one of 2 Categories according to Test Method N° 1 as
described in the Manual of Tests and Criteria.
• To be tested: burning time, burning rate and behaviour of fire in a wetted
zone of the test sample.
Oxidizing Liquids
Definition: Substances and preparations, which cause or contribute to the
combustion of other material (generally by yielding oxygen, but also
fluor e.g. Iodinepentafluoride).
Oxidizing Solids
Definition: Substances which cause or contribute to the combustion of other
material generally by yielding oxygen.
Organic Peroxides
Liquids or Solids containing the bivalent -O-O- structure, thermaly unstable and
exothermic self-accelerating decomposition.
• Such substances and preparations may
• be liable to explosive decomposition
• burn rapidly
• be sensitive to impact or friction
• react dangerously with other substances

ASEAN OSHNET Workshop 30


Corrosive to Metals
Definition: Substances and mixtures which by chemical reaction cause damage
or destroy metals.
Corrosion rate >6.25 mm/year at 55°C
Protection purpose:
• not material compatibility between container/tank and product
• but protection of equipment or installations in case of leakage (e.g.
plane, ship, tank)

Presentation 3 : Classification of health hazards


By Wayne Creaser
Health hazards includes:
• Acute toxicity (Chapter 3.1)
• Skin corrosion/irritation (Chapter 3.2)
• Serious eye damage/eye irritation (Chapter 3.3)
• Respiratory or skin sensitization (Chapter 3.4)
• Germ cell mutagenicity (Chapter 3.5)
• Carcinogenicity (Chapter 3.6)
• Reproductive toxicity (Chapter 3.7)
• Specific target organ systemic toxicity- single exposure (Chapter 3.8)
• Specific target organ systemic toxicity- repeated exposure (Chapter 3.9)
• Aspiration hazard (Chapter 3.10)

Presentation 4 : Classification of Environmental Aquatic Hazards


By Burkhard Wagner
Data Elements for Classification
• Acute aquatic toxicity – representative species e.g.
– fish 96 h LC50; crustacea 48 h EC50; algae 72 or 96 h ErC50
• Bioaccumulation potential
– Log Kow or Bioconcentration Factor (BCF)
• Rapid degradability
– Ready biodegradability; BOD5/COD; other evidence for rapid
degradation
• Chronic toxicity – relevant species e.g.
ASEAN OSHNET Workshop 31
– Fish Early Life Stage; Daphnia reproduction; Algal Growth Inhibition
Classification Criteria I
• The GHS consists of
– three acute classification categories, and
– four chronic classification categories.
• The acute and the chronic classification categories are applied independently.
• The criteria for classification of a substance in acute categories 1 to 3 are
defined on the basis of the acute toxicity data only.
Classification Criteria II
• The criteria for classification of a substance into chronic categories combine
two types of information, i.e. acute toxicity data and environmental fate data
(degradability and bioaccumulation).
• For assignment of mixtures to chronic categories, degradation and
bioaccumulation properties are derived from tests on components.
Definitions I
• Aquatic acute toxicity means the intrinsic property of a substance to be
injurious to an organism in a short term exposure to that substance
• Aquatic chronic toxicity means potential or actual properties of a substance
to cause adverse effects to aquatic organisms during exposure which are
determined in relation to the life-cycle of the organism.

Definitions II
• Degradation means the decomposition of organic molecules to smaller
molecules and eventually to carbon dioxide, water and salts. (It contains
biodegradation and hydrolysis.)
• Bioaccumulation means net result of uptake, transformation, and elimination
of the substance in an organism due to all routes of exposure (i.e. air, water,
sediment/soil, and food).
Aquatic Toxicity
• LC50 = lethal concentration, at which 50% of test animals (fish) in a laboratory
experiment die.
• ErC50 = effect concentration, at which 50% of growth rate of algae in
laboratory experiment shows no growth.

ASEAN OSHNET Workshop 32


• EC50 = effect concentration, at which 50% of test animals (crustacea) in a
laboratory experiment show effect.
• NOEC = No effect concentration, at which test animals show no effect (used in
chronic tests).
Aquatic Toxicity Testing
• Aquatic toxicity is an important element in identifying potential hazards to the
aquatic environment
• Fish, crustacea and algae/aquatic plants are considered representative of
aquatic flora & fauna
• Classification utilises data from tests at these three trophic levels
Intrinsic Properties
• Toxicity is an intrinsic property of a substance and relates to the potential of the
substance to cause effects
• Generally exposure to increasing concentrations of substance causes
increasingly severe effects, or effects on a greater proportion of an exposed
population
• By convention toxicity is expressed relative to parameters of this
concentration/response relationship.
Chronic Data
• Chronic toxicity is toxicity over an ‘extended’ period, defined with respect to the
life-time of the test organism
• In classification, chronic toxicity is normally inferred from acute toxicity + lack of
(bio)degradation and/or potential to bioaccumulate
• In some circumstances such inference of chronic toxicity can be avoided using
real data.
Degradation Testing
• Degradability is an important intrinsic property of substances that determines
their likely persistence in the environment
• Degradation processes can be facilitated by micro-organisms (biotic) or follow
abiotic pathways (eg hydrolysis or photolysis)
• Degradation is the decomposition of (organic) molecules to smaller
molecules (primary degradation) and eventually to carbon dioxide, water and
salts (ultimate degradation)
Incomplete Data Sets
ASEAN OSHNET Workshop 33
Toxicity
• Incomplete toxicity data-sets, e.g., where data are not available on all three
trophic levels.
• Classification considered as ’provisional’ and subject to further information
becoming available.
• In general, all the data available will need to be considered prior to assigning a
classification.
Degradation
• Default assumption in case of incomplete data-set: not (bio)degradable
Bioconcentration
• Default assumption in case log Kow is not applicable (few cases): no
bioconcentration in fish (BCF < 500)

Presentation 5 : Classification of MIXTURES


By Wayne Creaser
Classification criteria for mixtures
• Based on the classification criteria for substances;
• Consider the classification of any impurities, additives or individual constituents
of a substance which have been identified, if they exceed the cut-off
value/concentration limit for a given hazard class.
Normally,
the harmonized cut-off value/concentration limit is to be applied in all
jurisdictions and for all sectors.
• If there is evidence that the hazard of an ingredient is present below the cut-
off/concentration limit, or
• If there is conclusive data that the hazard of an ingredient will not be present at
a level above the harmonized cut-off/concentration limit,
• Data are available for the complete mixture.
• Data are not available for the mixture itself: Apply bridging principles:
i. Dilution;
ii. Batching;
iii. Concentration of mixtures of the highest category within one hazard
class;

ASEAN OSHNET Workshop 34


iv. Interpolation within one toxicity category;
v. Substantially similar mixtures;
vi. Aerosolized mixtures;
• Classification based on ingredients: Apply additivity formula
i. Data available for all ingredients;
ii. Data available only for some ingredients;
Germ cell mutagenicity
• Classification of mixtures will be based on the available test data for the individual
ingredients of the mixture, using cut-off values/concentration limits for those
ingredients.
• The classification may be modified on a case-by-case basis based on the available
test data for the mixture as a whole or based on bridging principles.
Carcinogenicity
• Classification of mixtures will be based on the available test data for the individual
ingredients of the mixture, using cut-off values/concentration limits for those
ingredients.
• The classification may be modified on a case-by-case basis based on the available
test data for the mixture as a whole or based on bridging principles.
Reproductive toxicity
• Classification of mixtures will be based on the available test data for the individual
ingredients of the mixture, using cut-off values/concentration limits for those
ingredients.
• The classification may be modified on a case-by-case basis based on the available
test data for the mixture as a whole or based on bridging principles.

Presentation 6 : Data Sources for Classification Purposes


By Burkhard Wagner
Data Quality I
Test data determine hazardous properties
• GHS classifications are test data independent
• Data from international standard tests, e.g. OECD Test Guidelines, ISO
Guidelines
• Data produced with OECD GLP
• Data estimated by QSAR
ASEAN OSHNET Workshop 35
• Test data for physical hazards are generally more clear cut than test data for
health and environmental hazards
Data Quality II (MAD Agreement)
• MAD = Mutual Acceptance of Data
• OECD Decision 1981 (legally binding)
• Experimental Data produced in one country with OECD Test Guidelines and
GLP must be accepted in the other country.
• Most recent countries that acceded to MAD were South Africa and Israel.
Data Quality III
• Test data already generated should be accepted for classification, therefore
avoiding duplicative testing.
• It may be difficult to determine the quality of test data. In such cases, expert
judgment will be necessary.
• Generally, data of good quality and reliability in humans will have precedence
over other data.
Data Quality IV
• Positive effects seen in either humans and animals will normally justify
classifications. (Chapter 3.4.2.2.2.2)
• The word “quality” is found 14 times in Chapter 3 “Health Hazards”, indicating
that particularly the animal and human toxicity data are especially critical for
health classification.

Weight of Evidence
• Both positive and negative results are assembled together in the weight of
evidence determination. However, a single positive study performed according to
good scientific principles and with statistically and biologically significant positive
results may justify classification
Weight of Evidence (Environment)
• More than one acceptable test available for the same taxonomic group
– The most sensitive (the one with the lowest L(E)C50 or NOEC) is
generally used for classification.
• Larger data sets (4 or more values) available for the same species
– The geometric mean of toxicity values may be used as the
representative toxicity value for that species.
ASEAN OSHNET Workshop 36
– It is not advisable to combine tests of different species within a
taxonomic group or in different life stages or tested under different
conditions or duration.
Data Quality Scoring Guide I
• Objective:
– To assist in the process of deciding on the best available data in case no
data according to standard test guidelines and GLP are available
• Category 1:
– Data derived from official data sources validated by regulatory
authorities
– Examples: EU Water Quality Monographs, USEPA Water Quality
Criteria.
– These data can be considered as valid for classification purposes.
– No assumption should be made that these are the only data available
• Due regard should be given to the date of the relevant report.
Newly available data may not have been considered.
• Category 2:
– Data derived from recognised international guidelines (e.g., OECD
Guidelines) or national guidelines of equivalent quality (but not under
GLP)
– Subject to the data interpretation issues these data can be used for
classification.
• Category 3:
– Data derived from testing which, while not strictly according to a
guideline detailed above, follows accepted scientific principles and
procedures and/or has been peer reviewed prior to publication.
– Where all the experimental detail is not recorded, some judgement may
be required to determine validity.
– Normally, such data may be used within the classification scheme.
• Category 4:
– Data derived from testing procedures which deviate significantly from
standard guidelines and are considered as unreliable, should not be
used in classification.

ASEAN OSHNET Workshop 37


• Category 5:
– QSAR data
– Can be relied upon to provide predictions of acute toxicity for fish,
daphnia, and algae for non-electrolyte, non-electrophilic, and otherwise
non-reactive substances.
– Reliable QSARs have been derived for chemicals acting by a basic
narcosis mechanism.
• Nonelectrolytes of low reactivity such as hydrocarbons, alcohols,
ketones and certain aliphatic chlorinated hydrocarbons which
produce their biological effects as a function of their partition
coefficients.
– Problems remain for substances which operate by means of special
mechanisms
• functional groups which interact with biological receptors, or which
can form sulfhydryl bonds with cellular proteins.
– Data derived from quality QSARs can be used for classification
• Category 6:
– Data derived from secondary sources such as handbooks, reviews,
citation, etc where the data quality cannot be directly evaluated.
– Such data should be examined where data from quality 1,2 and 3 are not
available, to determine whether they can be used.
– Such data should have sufficient detail to allow quality to be assessed.
– In determining the acceptability of these data for the purposes of
classification due regard should be given to the difficulties in testing that
may have affected data quality and the significance of the reported result
in terms of the level of hazard identified.

Presentation 7 : GHS Implementation and Tools for it in Japan


By Hiroshi JONAI
• Manufacturer or Supplier: To classify chemicals and make labels and SDS, to
educate workers
• Government: To harmonize the domestic regulations in order to implement GHS
• Employer: To give a chance of education and training for workers on GHS
• Worker: To understand the meaning of contents of a label or SDS
ASEAN OSHNET Workshop 38
• Consumer: To understand the meaning of contents of a label
• Institute, Agency, Academic society etc. : To do hazard assessment,
information dissemination, education program etc.
Current Regulations for chemical control in Japan
• Laws and regulations were followed by accidents and occupational diseases.
• Chemicals or jobs to be controlled were listed up in the regulations .
Hazard Communication in Japan
• Hazard Communication and Risk Management are combined. (No Hazard
Communication Std.)
• There is no pictogram but KANJI in a label (regulations).
• Hazard information is little but precautionary statements are many in a label.
Hazard Classification
• Physical hazards; Air or Sea transport – same as UNTDG
Other sectors – their own categories
• Acute toxicity; Two categories with criteria (e.g. Oral - 50 mg/kg, 300mg/kg)
• Other health hazards; List of substances according to a hazard concerned (e.g.
Cancer)
• Environmental hazards; List of substances according to a hazard concerned
Current SDS
• Format of SDS is the same as ISO’s.
– Revised according to GHS (2005)
• SDS should be produced for about 1,300 substances under the regulations.
• For the other chemicals, SDSs are made voluntarily.
Issues to be cleared for GHS Implementation
• Big coverage of substances and mixtures under GHS
• Collection of hazard data of chemicals, not regulated by laws or regulations
• Independent hazard communication system not related to risk management
• Clearance of duplication of label elements
GHS Implementation in Japan
• GHS committee consisted of every Ministry concerned (MHLW, METI, MoE,
MIC, MAFF, MLIT and MOFA) established 2001
• Translation of GHS Text into Japanese: First revised version is available from the
web-site of METI, MoE and MHLW)

ASEAN OSHNET Workshop 39


• Seminars on GHS (>2,000 participants)
• Pamphlets for raising awareness
• Revision of Industrial Safety and Health Law for better hazard communication
Enforcement from December 1, 2006
• Guidelines for classification of chemicals
• Classifying 1,500 regulated substances according to GHS criteria and the results
are available on the web of NITE (National Institute of Technology and Evaluation).
Having done 98 substances (Feb. 2006)

New JIS based on GHS


(JIS: Japanese Industrial Standard)
• JIS-SDS based on GHS was issued in Dec. 2005.
• JIS-labelling system based on GHS will be issued in 2006.
Educational Tools for GHS
Pamphlet
• For the public (Ministry of Environment, 2003)
• For industries (Ministry of Health, Labour and Welfare, 2006)
• For workers (Ministry of Health, Labour and Welfare, 2006)
Seminars or Lectures
• For the staff concerned with chemical control from enterprises, institutes and
agencies
• For researchers studying chemical hazards
Workshop
• To classify chemicals according to GHS criteria (JISHA : Japan Industrial Health
and Safety Association)
• To make labels and SDSs under GHS requirements
Guidelines issued
• For dealers how to comply with Poisonous and Deleterious Control Law
• For classifiers how to classify the regulated 1,500 substances
• For suppliers how to make SDS for mixtures

ASEAN OSHNET Workshop 40


Presentation 8 : GHS Labelling
By Wayne Creaser
Target audiences: needs
• Factors considered:
• Potential use of products;
• Availability of information other than label;
• Availability of specific training.
• Needs:
• Workplace: labels, SDS, specific training;
• Consumers: labels
• Emergency responders: labels, specific training;
• Transport: labels, transport documents, specific training.
Comprehensibility of hazard communication elements
Guiding principles:
• Information should be conveyed in more than one way
• Comprehensibility should take account of existing information (literature,
studies and data)
• Phrases indicating degree of hazard should be consistent across different
hazard types
• Words and phrases should retain comprehensibility when translated into other
languages
• Format and colour of the label elements, and SDS format should be
standardized
Labelling according to GHS
Information required on a GHS label:
• Pictograms : Graphical composition that includes a symbol and other graphic
elements, such as a border, background pattern or colour that is intended to
convey specific information.
• Signal words : word used to indicate the relative level of severity of hazard and
alert the reader to a potential hazard on the label.
• Hazard statements : phrase assigned to a hazard class and category that
describes the nature of the hazards of a hazardous product, including, where
appropriate, the degree of hazard.

ASEAN OSHNET Workshop 41


• Precautionary statements and pictograms : phrases (and/or pictograms) that
describe recommended measures that should be taken to minimise or prevent
adverse effects resulting from exposure to a hazardous product, or improper
storage or handling of a hazardous product.
• Product identifier : Chemical identity of the substance.
• Supplier information : Name, address and telephone number of the
manufacturer or supplier of the substance/mixture
Labelling according to GHS: Precedence of hazard information
Symbols for physical hazards:
• Substances/mixtures covered by UN Model Regulations:
as specified by the Model Regulations;
• Workplace: as specified by competent authority;
Symbols for health hazards:
Exclamation mark should not appear if:
• if skull and crossbones applies; or
• if used for skin sensitization or skin/eye irritation:
• if corrosive symbol applies;
• if the health hazard symbol appears for respiratory sensitization;
• Signal words: If “Danger” applies, “warning” should not appear
• Hazard statements: All applicable hazard statements should appear on the
label, in the order specified by the competent authority.
Australian perspective on labelling
• Australian chemical regulatory system is complex
• Different regulatory agencies covering different sectors, for example:
– Agricultural and Veterinary Chemicals
– Scheduled poisons (eg domestic chemicals, pharmaceuticals)
– Workplace chemicals
• Hazard classification and communication using a combination of hazard and
risk based approaches
• For successful implementation of GHS in Australia, labelling must be able to
accommodate both approaches
• Workplace chemicals driving GHS implementation in Australia
• Development of a GHS based labelling code
• Work to develop a hierarchy or precedence of:
ASEAN OSHNET Workshop 42
– hazard classes and categories,
– hazard statements and
– precautionary statements
to accommodate risk-based approaches to labelling
• Additional precedence rules (than currently in GHS) for some situations (eg
small containers)

Presentation 9 : Hazard communication – Safety Data Sheets


By Wayne Creaser
• Australia was the lead country in the UN Correspondence Group on Safety
Data Sheets
• The guidance material was endorsed at the December 2004 GHS meeting
• The current Annex 4 of the GHS (Revision 1) is based on the Australian
National Code of Practice for the Preparation of MSDS
• The SDS requirements are based on a 16-header format
Role of Safety Data Sheets
• Provide comprehensive information of a substance/mixture for use in workplace
• Are product related
• The information provided enables the employer:
• To develop worker protection measures specific to the workplace
• To consider measures to protect the environment
Safety Data Sheets
• SDS should be provided for:
• all substances/mixtures meeting GHS harmonized criteria for physical,
health and environmental hazards;
• mixtures containing substances meeting criteria for carcinogenicity,
toxicity for reproduction or specific target organ systemic toxicity, in
concentration exceeding cut-off values.
• other substances/mixtures not meeting the criteria for classification as
hazardous but containing hazardous substances in certain
concentrations, if required by the competent authority
Safety Data Sheets: Format
Information should be presented as follows:
1. Identification
ASEAN OSHNET Workshop 43
2. Hazard(s) identification
3. Composition/information on ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information.
Updating information
• Labels and Safety Data Sheets should be updated when new and significant
information is available for a chemical.
(“New and significant information” means any information that changes GHS
classification and leads to a change in the information to be provided in the label or in
the SDS.)

Presentation 10 : New Zealand Experience in GHS


By Barry Dyer
The New Zealand Experience
Hazardous Substances and New Organisms (HSNO) Act
• Act Drafted 1989 - 1995
• Enacted 1996
Background
• Replace Obsolete Regulations
• Environmental 1991
• Workplace Health & Safety 1992
• Building 1992
Basic Requirements
ASEAN OSHNET Workshop 44
• Reflect New Zealand’s International Obligations
• Industry Best Practice
• Performance Based
• Commonality with Australia
Hazardous Substances Regulations
• Reflects GHS and UN Transport Model
• Involves 9 Government Agencies
• Created Environmental Risk Management Agency (ERMA)
• Support of NZ Chemical Industry Council (NZCIC)
• Provoked opposition from Employers
Hazardous Substances and New Organisms (HSNO) Act
Hazardous Substances Regulations (13) 2001
• Phased Implementation 2001 –
• Five Year Transitional Period July 06
Basic Infrastructure
• National Performance Standards
9 Approved Codes of Practice
9 Standards
• Professional Qualifications
9 Enforcement Officers
9 Test Certifiers
9 Approved Handlers
• Quality Assurance Accreditation
9 Test Certifiers
9 Trainers
• Training – Model Courses
9 Reference Material
9 Training Aids
Progress to date
• Regulatory Timetable – Complete Transition Phase (July 06) On Target
• Updating Regulations Uncertain
• Compliance Objectives Incomplete
• Infrastructure Incomplete
• Enforcement Deferred
ASEAN OSHNET Workshop 45
• Update Regulations Uncertain
• Provide Performance Standards Behind Schedule
• Introduce Major Improvements e.g. Group Standards On Target
• Training Slow Progress
• Compliance Behind Schedule

• Enforcement Delayed

Compliance Tools
• Codes of Practice
ƒ Signage©
ƒ SDS©
ƒ Labelling©
ƒ Emergency
ƒ Management
• Industry Guides
ƒ DG Wheel/Charts
• ChemCall©24/7 ERS
ƒ Regulatory Requirement
ƒ (GHS/TPT)
• Site Assessments
ƒ PRINCE©
ƒ Accreditation

ASEAN OSHNET Workshop 46


Appendix 5
Program for ASEAN OSHNET Workshop
ASEAN OSHNET Workshop on The Draft ASEAN Guidelines on Classification,
Labeling and Packaging (CLP) of Chemicals
(in collaboration with UNITAR-ILO)
Grand Seasons Hotel, Kuala Lumpur, Malaysia
6 – 8 March 2006

DAY 0 ( 05th MARCH 2006 )


Time Activity
1400-1800 Arrival of ASEAN Delegates
1830-2230 Dinner at (hotel)
End of Day 0

DAY 1 ( 06th MARCH 2006 )


Time Activity
0700-0800 Breakfast at (hotel)

0800-0845 Registration/Arrival of Guests


Arrival of Yang Berhormat Datuk Abdul Rahman Bakar,
0845-0900
Deputy Minister of Human Resources, Malaysia
Welcoming Address by
0905-0910 Ir Hj Abu Bakar Che’ Man, Director General of
Department of Occupational Safety and Health, Malaysia
Welcoming Address by
0910-0915 Y. Bhg Dato’ Ir Dr Johari Basri, Executive Director of
ASEAN OSHNET Secretariat
0915-0920 Welcoming Address by UNITAR
Opening Address by
0920-0935 Yang Berhormat Datuk Abdul Rahman Bakar,
Deputy Minister of Human Resources, Malaysia
0930-1000 Tea Break
Presentation 1 by Mr. Wayne Creaser, Australia:
1000-1100
Introduction to the GHS
Presentation 2 by Mr. Burkhard Wagner, UNITAR: Classification of
1100-1200
Physical Hazards
Presentation 3 by Mr. Wayne Creaser, Australia:
1200-1230
Classification of Health Hazards
1230-1400 Lunch
Presentation 4 by Mr. Burkhard Wagner, UNITAR: Classification of
1400-1500
Environmental Hazards
Presentation 5 by Mr. Wayne Creaser, Australia:
1500-1600
Classification of Mixtures
1600-1615 Tea break
Presentation 6 by Mr. Burkhard Wagner, UNITAR:
1615-1715
Data sources for classification purposes

ASEAN OSHNET Workshop 47


DAY 1 ( 06th MARCH 2006 )
Time Activity
2000-2230 Welcoming Dinner at (hotel). Host by DOSH, Malaysia
End of Day 1

DAY 2 ( 07th MARCH 2006 )


0700-0800 Breakfast at (hotel)

Presentation 7 by Mr Hiroshi Jonai, Japan: The Experience of Japan


0900-0930
with GHS Implementation
Presentation 8 by Mr. Wayne Creaser, Australia:
0930-1015
GHS Labelling
1015-1030 Tea break
Presentation 9 by Mr. Wayne Creaser, Australia:
1030-1115
GHS Safety Data Sheet (SDS)
Presentation 10 by Mr. Barry Dyer, New Zealand: New Zealand
1115-1135
Experience in implementing GHS
Exercise 1: Worked example on classification & labelling of a pure
1135-1245
chemical
1245-1415 Lunch
1415-1530 Exercise 2: Worked example on classification & labelling of a mixture
1530-1545 Tea break
Presentation of a Draft ASEAN CLP Guidelines by Hj Anuar Mohd
1545-1645
Mokhtar, DOSH Malaysia

2000-2230 Dinner at (hotel)


End of Day 2

DAY 3 ( 08th MARCH 2006 )


0700-0800 Breakfast at (hotel)

0900-0915 Briefying on the group discussion


0915-1000 Break-up session: Discussion on criteria used for the guidelines
1000-1015 Tea break
1015-1230 Discussion continue
1230-1400 Lunch
1400-1420 Group #1 presentation
1420-1440 Group #2 presentation
1440-1500 Group #3 presentation
1500-1600 Resolutions on Draft ASEAN CLP Guidelines
1600-1615 Tea break
1615-1630 Closing

2000-2230 Dinner at (hotel)


End of Day 3

ASEAN OSHNET Workshop 48


DAY 4 ( 09th MARCH 2006 )
Time Activity
0700-0800 Breakfast at (hotel)
0830-0900 Room check-out
0900-2230 Departure/Program with NIOSH Malaysia
End of Day 4

ASEAN OSHNET Workshop 49


Appendix 6
Question and answer

Presentation 1 : By Mr. Wayne Creaser, Australia:


Introduction to the GHS
Question : I’m always wonder why, United Nation put it as a model regulation for
the transport dangerous goods, might be incredibly help the country
wishing to follow that particular regime. How far are we confidence with
some model regulation on GHS?
(Mr. Barry Dyer)

Answer : I think that we did five ways after a long why way thing. The transport
dangerous goods covered by a things commended by relationship
advise product.

Presentation 2 : By Mr. Burkhard Wagner, UNITAR-ILO


Classification of Physical Hazard
Question : I wonder if you say that it is corrosive to metal and your definition of
substance and mixture which by chemical reaction cause damage but
the criteria said that it will be caution red more than 6.25mm/year at
550C. If there is a time consuming for this testing, so in the testing
method will be compared or will be doing in some term instead to do a
year?
(Participant from Thailand)

Answer : Sorry, I’m not sure in the testing method.

Presentation 3 : By Mr. Wayne Creaser, Australia


Classification of Health Hazard
Question : Can we state precise concentration that should be applied.
(Participant from Brunei)

Answer : The answer probably no because some compounds even you dilute to
some extremely level it still be extremely toxic where others compounds
ASEAN OSHNET Workshop 50
you can use cut-off 0.1% because each compounds have a different cut-
off value. GHS always consider if you can substituting the chemical for
other that have less hazard for long term benefits.

Question : In doing testing, there is bound to be different interpretation of the testing


result especially on health hazards. Do we have mechanism to resolve
this differences.
(Participant from Malaysia)

Answer : This need to have to start developing a database of classified


substances a baseline where you do have general agreement from the
toxicological community to say yes that this is the reasonable finding you
have. At this stage there is no agreement or process to set-up something
internationally to look at the work that was done between USCPI in
Germany is being reviewed or up for discussion the next GHS meeting
and we hope it will be debated in the next meeting.

Presentation 4 : By Mr. Burkhard Wagner, UNITAR-ILO


Classification of Environmental Hazard
Question : Do you have any institute that implement of this standard where it can be
as a reference organisation lately? It can be a government.
(Participant from Thailand)

Answer: All the test data more or less produce by industries and in Germany
when we received the data, we check the industries if they follow the
guidelines and have produce a documentation or good laboratory
practices we formally accept it. The MITI have done the test for more
than 10,000 chemical and this can be reliable, and I considered this data
as a reference data. But in Purple Book, there is no re-testing necessary.

(Mr. Wagner Creaser)

ASEAN OSHNET Workshop 51


Presentation 5 : By Mr. Wayne Creaser, Australia
Classification of Mixture
No Question

Presentation 6 : By Mr. Burkhard Wagner, UNITAR-ILO


Data sources for classification purposes
Question : You mentioning about the quality of the data it have 6 categories right,
its that right that category 1 is more reliable than category 2.
(Participant from Malaysia)

Answer : It’s a hierarchy, its preceding way from simple to complex. I think its
starts from quality data to the less quality data.

Presentation 7 : By Mr. Hiroshi Jonai, Japan


The Experience of Japan with GHS Implementation
No Question

Presentation 8 : By Mr. Wayne Creaser, Australia


GHS Labelling
Question : Is Australia adopting a new requirement about the minimum information
that need to put on the labels of small container.

Answer : There were a discussion in the GHS Committee at UN about the


minimum information on small container that you must enclosed the SDS
if you packages small container generally small container come in boxes
and SDS is an extra information.

Question : What about the label itself, do we restrict the number of pictograms that
is supposed to put in the labels?

Answer : You must made a decision what is the most important information you
need to put in the labels because if you put all the information it become
smaller and unreadable.

ASEAN OSHNET Workshop 52


Question : Is there any reference regarding the size of the labels?

Answer : As an example, the minimum size of label is depends on the size of the
container just like a 200 litres drum you should put all the information in
the labels so that everybody can read it.

Question : Do we need to labels fixed structures like tank or moving container in the
workplace?
Answer : In Australia, a placard is needed because the potential we exposed to
the chemical is high. Without a placard displayed in the tank or the
moving container, the information about the chemical will not be known
by the public.

Presentation 9 : By Mr. Wayne Creaser, Australia


GHS Safety Data Sheet (SDS)
Question : Under what situation that the suppliers did not need applying SDS?

Answer : The situation where the products is not classified as hazardous


chemical.

Question : If the mixtures is below the cut-off point, do we need the SDS?

Answer : That will be correct if the product is not classified as the hazardous
products to the consumer. A lot of companies developed SDS because it
involved the consumer.

Presentation 10 : By Mr. Wayne Creaser, Australia


New Zealand Experience in GHS
Question : Do you have a training courses for the classifiers to do the
classifications?
(Participant from Malaysia)

ASEAN OSHNET Workshop 53


Answer : No, but I’m sure ERMA will provide the training if u ask them but there
will be someone would like to share the experience if you really want it, I
think Peter Dawson is the right person.

Question : Could you tell me the main reason why government really want to
implement GHS?

Answer : The reason was we had a forty years old legislation and we sat down
and discuss in 1998 and decide we must change all the requirements
using the chemicals.

ASEAN OSHNET Workshop 54


Appendix 7
List of Speaker/Chairman/Facilitator

No. Name Agency/Country Remark


1. Haji Anuar Mohd Moktar DOSH Speaker/Moderator/Chairman
2. Wayne Creaser Australia Speaker/Moderator
3. Dr. Burkhard Wagner Germany Speaker
4. Prof. Dr. Hiroshi Jonai Japan Speaker/Moderator
5. Barry Dyer New Zealand Speaker/Moderator
6. Ir. Mohtar Musri DOSH Chairman
7. Ibrahim Abdul Rahman NIOSH Chairman

ASEAN OSHNET Workshop 55


Appendix 8
List of Participant of ASEAN OSHNET Workshop on 6-8 March 2006

No. Name Country


1. Haji Rambli Trokie Brunei
2. Shahriman Haji Besar Brunei
3. Dr. Leng Tong Cambodia
4. Dr. Pok Vanthat Cambodia
5. Roland Hutapea Indonesia
6. Tumbur Saut Parulian Indonesia
7. Dr. Bounma Sitthisom Laos
8. Khamphat Onlasy Laos
9. Buhairah Ismail Malaysia
10. Fadzil Osman Malaysia
11. Habibah Supoh Malaysia
12. Mohd Fadhil Haji Abu Yazid Malaysia
13. Prema Arasan Malaysia
14. Sukati Sakka Malaysia
15. Soa Win Sein Myanmar
16. U Thein Win Myanmar
17. Chow Li Yee Singapore
18. Dan Liu Singapore
19. Chana Charnmongkol Sumalee Thailand
20. Suksuntichai Kanokkarn Thailand
21. Dang Chan Thong Vietnam
22. Ngo Ke Nghiep Vietnam

ASEAN OSHNET Workshop 56


Appendix 9
List of Secretariat of the ASEAN OSHNET Workshop
No. Name Agency Position
Tuan Hj Anuar Mohd Mokhtar DOSH Director
Pn Zaiton Sharif DOSH Deputy Director
En Ramesh Zakir DOSH Deputy Director
Pn Habibah Supoh DOSH Assistant Director
Cik Zamrudah Yeop DOSH Assistant Director
Roselan Mohamed DOSH Assistant Director
Hamidi Saidin DOSH Assistant Director
Mokhtar Sabtu DOSH Assistant Director
Kasman Nasir DOSH Assistant Director
Noraita Tahir DOSH Assistant Director
Noor Azurah Abd. Rahman DOSH Assistant Director
Azmir Ismail DOSH Assistant Director
Ikhwani Ismail DOSH Assistant Director
Nichalos a/l Maria Soosay Thas DOSH Assistant Director
Ibrahim Abd Rahman NIOSH OSHNET Secretariat
Ayob NIOSH
Khamsiah Mohamad MOHR International Division
Roslindawati Mohamed DOSH Admin
Zuhairi Zakeri DOSH OSH Officer
Christina Shak Sang DOSH OSH Officer
Sofia Hasan DOSH Sister
Noraini Ismail DOSH Sister
Sulaiman R Rahman DOSH OSH Officer
Mohd Poad Abdullah DOSH OSH Officer
Nordin Saian DOSH OSH Officer
Nor Azli Muhamad DOSH OSH Officer
Norazilah Ayuni Muhamad DOSH Admin
Suhairi Abdul Kadir DOSH OSH Officer
Mohd Fairuz Malek DOSH Admin
Yuzriman Jamil DOSH OSH Officer

ASEAN OSHNET Workshop 57


Appendix 10
Curriculum Vitae of the Presenter from UNITAR-ILO

BURKHARD WAGNER
PhD

Chemist
1969 - PhD of University of Heidelkeof in Germany

1970-1971 - Post doc at California, Institute of


Technology in Pasadena/USA

1974-2005 - Employed by the German Environment Protection Agency in


Berlin

2005 - Retired in April

1979-1981 - Worked at OECD in Paris on Good Laboratory Practice.

1991-1996 - Worked at UNEP Chemicals in Geneva/Switzerland.

1999-2006 - Worked in environmental risk assessment of chemicals,


biocides, pesticides, specialist on environmental exposure
assessment.

United Nation Institute for Training and Research (UNITAR) of Experts on GHS

ASEAN OSHNET Workshop 58


Appendix 11
Curriculum Vitae of the Presenter from UNITAR-ILO

WAYNE CREASER
Assistant Secretary
Standards and Research Branch
Office of the Australian Safety and Compensation Council
Department of Employment and Workplace Relations

Wayne has recently been promoted into a position with management and leadership
responsibility for development of national standards relating to plant and occupational
licensing, research on OHS policy issues and reviewing national OHS framework
implementation issues.

Prior to this, Wayne has been responsible for managing the review of the Australian
workplace chemicals framework, developing a new national standard and code of
practice utilising the GHS as the basis for classification and hazard communication. In
this position, Wayne has been head of the Australian delegation to the GHS for the
past two years (2004).

Wayne’s background is in chemistry supplemented with graduate diplomas in


occupational health and safety and management.

Prior to joining the Office of the Australian Safety and Compensation Council, Wayne
worked for the Australian Capital Territory and Northern Territory government’s OHS
regulatory authorities, managing the OHS inspectorates. He has also worked as an
occupational hygienist and environmental chemist.

Wayne lives in Canberra with his wife and two children and is involved in playing and
coaching hockey and is currently undertaking a course in fine woodworking.

ASEAN OSHNET Workshop 59


Appendix 12
Curriculum Vitae of the Presenter from Japan

HIROSHI JONAI email:jonai@medwel.cst.nihon-u.ac.jp


MD, MSc. Chem. Eng., PhD

1978 Graduated at Waseda University


Master Degree of Chemical Engineering

1985 Graduated at Akita University


School of Medicine (Got Physician’s License)

1985 – 2002 March


Worked for National Institute of Industrial Health

2002 April Working for Nihon-University as a Professor

Japan Delegates for UNSCEGHS


United Nations Sub-Committee of Experts on GHS

ASEAN OSHNET Workshop 60


Appendix 13
Curriculum Vitae of the Presenter from New Zealand

BARRY DYER
New Zealand
Chemical Industry Council

The New Zealand Chemical Industry Council is a not-for-profit industry association


representing 90% of Chemical manufacturing and importers. The council aim is to
achieve excellence in safety, health and environmental performance, particularly the
safe management of hazardous substances and dangerous goods through the global
chemical industry’s responsible care initiative.

Following a distinguished military career, Barry was appointed to revitalize the


organization and help the industry prepare for the new GHS based chemical control
legislation.

Under Barry’s leadership, the council is playing a leading role in implementing this
complex and confusing system. The council provides

Technical advice to government, industry and the community


Specialist training for government and industry
A comprehensive range of ‘compliance tools’
A 24/7 emergency response advisory service
Advice and support to APEC countries

Barry is a board member of the international council of chemical associations (ICCA)


comprising 52 countries who are working to implement the GHS by 2010

Barry’s member also included major chemical users, such as hospitals, local
environmental agencies, government agencies, transport operators and the armed
forces.

ASEAN OSHNET Workshop 61


Appendix 14
ASEAN OSHNET Workshop on the Draft ASEAN Guidelines on Classification,
Labelling and Packaging (CLP) of Chemicals
Kuala Lumpur, Malaysia
6-8 March 2006

Exercise 1: Classification of a Substance

Using the following hazard information for 37% aqueous formaldehyde solution
(formalin):

• Determine hazard classification using GHS criteria.


• Using the hazard classification, determine which label elements (symbols, signal
words and hazard statements) would be needed on a label.

Property Results
Flammability Flash point 83-85 C
BP 96 C
Acute toxicity Oral LD50 Rat: 800 mg/kg bw
Guinea pig: 260 mg/kg bw
Dermal Rabbit: 270 mg/kg bw
LD50 Rat: 480 ppm (0.578 mg/L)
Inhalation Mouse: 414 ppm (0.511 mg/L)
LC50
(4 h)
Corrosion/Irritation Eye test Instilling 10 l of 37% formalin solution into
the eye resulted in irritation of the iris and
conjunctiva 3 hours post instillation and
permanent damage to cornea after 1 day.
Sensitisation Skin Known skin sensitiser (patch testing) from
human and animal trials.
Some evidence that formaldehyde may
Inhalation cause sensitisation in sensitive population,
however results are inconclusive.
Carcinogenicity Meets criteria for classification as a
carcinogen category 1
Chronic toxicity Does not meet criteria for classification as
systemically toxic.
Mutagenicity Does not meet criteria for classification as a
mutagenic substance.
Reproductive, Does not meet criteria for reproductive or
developmental effects developmental toxicity.
Environmental toxicity Acute Most sensitive aquatic organism was
Daphnia pulex, with the lowest reported
median effective concentration (EC50) of
5.8 mg/L.

ASEAN OSHNET Workshop 62


Answers

As a result of the above test results, the substance may be assigned to the following
GHS hazard classes.

Health Classification Symbol Signal Hazard


hazards word statement
Health hazards – Oral Category 3 skull and Danger Toxic if
acute toxicity cross bones swallowed
Dermal Category 3 skull and Danger Toxic in
cross bones contact with
skin
Inhalation Category 2 skull and Danger Fatal if
cross bones inhaled
Corrosion/irritation Eye Category 1 Corrosion Danger Causes
serious eye
damage
Sensitisation Skin Category 1 Exclamation Warning May cause
mark an allergic
skin reaction
Carcinogenicity Category 1 Health Danger May cause
hazard cancer by
inhalation
Environmental Acute Category 2 - - Toxic to
hazard toxicity aquatic life
Flammable liquid Category 4 - Warning Combustible
liquid

ASEAN OSHNET Workshop 63


Appendix 15
ASEAN OSHNET Workshop on the Draft ASEAN Guidelines on Classification,
Labelling and Packaging (CLP) of Chemicals
Kuala Lumpur, Malaysia
6-8 March 2006

Exercise 2: Classification of a Mixture

1. Determine the GHS hazard classification of a hypothetical mixture


containing 10% pesticide X and 90% aromatic hydrocarbon solvent. No data
are available for the mixture therefore hazard classification must be determined
using the following hazard information for the two ingredients in the mixture.

2. Using the hazard classification derived, determine which label elements


(symbols, signal words and hazard statements) would be needed on a label.

Data for pesticide X (10%)

Acute toxicity – oral LD50 = 20 mg/kg bw


Acute toxicity – dermal LD50 = 100 mg/kg bw
Acute toxicity – inhalation LD50 = 0.1 mg/L
Acute toxicity – aquatic
Freshwater cladoceran Mean 48h EC50 =
(Daphnia magna) 0.15 mg/L
Estuarine mysid (Neomysis Mean 96h LC50 = 0.20
mercedis) mg/L
Flash point 120 C
Vapour pressure 0.00004 mm Hg
Water solubility 0.002 g/100 mL
Octanol/water partition Log Kow = 3.8
coefficient

Data for aromatic hydrocarbon (90%)

Acute toxicity – oral LD50 = 650 mg/kg bw


Acute toxicity – inhalation LD50 = 12.5 mg/L
Flash point 4C
Vapour pressure 21 mm Hg
Boiling point 111 C
Viscosity 0.590 mPa.s = 0.6806
mm2/s
Density 0.8669 g/cm3

ASEAN OSHNET Workshop 64


Answers

Calculation for acute toxicity of the mixture

Using equation in section 3.1.3.6.1, page 115

100 Ci C1 C2 Cn
=∑ = + + .....
ATEmix n ATEi ATE1 ATE2 ATEn

Where :
ATEmix = acute toxicity estimate for the mixture
ATEi = acute toxicity of ingredient i
Ci = concentration of the ingredient i

Rearrange equation to determine ATEmix as follows:

Ci
1
∑ ATEi 100 100
= n
therefore ATEmix = =
ATEmix 100 Ci C C Cn
∑n ATEi ATE1 + ATE2 + ..... ATEn
1 2

inhalation toxicity,
100 100
ATEmix = = = 0.93 mg/L
10 90 100 + 7.2
+
0.1 12.5
(acute tox (inhalation) cat 2)

Dermal toxicity (mixture)


Only 1 ingredient has dermal toxicity therefore calculation of dermal toxicity of the
mixture is simply a dilution:
= 100/(10/100) = 100/0.1 = 1000 mg/kg bw
therefore classification as acute toxicity (dermal) category 3

Oral toxicity (mixture)


100 100
ATEmix = = = 156 mg/L
10 90 0.5 + 0.138
+
20 650

Therefore classification is acute toxicity (oral) category 3

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Flammability
Using logic in section 2.6.4.1, page 70
Part 2.6.4.2.2 applies because pesticide x is non-volatile (v.p.=0.00004 mm Hg
compared to 21 mm Hg for aromatic hydrocarbon solvent) therefore flash point of
mixture is based on flash point of solvent. That is, mixture has flash point of 4 C.
Flammability classification is category 2 (flash point <23 C and BP >35 C).

Environmental toxicity classification


Lowest acute aquatic tox is 0.15 mg/L for pesticide x making the ingredient aquatic
acute I category.
Aromatic hydrocarbon solvent has no aquatic toxicity and therefore is not considered
further.
Use decision flow chart in figure 4.1.2 which should lead to classification using
summation method. Go to section 4.1.3.5.5.3 – classification of acute categories I, II
and III. See also summation method, referred to in Table 4.1.2 on page 231.

Step 1: Acute I x M >25% means mixture classed as acute I. [M derived from LC50
value range as shown in Table 4.1.4 on page 231]. Component with acute tox I is
less than 25% therefore go to step 2 (3.10.3.5.5.3.2).
Step 2: 10 times Acute I ingredient = 100 , ie >25% therefore classify mixture as Acute
II. This step completes the classification of aquatic toxicity.

Aspiration toxicity
The mixture meets the criteria for classification into category 1 because it is contains
90% aromatic hydrocarbon solvent with kinematic viscosity of <20.5 mm2/s.

Overall classification of mixture:

acute toxicity (dermal) category 3


acute toxicity (oral) category 3
acute toxicity (inhalation) category 2
Flammable liquid category 2
Aquatic - Acute toxicity category II.
Aspiration toxicity category 1

Label elements
Health Classification Symbol Signal Hazard
hazards word statement
Health hazards Oral Category 3 skull and Danger Toxic if
– acute toxicity cross swallowed
bones
Dermal Category 3 skull and Danger Toxic in contact
cross with skin
bones
Inhalation Category 2 skull and Danger Fatal if inhaled
cross
bones
Environmental Acute Category 2 - - Toxic to aquatic
hazard toxicity life
Flammable Category 2 Flame Danger Highly

ASEAN OSHNET Workshop 66


Health Classification Symbol Signal Hazard
hazards word statement
liquid flammable
liquid and
vapour
Aspiration Category 1 Health Danger May be fatal if
hazard hazard swallowed and
enters airways

ASEAN OSHNET Workshop 67


Appendix 16
Group 1: Assignment on classification
No Chapter/Header Comment Comment Reason and recommendation
(fully agree) (Partially
agree)
1 Chapter 1

1.1 Scope x To be added in ”Definition”


1. Use at work: use means chemicals involved in
production, processing, handling, storage,
transportation, disposal and treatment.
2. Hazardous chemicals : any substances or mixtures
which possess any of the properties categories in
schedule 1
3. Item to remove from definition : supplier
1.2 Coverage x
1.3 Exclusions x Para 3: Pharmaceutical products, consumer products, food
additives, cosmetics, and pesticide residues in food are
not covered if use for intentional intake.
Para 4: to refer to planner to redefined definition of
“articles” and clarify on including explosive articles.

Additional : Training Planner to discuss


2 Chapter 2

2.1 Duty to classify x Para 5 : should read as


It is the duty of formulator, manufacturer and importer of
chemical for use at work………until schedule I
2.2 Classification x Para 6 ; all agreed except
process b) Subsequent review of those data and quality to
ascertain…….
Para 7 : b and c
To write Purple Book
2.3 Use available data x Para 8 : add : Classification should be reviewed in
periodic time frame or when new data become available.

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No Chapter/Header Comment Comment Reason and recommendation
(fully agree) (Partially
agree)
2.4 Use of cut-off x Para 9 : However, if the supplier if information that the
hazard…..
2.5 Classification x Para 10 : Schedule II to be removed and replaced with
summary Annex II Purple Book…….
2.6 Competent Classifier x Para 11 : Planner to consider on:
1. Industry to organize
2. Government should train own personnel
3. Government can support industry in training
4. Industry should have own competent classifier
5. Government should certify competent classifier

ASEAN OSHNET Workshop 69


Appendix 17
GROUP 2 : Assignment on Labelling

SUKSUNTICHAI KANOKKARN (THA) -Chairman


SUKATI SAKKA (MAS)
ROLAND HUTAPEA (INA)
HAJI RAMBLI TROKIE (BRU)
DR. LENG TONG (CAM)
DR BOUNMA SITTHISOM (LOA)
MOHD FADHIL HJ ABU YAZID (MAS)-Rappateur

FACILITATOR EXPERT : HIROSHI JONAI


CO-FACILITATOR: ANUAR MOHD. MOKHTAR

TOPIC : LABELLING

DRAFT

CHAPTER 3: LABELLING
3.1 Information on a Label

12. A supplier should ensure that every packaging is labelled clearly and indelibly
with the following information -
(a) the name of the chemical product and component;
(b) pictograms or symbols depicting the danger as stipulated in Schedule II;
(c) signal word ‘danger’ or ‘warning’
(d) hazard statements associated with the use of the chemicals as stipulated in
Schedule II; and
(e) precautionary statements as stipulated in Schedule III;
(f) name, address and telephone number of the principal supplier;

13. The hazard pictograms signal word and hazard statements should be located
together on the label.

14. Indications such as "non-toxic", "non-harmful" or any other similar indications


must not appear on the label or packaging of chemicals even though the chemical has
been classified into hazard categories other than toxic or harmful, or has not been
classified into any of the hazard category.

3.2 Precedence Principles

15. The precedence of symbols for physical hazards should follow the rules of
the UN Model Regulations on the Transportation of Dangerous Goods. (Delete)

16. For health hazards the following principles of precedence applies:


a) if the skull and crossbones applies, the exclamation mark should not
appear;
b) if the corrosive symbol applies, the exclamation mark should not appear
when it is used for skin or eye irritation;

ASEAN OSHNET Workshop 71


c) if the hazard symbol appears for respiratory sensitization, the exclamation
mark should not appear where it is used for skin or eye irritation;
d) if the signal word “danger” applies, the signal word “warning” should not
appear;
e) all assigned hazard statements should appear on the label , with the
hazard statements corresponding to the “danger” signal word to
appear before the hazard statements corresponding to the “warning”
signal word.

3.3 Dimension of a Label


17. The area covered by the hazard pictogram, signal word and hazard statements
as required under paragraph 13 should be as stipulated in Schedule IV.

3.4 Affixing of label


18. The label should be firmly affixed to one or more surfaces of the packaging
so that the label can be read horizontally when the package is set down normally.

19. Where labelling on the container surface is not possible due to its size or
unevenness, the containers should be tagged.

3.5 Review of labels


20. Labels should be reviewed every 5 years or earlier if there are ‘new and
significant’ information about a chemical hazard. New and significant information is
any information that changes the classification of the substance or mixture and
leads to a resulting change in the information provided on the label or any
information concerning the chemical and appropriate measures that may affect the
safety data sheet.

Schedule II: CLASSIFICATION AND LABELLING SUMMARY

Please refer to Annex 2 of the purple book.

Schedule III: PRECAUTIONARY STATEMENTS

Please refer to Annex 3 of the purple book.

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Schedule IV: LABELLING SIZES

Capacity of the package Area occupied by the three label


elements prescribed under paragraph 13.
Not more than 3 litre To cover at least 50% of total label area
Greater than 3 litre but not At least 52 mm x 74 mm or 3848 square
exceeding 10 litres millimetres
Greater than 10 litres but not At least 74 mm x 105 mm or 7770 square
exceeding 50 litres millimetres
Greater than 50 litres but not At least 105 mm x 148 mm or 15540
exceeding 500 litres square millimetres
Greater than 500 litres At least 148 mm x 210 mm or 31080
square millimetres

Label Example

1 Chemical name:……
Cas No:………. 1. Chemical Name
2. Signal word
2 Signal word 3. Pictogram (Symbol)
4. Hazard statement
1 1 1 5. Precautionary statement
3 6. Supplier

Hazard statement Points to pick up


4
• ………..
• ……….. 1. Order of 1 to 6
5 Precautionary statement 2. Location of 1 to 6
• ……….. 3. Label size
• ……….. 4. Selection of precautionary statement
5. Frame color
Company name:
6 Tel:

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Questions
1) Are the labeling precedence principles acceptable?
All precedence principles are acceptable except no 15 because of not
consistent with GHS.

2) Are the labeling sizes required to be stipulated? If yes, any comments or


suggestions?
Leave decision to the UN expert sub committee.

3) What are the specific technical materials to be developed to support the


guidelines?
Technical Guidance must be informed for the whole GHS. Apart from
the code of practice in specific issue eg. the terminology, the sample of
GHS labelling, the quality of SDS etc.

4) Can the Small Medium Industries (SMEs) implement this guidelines?


Use the strengh of association to devolop or sharing the resources.

5) How to implement guidelines in ASEAN Region?, (Road shows, training and


timing)
Sharing the resources as well as allocate some or manpower budget
information system because the major point is to communicate hazard
with understanding label to the users.

6) Other points for improving draft?


Put some appropiate sample label to the draft by comparing the old and
new GHS label should be.

Conclusion
We must emphasize that standard of GHS should be one and harmonize all
standards across the continents even though they have their own standards.
This leads to add -on value in practical GHS standard in the real world.

ASEAN OSHNET Workshop 74


Appendix 18
GROUP 3 : Assignment on Safety Data Sheet

1. Stock taking in Asean countries remarks


Existing: detailed CPL guidelines compared to Asean guidelines Malaysia
Exisiting: Pesticides law but no guidelines Myanmar
Checklist Cambodia
Regulations on chem. used in factory consists 1,500 chem Thailand
Factory to submit SDS to gov
Drafting standard according to GHS Singapore
2. Definitions
Definitions in GHS need not be redefined
Article requires refinement See Australian standard
Flash point to follow GHS
Change purple book to GHS current revision
– as a reference doc for this guidelines

Definition of suppliers too broad and not consistant to scope….?

3. SDS
Refer to GHS Annex 4 for SDS and table 152

Meanings: shall = mandatory


Maybe = optional

Optional for countries to define:

Imported SDS may be translated to national language for


countries
Option for countries to define:
Review of Safety Data Sheet
Safety data sheet should be reviewed every 5 years or earlier if
there are ‘new and significant’ information about a chemical
hazard. New and significant information is any information that
changes the classification of the substance or mixture and leads to
a resulting change in the information provided on the label or any
information concerning the chemical and appropriate measures
that may affect the safety data sheet.
Refer to CBI to refer to GHS section1.4.8

Option for countries to define:


The following proportion ranges maybe indicated as:
> 60 %; (30% -60%); (10 % - 30%); < 10%

Option for countries to define


Criteria for CBI full ingredient and full name disclosure refer to
EEC council directive 67/548/EEC on generic names.

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Criteria for full disclosure: cat 1 health hazards or country PEL??
to discuss…
Chapter 6: Hazards Communication.

Optional for countries to define:


The information to be used on labels and safety datasheets
maybe written in the respective national language.
Optional for countries to define:
The translation of the label elements and safety data sheets
maybe done by competent (as defined by competent authority)
translators.

Classification of Confidential Business Information (CBI)


chemicals: formulator may use the highest range for formulation.

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ASEAN-OSHNET/UNITAR-ILO Workshop 2006 82
DEFINITIONS

“aerosols” means any non-refillable receptacles made of metal, glass or plastics and
containing a gas compressed, liquefied or dissolved under pressure, with or without a liquid,
paste or powder, and fitted with a release device allowing the contents to be ejected as solid
or liquid particles in suspension in a gas, as a foam, paste or powder or in a liquid state or in
a gaseous state. Aerosol includes aerosol dispensers;

“alloy” means a metallic material, homogenous on a macroscopic scale, consisting of two or


more elements so combined that they cannot be readily separated by mechanical means.
Alloys are considered to be mixtures for the purpose of classification under this guideline;

“article” means a particular item or separate thing such as a lead acid battery, a dry cell
battery or a cigarette lighter, that are not normally considered as a chemical substance per
se;

"boiling point" means the temperature of a liquid at which the vapour pressure ( i.e the
pressure characteristic at any given temperature in oC of a vapour in equilibrium with its
liquid form) is equal to or slightly greater than ambient atmospheric pressure;

"carcinogen" means a chemical substance or a mixture of chemical substances which induce


cancer or increase its incidence;

“chemical identity” means a name that will uniquely identify a chemical. This can be a
name that is in accordance with the nomenclature systems of the International Union of Pure
and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS), or a technical
name;

"exothermic reaction" means a chemical reaction which resulted in the production of heat
energy;

"flash point", in relation to extremely flammable, highly flammable and flammable


chemicals, means the lowest temperature in degrees Celsius at which the liquid will
produce enough vapour to ignite;

"foodstuff" means food or drink intended for consumption;

“hazard category” means the division of criteria within each hazard class, e.g. oral acute
toxicity includes five hazard categories and flammable liquids includes four hazard
categories. These categories compare hazard severity within a hazard class and should not
be taken as a comparison of hazard categories more generally;

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“hazard class” means the nature of the physical, health or environmental hazard, e.g.
flammable solid, carcinogen, oral acute toxicity;

"LC50" means the concentration of a chemical in air or of a chemical in water which causes
death of 50% of a group of test animals;

"LD50" means the amount of a chemical, given all at once, which causes death of 50% of
a group of test animals;

“mixture” means mixtures or solutions composed of two or more substances in which they
do not react;

"mutagen" means an agent giving rise to an increased occurrence of mutations in population


of cells and/or organisms;

“mutation” means a permanent change in the amount or structure of the genetic material in a
cell;

“precautionary statement” means a phrase (and/or pictogram) that describes recommended


measures that should be taken to minimize or prevent adverse effects resulting from
exposure to a hazardous product, or improper storage or handling of a hazardous product;

“product identifier” means the name or number used for a hazardous product on a label or in
the safety data sheet. It provides a unique means by which the product user can identify the
substance or mixture within the particular use setting e.g. transport, consumer or workplace;

“purple book” means the First Revised Edition of the Globally Harmonized System of
Classification and Labelling (GHS) documentation published in 2005 by the United
Nations;

“signal word” means a word used to indicate the relative level of severity of hazard and alert
the reader to a potential hazard on the label. ‘Danger’ and ‘Warning’ are used as signal
words with ‘danger’ being of higher severity than ‘warning’.

“substance” means chemical elements and their compounds in the natural state or obtained
by any production process, including any additive necessary to preserve the stability of the
product and any impurities deriving from the process used, but excluding any solvent which
may be separated without affecting the stability of the substance or changing its
composition;

"supplier" means a person who supplies chemicals and include a formulator, a manufacturer,
an importer, a retailer or a distributor;

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CHAPTER 1: INTRODUCTION

1.1 Scope

1. This guideline is applicable to all persons who formulate, manufacture, import,


retail, supply, and distribute hazardous chemicals for use at work.

1.2 Coverage

2. Chemicals covered by this guideline are industrial chemicals and pesticides.


Chemicals refer to pure chemical substances, their dilute solutions or to mixtures of
chemical substances.

1.3 Exclusions

3. Pharmaceutical products, consumer products, food additives, cosmetics, and


pesticide residues in food are not covered for intentional intake.

4. Articles are outside the scope of this guideline.

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CHAPTER 2: CLASSIFICATION

2.1 Duty to classify

5. It is the duty of any persons who supplies chemicals for use at work to classify
them according to the specific hazard class as laid down in Schedule I.

2.2 Classification process

6. Hazard classification incorporates 3 steps, i.e.:


a) Identification of relevant data regarding the hazards of a substance or mixture;
b) subsequent review of those data to ascertain the hazards associated with the
substance or mixture; and
c) a decision on whether the substance or mixture will be classified as a hazardous
substance or mixture and the degree of hazard, where appropriate, by
comparison of the data with agreed hazard classification criteria.

7. The recommended process of classification of mixtures is based on the following


sequence:
a) where test data are available for the complete mixture, the classification of the
mixture will always be based on that data;

b) where test data are not available for the mixture itself, then bridging principles
included and explained in each specific chapter of the purple book should be
considered to see whether they permit classification of the mixture;

In addition, for the health and environmental classes,


c) If (i) test data are not available for the mixture itself, and (ii) the available
information is not sufficient to allow application of the above mentioned
bridging principles, then the agreed method(s) described in each chapter of the
purple book for estimating the hazards based on information known will be
applied to classify the mixture.

2.3 Use of available data

8. Test data already generated for the classification of chemicals under previous
systems should be accepted when classifying these chemicals under this system.

2.4 Use of cut-off/concentration limits

9. Normally, the generic cut-off values/concentration limits adopted in the GHS should
be applied uniformly in all jurisdictions and for all sectors. However, if the supplier has
information that the hazard of an ingredient will be evident below the generic cut-off
values/concentration limits, the mixture containing that ingredient should be classified
accordingly.

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2.5 Classification summary

10. Summary of classification criteria and hazard communication elements can be


found in Schedule II. For details on the classification criteria please refer to the
references given under the Criteria column.

2.6 Competent Classifier

11. The classification of products should be done by a competent classifier.

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CHAPTER 3: LABELLING

3.1 Information on a Label

12. A supplier should ensure that every packaging is labelled clearly and indelibly with
the following information -
(a) the name of the chemical product and component;
(b) pictograms or symbols depicting the danger as stipulated in Schedule II;
(c) signal word ‘danger’ or ‘warning’
(d) hazard statements associated with the use of the chemicals as stipulated in Schedule
II; and
(e) precautionary statements as stipulated in Schedule III;
(f) name, address and telephone number of the principal supplier;

13. The hazard pictograms signal word and hazard statements should be located together
on the label.

14. Indications such as "non-toxic", "non-harmful" or any other similar indications must
not appear on the label or packaging of chemicals even though the chemical has been
classified into hazard categories other than toxic or harmful, or has not been classified into
any of the hazard category.

3.2 Precedence Principles

15. The precedence of symbols for physical hazards should follow the rules of the UN
Model Regulations on the Transportation of Dangerous Goods.

16. For health hazards the following principles of precedence applies:


a) if the skull and crossbones applies, the exclamation mark should not appear;
b) if the corrosive symbol applies, the exclamation mark should not appear when
it is used for skin or eye irritation;
c) if the hazard symbol appears for respiratory sensitization, the exclamation
mark should not appear where it is used for skin or eye irritation;
d) if the signal word “danger” applies, the signal word “warning” should not
appear;
e) all assigned hazard statements should appear on the label , with the hazard
statements corresponding to the “danger” signal word to appear before the
hazard statements corresponding to the “warning” signal word.

3.3 Dimension of a Label


17. The area covered by the hazard pictogram, signal word and hazard statements as
required under paragraph 13 should be as stipulated in Schedule IV.

3.4 Affixing of label


18. The label should be firmly affixed to one or more surfaces of the packaging so
that the label can be read horizontally when the package is set down normally.

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19. Where labelling on the container surface is not possible due to its size or
unevenness, the containers should be tagged.

3.5 Review of labels


20. Labels should be reviewed every 5 years or earlier if there are ‘new and
significant’ information about a chemical hazard. New and significant information is any
information that changes the classification of the substance or mixture and leads to a
resulting change in the information provided on the label or any information concerning
the chemical and appropriate measures that may affect the safety data sheet.

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CHAPTER 4: SAFETY DATA SHEET

4.1 Duty to Furnish Safety Data Sheet


21. A supplier should furnish the current Safety Data Sheet for each hazardous chemical
supplied to any person for use at work based on the generic cut-off values/concentration
limits indicated in Table I:
Table I:
Cut-off values/concentration limits for health & environmental hazard class.
Hazard Class Cut-off Value/
Concentration Limit
Acute Toxicity ≥ 1.0%

Skin Corrosion/Irritation ≥ 1.0%

Serious Damage to Eyes/Eye Irritation ≥ 1.0%

Respiratory/Skin Sensitization ≥ 1.0%

Mutagenicity: Category 1 ≥ 0.1%

Mutagenicity: Category 2 ≥ 1.0%

Carcinogenicity ≥ 0.1%

Reproductive Toxicity ≥ 0.1%

Target Organ Systemic Toxicity (Single ≥ 1.0%


Exposure)

Target Organ Systemic Toxicity (Repeated ≥ 1.0%


Exposure)

Hazardous to the Aquatic Environment ≥ 1.0%

4.2 Review of Safety Data Sheet


22. Safety data sheet should be reviewed every 5 years or earlier if there are ‘new and
significant’ information about a chemical hazard. New and significant information is any
information that changes the classification of the substance or mixture and leads to a
resulting change in the information provided on the label or any information concerning the
chemical and appropriate measures that may affect the safety data sheet.

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4.3 Format of SDS

23. The Safety Data Sheet should contain the following information in the following
order:–
Section 1: Identification of the chemical and of the supplier
Section 2: Hazards identification
Section 3: Composition/information on ingredients
Section 4: First aid measures
Section 5: Fire fighting measures
Section 6: Accidental release measures
Section 7: Handling and storage
Section 8: Exposure controls/personal protection
Section 9: Physical and chemical properties
Section 10: Stability and reactivity
Section 11: Toxicological information
Section 12: Ecological information
Section 13: Disposal considerations
Section 14: Transport information
Section 15: Regulatory information
Section 16: Other information

4.4 Content of SDS

24. Section 1 should contain the following information:

Product Details

i. Product Identifier
The product identifier used should be the same as used in the label. Where
a substance or a mixture is covered by the UN Model Regulations on the
Transport of Dangerous Goods, the UN proper shipping name should also
be used on the package.

ii.Other means of identification


This includes the trade name, the chemical name, and/or the chemical
formula.
For substances, the chemical family could also be stated. The
manufacturer’s code could also be included.

iii.Recommended Use
This sub-section should state the common uses of the product and it
should be given in descending order of importance. The method of
application should also be included. For example, ‘Use: A spray on paint
stripper’. Restrictions on use should also be stated.

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Supplier’s Identification

i. Supplier’s Name:
This subsection should state
a) the names of overseas or local manufacturers and
b) the names of local supplier (formulator or importer or distributor).

ii. Supplier’s Telephone Number:


This subsection should state the supplier (local supplier) company’s telephone
number, including the area code, where advice on the hazardous chemical can
be obtained. The information given should not be a general switchboard
number, but should direct a caller to someone who can clarify information or
provide further information and/or a bibliography. The titles of a position or
department should be inserted. This contact point refers to the local supplier
company.

iii. Emergency phone number:


State the emergency telephone number where advice on an emergency
could be given 24 hours.

25. Section 2 on hazard identification is important for emergency overview purpose.


The supplier should state the classification of the substance or mixture. The label
elements, including precautionary statement should be stated. Hazard symbols may be
provided as a graphical reproduction of the symbols in black and white or the name of the
symbol e.g. flame, skull and crossbones. Other hazards which do not result in
classification (e.g. dust explosion) or are not covered by the GHS could be stated as well.

26. Section 3 on the composition information on ingredient should describe the actual
composition of the hazardous chemical. It should be completed both for pure entities and
for mixtures. The information should allow users to identify clearly the risks associated
with a particular chemical so that they may conduct a risk assessment. Ingredient details
should be listed in a column format under the following headings, i.e: chemical identity;
common name, synonyms, etc.; and the CAS number. The description of information
required under section 3 should be as follows:-

i . Chemical identity
The substance or each ingredient present in a mixture, including impurities and
stabilizing additives that are themselves classified and which contribute to the
classification of the substance itself, should be listed by its chemical name
according to the IUPAC naming system. For mixtures, the proportion of all
ingredients that are present above their cut-off levels should be stated. Ingredients
should be listed with the ingredient representing the highest proportion first and
so on in descending order. Solvents (including water) should be listed last. It is
not possible to set a lower limit of chemicals included in this list as an entity at
0.01 % may be more than 10 times more toxic than one at 0.1%. (Please note that
only the composition of the hazardous ingredient(s), need to be stated)

ASEAN-OSHNET/UNITAR-ILO Workshop 2006 92


ii. Common name, synonym
The common name for the substance or mixture should be given as well as
synonyms.

iii. CAS No.


The substance or in the case of mixture, each ingredient should be listed with its
Chemical Abstract Service (CAS) Number.

27. Section 4 on first aid measures should describe the necessary measures according
to the different routes of exposure, i.e. inhalation, skin and eye contact and ingestion.

This section should also describe the most important symptoms or effects whether acute
or delayed. Immediate medical attention and special treatment needed, if necessary,
should also be indicated.

Examples of suitable instructions are (if appropriate for the chemical):


• Give water or milk to drink and induce vomiting;
• Irrigate with very generous quantities of water for 15 minutes;
• Urgently seek medical assistance;
• Seek medical advice. Show this CSDS to a medical practitioner; or
• Transport to a hospital or medical centre.

Advice to Doctor: Specific antidotes should be indicated where they are available. Where no
specific antidote is available, the doctor should be advised to contact a poison information
centre. This should also, if possible, indicate whether delayed effects can be expected after
exposure.

28. Section 5 on fire-fighting measures should indicate the suitable (and unsuitable)
extinguishing media. Specific hazards arising from the chemical should be indicated (Fire
hazards in presence of various chemical, explosion hazards in presence of various chemical
& any dangerous decomposition products).

This section should specify the special protective equipment and precautions for fire-fighters.

29. Section 6 on accidental release measures is to provide information on the actions


to be taken in the event of an accidental release (including leaks and spills) of a chemical.
This section should address personal precautions, protective equipment and emergency
procedures in the event of accidental release of chemicals into the environment. Indicate
also the methods and materials for containment and cleaning of spills or leakages.

This section should also include environmental precautions to prevent or minimise


environmental pollution.

ASEAN-OSHNET/UNITAR-ILO Workshop 2006 93


30. Section 7 on handling and storage to describe the precautions for safe handling
and the conditions for safe storage, including any incompatibilities.

This section should include all data required for the safe handling and storage
requirements of the chemical, including, where appropriate:
• Location/siting of store;
• Fire separation distances;
• Ventilation;
• Temperature conditions;
• Protection from weather, sun light, etc;
• Type of container;
• Types of products near which the material should not be stored;
• Type of flooring;
• Bunding;
• Security;
• Emergency facilities, e.g. showers, eye washes.

31. Section 8 on exposure controls/personal protection should focus on the exposure


limit relevant to the product or any or all of its ingredients and the requirements for
engineering measures and/or protective equipment. Control parameters such as the
occupational exposure limit values or the biological limit values should be included
where applicable. Emphasis in the safety data sheet should be on engineering methods of
minimising and controlling exposure rather than on the need for protective equipment.

This section should recommend appropriate engineering measures and indicate whether
special ventilation requirements are necessary and specify which type to be used, e.g. use
in a well-ventilated area, ensure ventilation is adequate to maintain air concentrations
below the occupational exposure limits, local exhaust ventilation required etc.

Information on personal protection should be specific both about when protection is


required and the type required. This information may not be relevant for emergency
services. The specific types of respirators etc. should be defined e.g. ‘approved face
mask’ will not be sufficient information whereas ‘approved half-face cartridge respirator
suitable for organic vapours’ could be sufficient. Special requirements may exist for
gloves or other protective clothing to prevent skin exposure, so that specifics of material
are needed; that is ‘impervious gloves’ is not sufficient whereas ‘PVC gloves’ or ‘nitrile
gloves’ could be used. Similarly, eye protection if required should be described as
‘general use industrial safety glasses’ or other specific requirements.

32. Data provided under section 9 on physical and chemical properties should apply
to the product. If the product is a mixture, the data should describe the mixture. The
information is useful for estimating exposure potential; handling leaks and spills;
designing ventilation system; and aiding in design, development and checking of safety
controls and procedures. The data provide should include, where appropriate, the
following:

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i. Appearance : should be described in terms of colour and form
(e.g. brown liquid, grey powder)
ii. Odour : should be mentioned whether the odour of the
product is detectable or no. Include its odour
threshold where applicable.
iii. pH : give the pH of the product
iv. Melting /freezing point : melting or freezing point at 760 mm Hg to be
indicated in degrees Celsius (°C)
v. Boiling point : initial boiling point and boiling range at 760 mm
Hg should be indicated in degrees Celsius (°C)
vi. Flash Point : flash point should be expressed in °C. It should
indicate the method that the data is established,
either by closed or open cup methods.
vii. Evaporation Rate : should state the reference liquid the ratio refers to.
viii.Flammability : whether the solid and gas are flammable,
combustible or inert. The upper/lower flammability/
explosive limits should be expressed where
applicable.
ix. Vapour Pressure : vapour pressure should be expressed in mm Hg at
25 °C
x. Vapour Density : the density of the vapour compared to the density of
air
xi. Specific Gravity : the density of the product compared to water with
density of water being equal to one g/cm3
xii. Solubility : when describing solids or powders, solubility in
water in grams per litre or parts per million parts
of water may be included
xiii.Partition coefficient : log n-octanol/water partition coefficient (log Kow)
xiv.Autoignition Temperature : the minimum temperature required to start or
cause self sustained combustion in any substance.
xv. Decomposition temperature: in °C
xvi.Other Information : other information such as volatility, penetration,
percent volatiles, viscosity @ 40 0C could be
inserted

33. Section 10 on stability and reactivity should provide information on chemical


stability.

This section should also state the possibility of hazardous reactions under certain
conditions and indicate incompatible materials or conditions to be avoided such as static
discharge, shock or vibration. Examples: ‘Avoid physical conditions e.g. temperature,
pressure, light, shock, and contact with moisture or air’ or ‘Avoid proximity to other
chemicals e.g. acids, bases, oxidising agents or any other specific substance that may
cause a dangerous reaction’. Where hazardous decomposition products are given off,
these should be specified along with the necessary precautions.

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34. Section 11 should provide toxicological information on the substance or mixture.
Concise but complete and comprehensible description of the various toxicological
(health) effects and the available data used to identify those effects should be given.
These include
a) information on the likely routes of exposure (inhalation, ingestion, skin and eye
contact);
b) symptoms related to the physical, chemical and toxicological characteristics;
c) delayed and immediate effects and also chronic effects from short- and long-term
exposure; and
d) numerical measures of toxicity (such as acute toxicity estimates).

Reference should be made for overexposure effects both acute and chronic. Reference
should also be made to health hazards as a result of possible reaction with other
chemicals including any known interactions, for example, resulting from the use of
medication, tobacco and alcohol.

35. Section 12 should provide ecological information that includes ecotoxicity


(aquatic and terrestrial, where available); persistence and degradability; bioaccumulative
potential; and mobility in soil. Other adverse effects should also be included, e.g. effects
on water treatment works.

36. Section 13 on disposal considerations should describe the waste residues and
information on their safe handling and methods of disposal, including the disposal of any
contaminated packaging.

This section should contain specific recommendation on:


• Disposal containers;
• Disposal method;
• The need to check local statutory requirements;
• Special precautions for incineration or landfill.

Recommendations on disposal methods are considered essential. Disposal into sewerage


systems should be discouraged. Recommendation for small- and large- scale disposals
should be distinguished from each other.

37. Section 14 should provide transport information that includes the UN number;
UN proper shipping name; transport hazard class(es); and packing group (if applicable).

This section should indicate whether the chemical is a marine pollutant or not. Special
precautions which a user needs to be aware of or needs to comply with in connection with
transport or conveyance either within or outside their premises should be mentioned, e.g.
‘precautions on hazard such as shock sensitivity’.

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38. Section 15 should provide information on safety, health and environmental
regulations specific for the product in question.

39. Section 16 to provide any information not specified in other sections which the
manufacturer could provide. Information on preparation and revision of the SDS should
be included in this section. References could also be listed in this section.

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CHAPTER 5: CONFIDENTIAL BUSINESS INFORMATION

40. Where the name of the chemical constitute confidential information, the name of
the chemical may be omitted from the label or SDS but the actual chemical name must be
disclosed upon written request to a medical practitioner or to any person who uses or
handles the chemical provided that the information is to be used only for the protection of
the safety and health of employees.

The name of the chemical may be omitted and replaced by its generic name if the
chemical is either
a. Classified as harmful or irritant; or
b. Below the relevant concentration limit/cut-off level. (refer Table I)

41. If the exact amount of ingredient in the formulation cannot be specified, then the
proportion ranges of each ingredient contained in the product should be indicated so as to
provide as much information as possible about the potential hazards of a formulation.

The following proportion ranges should be indicated as:


Very High > 60 %; High (30% -60%); Medium (10 % - 30%); Low < 10%

42. The following three examples below show how ingredients should be presented
taking into consideration the concern on confidentiality of information.

Example 1: Full disclosure of ingredients and composition of mixture.


xylene [1330-20-7] 67 %
trichloroethylene [79-01-6] 23%
ethanol [64-17-5] 8%
benzene [71-43-2] 0.9 %
other impurities

Example 2: If the exact composition of the mixture is confidential.


xylene [1330-20-7] very high
trichloroethylene [79-01-6] medium
ethanol [64-17-5] low
benzene [71-43-2] low
other impurities

Example 3 : If the identity of trichloroethylene is commercially confidential.


xylene [1330-20-7] 67%
chlorinated alkyl hydrocarbon 23%
ethanol [64-17-5] 8%
benzene [71-43-2] 0.9%
other impurities

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CHAPTER 6: HAZARD COMMUNICATION

43. The information to be used on labels and safety datasheets should be written in the
respective National Language and English.

44. The translation of the label elements and safety data sheets should be done by
competent translators with relevant technical background.

45. Workers should be trained to read and understand labels, safety data sheets and
any other specific communication systems used in a workplace.

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Schedule 1: HAZARD CLASSES AND HAZARD CATEGORIES

HAZARD TYPES HAZARD CLASSES HAZARD CATEGORIES


1. Explosives Division 1.1 to 1.6
2. Flammable gases Categories 1 and 2
3. Flammable aerosols Categories 1 and 2
4. Oxidizing gases Category 1
5. Gases under pressure Compressed gas; liquefied gas;
refrigerated liquefied gas;
dissolved gas
6. Flammable liquids Categories 1 to 3
7. Flammable solids Categories 1 and 2
8. Self-reactive substances Types A to F
PHYSICAL HAZARD 9. Pyrophoric liquids Category 1
10. Pyrophoric solids Category 1
11. Self-heating substances Categories 1 and 2
12. Substances, which on contact Categories 1 to 3
with water, emit flammable gases
13. Oxidizing liquids Categories 1 to 3
14. Oxidizing solids Categories 1 to 3
15. Organic peroxides Types A to F
16. Corrosive to metals Category 1
17. Acute toxicity (oral, dermal and Categories 1 to 4
inhalation)
18. Skin corrosion/irritation Categories 1A, 1B, 1C and 2
19. Serious eye damage/ eye Categories 1 and 2A
irritation
20. Respiratory sensitizer Category 1
21. Skin sensitizer Category 1
22. Mutagenicity Categories 1A, 1B and 2
HEALTH HAZARD 23. Carcinogenicity Categories 1A, 1B and 2
24. Toxic to reproduction Categories 1A, 1B and 2
25. Target organ systemic toxicity Categories 1 and 2
following single exposure
26. Target organ systemic toxicity Categories 1 and 2
following repeat exposure
27. Aspiration hazard Categories 1 and 2
28. Acute hazards to the aquatic Category 1
ENVIRONMENTAL environment
HAZARD 29. Chronic hazards to the aquatic Categories 1 and 2
environment

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Schedule II: CLASSIFICATION AND LABELLING SUMMARY

Please refer to Annex 2 of the purple book.

Schedule III: PRECAUTIONARY STATEMENTS

Please refer to Annex 3 of the purple book.

Schedule IV: LABELLING SIZES

Capacity of the package Area occupied by the three label elements


prescribed under paragraph 13.
Not more than 3 litre To cover at least 50% of total label area
Greater than 3 litre but not exceeding At least 52 mm x 74 mm or 3848 square
10 litres millimetres
Greater than 10 litres but not exceeding At least 74 mm x 105 mm or 7770 square
50 litres millimetres
Greater than 50 litres but not exceeding At least 105 mm x 148 mm or 15540 square
500 litres millimetres
Greater than 500 litres At least 148 mm x 210 mm or 31080 square
millimetres

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