Professional Documents
Culture Documents
With the financial support of the Government of Switzerland and the European Union.
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.
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.
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.
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.
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.
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
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:
Reviewed by:
Approved by:
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.
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.
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.
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.
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.
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.
With that, I officially declared the ASEAN OSHNET Workshop on the Draft ASEAN
Guidelines on Classification, Labelling and Packaging (CLP) Chemical open.
Thank you.
Distinguished Speakers:
Distinguished guests,
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.
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.
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.
Thank you.
ASEAN-OSHNET Secretariat
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)
Guests; and
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.
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.
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.
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.
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.
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.
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.
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
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.
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.
• Enforcement Delayed
Compliance Tools
• Codes of Practice
Signage©
SDS©
Labelling©
Emergency
Management
• Industry Guides
DG Wheel/Charts
• ChemCall©24/7 ERS
Regulatory Requirement
(GHS/TPT)
• Site Assessments
PRINCE©
Accreditation
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.
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.
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.
Answer : It’s a hierarchy, its preceding way from simple to complex. I think its
starts from quality data to the less quality data.
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.
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.
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.
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.
BURKHARD WAGNER
PhD
Chemist
1969 - PhD of University of Heidelkeof in Germany
United Nation Institute for Training and Research (UNITAR) of Experts on GHS
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).
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.
BARRY DYER
New Zealand
Chemical Industry Council
Under Barry’s leadership, the council is playing a leading role in implementing this
complex and confusing system. The council provides
Barry’s member also included major chemical users, such as hospitals, local
environmental agencies, government agencies, transport operators and the armed
forces.
Using the following hazard information for 37% aqueous formaldehyde solution
(formalin):
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.
As a result of the above test results, the substance may be assigned to the following
GHS hazard classes.
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
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)
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.
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
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.
15. The precedence of symbols for physical hazards should follow the rules of
the UN Model Regulations on the Transportation of Dangerous Goods. (Delete)
19. Where labelling on the container surface is not possible due to its size or
unevenness, the containers should be tagged.
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
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.
3. SDS
Refer to GHS Annex 4 for SDS and table 152
“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;
“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;
“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;
“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;
"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;
“mutation” means a permanent change in the amount or structure of the genetic material in a
cell;
“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;
1.1 Scope
1.2 Coverage
1.3 Exclusions
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.
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;
8. Test data already generated for the classification of chemicals under previous
systems should be accepted when classifying these chemicals under this system.
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.
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.
15. The precedence of symbols for physical hazards should follow the rules of the UN
Model Regulations on the Transportation of Dangerous Goods.
Carcinogenicity ≥ 0.1%
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
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.
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.
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).
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)
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.
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.
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.
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.
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:
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.
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.
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.
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’.
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.
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.
42. The following three examples below show how ingredients should be presented
taking into consideration the concern on confidentiality of information.
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.