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Hazardous Chemicals - the impact of new Work Health and Safety (WHS) regulations on chemical classification, safety data sheets (SDS) and labelling. Presented by Adrian Thomas Chemicalia Pty Ltd 1

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Hazardous Chemicals - the impact of new Work Health and Safety (WHS) regulations on

chemical classification, safety data sheets (SDS) and labelling.

Presented by Adrian Thomas

Chemicalia Pty Ltd

1

2

Involved in four areas of activity relating to industrial chemicals: Trading in specialty raw materials including: Marketing Consulting (including supply of raw

materials and finished products). Technical Consulting (including expert witness). Regulatory Affairs

Chemicalia Pty Ltd - Part 1

3

Regulatory Affairs includes: Complying with regulations in Australia with emphasis

on: • National Industrial Chemicals Notification and Assessment

Scheme (NICNAS): – Complying with NICNAS requirements for importation of

chemicals into Australia. – Preparation of NICNAS submissions for Australia.

• Labelling of chemicals (consumer and industrial). • Preparation of Safety Data Sheets (SDS) to comply with

Australian requirements. Complying with the Hazardous Substances And New

Organisms Act (HSNO) for importation of chemicals into New Zealand.

Chemicalia Pty Ltd - Part 2

4

Five documents from the SafeWork Australia website (www.safeworkaustralia.gov.au), these are: “Managing Risks Of Hazardous Chemicals” - code of practice, published

by SafeWork Australia in July 2012. “Guidance on the classification of hazardous chemicals under the WHS

regulations - implementation of the Globally Harmonised System of classification and labelling of chemicals (GHS)”, published by Safe Work Australia in April 2012.

“Preparation of Safety Data Sheets for Hazardous Chemicals”-code of practice, published by SafeWork Australia in December 2011 (ensure pdf is dated December 2011).

“Managing Noise and Preventing Hearing Loss at Work” - code of practice, published by SafeWork Australia in December 2011.

“Labelling of Workplace Hazardous Chemicals”-code of practice, published by SafeWork Australia in December 2011 (ensure pdf is dated December 2011).

Main Source of information (Australia) - Part 1

5

Two documents from the SafeWork Australia website (www.safeworkaustralia.gov.au), these are:

“Globally Harmonised System of classification and labelling of chemicals (GHS)”, 3rd Revised edition published by United Nations in 2009 – (Purple book)

“Understanding the Globally Harmonised System of classification and labelling of chemicals (GHS) - A companion guide to the GHS Purple Book”, 3rd Revised edition published by the United Nations Institute for Training and Research (UNITAR) in June 2010

Main Source of information (Australia) - Part 2

6

Globally Harmonised System for the Classification and Labelling of Chemicals (GHS) – Purple book

WHS explicitly calls 3rd Edition 2009 4th Edition 2011 includes new hazard statements

for aerosols and flammable gases 6th Edition 2015 will be released before the

transition period expiry

Main Source of information (Australia) - Part 3

7

One document from the the National Measurement Institute - Trade Measurement publication website (www.measurement.gov.au): “Guide to the sale of pre-packaged goods”

which was issued in November 2010

Main Source of information (Australia) - Part 4

8

Legal Status

WHS Codes of Practice

now

Admissible in Court Proceedings

9

In relation to Hazardous Chemicals The WHS Regulations implement regulations in relation to: – Obligations relating to safety data sheets and other

matters – Register and manifest of hazardous chemicals – Placards – Control of risk—obligations of persons conducting the

businesses or undertakings – Health monitoring – Induction, information, training and supervision – Prohibition, authorisation and restricted use – Pipelines – Lead

WHS Regulations (including GHS) - Part 1

10

Hazardous Chemicals issues in the WHS regulations include: 16 Hazardous chemicals requiring health

monitoring 9 Prohibited carcinogens 11 Restricted carcinogens 21 Restricted hazardous chemicals Polychlorinated biphenyls (PCBs)

WHS Regulations (including GHS) - Part 2

11

The WHS Regulations implement a new system of chemical hazard classification, labelling and safety data sheet requirements based on the United Nations’ Globally Harmonised System of Classification and Labelling of Chemicals (the GHS). Transition to this new system will occur over a

5 year period from 1 January 2012 until 31 December 2016. The new codes refer to hazard classes and categories under the GHS.

Implementation of WHS Regulations (including GHS) - Part 1

12

From 1/1/2012: Commonwealth. Australian Capital Territory. New South Wales. Northern Territory. Queensland.

From 1/1/2013: South Australia. Tasmania.

Later: Victoria. Western Australia.

All States and Territories to comply by 31/12/2016!

Implementation of WHS Regulations (including GHS) - Part 2

13

Implementation of WHS Regulations (including GHS) - Part 3

Where: Red = Delayed Orange = 1 Jan 2013 Green = 1 Jan 2012

14

Implementation of WHS Regulations (including GHS) - Part 4

Victoria In April 2012 the Victorian Government announced it

would delay harmonisation.

But: Since 2009, Victoria’s Occupational Health & Safety

Regulations 2007 recognise the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) published by the United Nations in 2009.

So GHS Classification labelling and SDS are recognised

15

Implementation of WHS Regulations (including GHS) - Part 5

Western Australia In 2011 WA Government announced that it was unable to

meet the 1 January 2012 implementation timeframe. WorkSafe WA has engaged Marsden Jacob Associates to conduct a regulatory impact analysis on the model WHS Regulations.

But: Since 2010, amendments to the WA OSH Regulations 1996

were gazetted and they recognise the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) published by the United Nations in 2009.

So GHS Classification labelling and SDS are recognised

16

Transition timeline to GHS including the relevant documents to use for classification, labelling and SDS

17

How is the GHS to be applied?

18

Duties and responsibilities in relation to classification, labels and SDSs

Duty Holder Responsibilities

Manufacturer or Importer

• determine whether a substance, mixture or article is a hazardous chemical.

• ensure the hazardous chemical is correctly classified. • prepare and provide safety data sheets (SDS). • ensure the hazardous chemical is correctly labelled. • amend safety data sheets every 5 years and

whenever necessary to ensure it contains correct, current information.

Supplier • ensure the hazardous chemical is correctly labelled.

Person conducting a business or undertaking

• ensure the hazardous chemical is correctly labelled.

19

Signal Word - DANGER or WARNING Hazard Statements Precautionary Statements Pictograms

Elements of GHS

20

Hazard Statement a statement assigned to a hazard class or hazard category describing the nature of the hazards of a hazardous chemical including, if appropriate, the degree of hazard.

Examples: Causes eye irritation. Fatal if inhaled. Combustible liquid. Suspected of causing cancer.

Key terms & abbreviations

21

Physical Hazards: – Includes Dangerous Goods – Explosives, Flammables, Oxidisers, Corrosives – H200 series

Health Hazards: – Includes Hazardous Substances – Toxic, Irritant, Cancer, Skin/Eye Corrosion – H300 series

Environmental Hazards: – Aquatic Hazards – H400 series – Outside jurisdiction of SafeWork Australia

Scope of GHS

22

Physical hazard statements AUH001: Explosive when dry AUH006: Explosive with or without contact with air AUH014: Reacts violently with water AUH018: In use, may form flammable/explosive vapour-air mixture AUH019: May form explosive peroxides AUH044: Risk of explosion if heated under confinement Human health hazard statements AUH029: Contact with water liberates toxic gas AUH031: Contact with acids liberates toxic gas AUH032: Contact with acids liberates very toxic gas AUH066: Repeated exposure may cause skin dryness or cracking AUH070: Toxic by eye contact (cutoff 0.1%) AUH071: Corrosive to the respiratory tract

Additional Australian Hazard Statements

23

Precautionary Statement A phrase prescribed by the GHS that describes recommended measures to be taken to prevent or minimise the adverse effects of exposure to a hazardous chemical or the improper handling of a hazardous chemical. Precautionary statements are separated into five categories:

General statements for use as appropriate. Prevention statements refer to precautions to be taken to prevent an

accident or exposure. Response statements refer to instructions in case of an accident. Storage statements refer to instructions for safe storage of the

chemical. Disposal statements refer to appropriate disposal instructions.

A unique precautionary statement code is assigned to each precautionary statement.

Key terms & abbreviations

24

One document from the SafeWork Australia website (www.safeworkaustralia.gov.au), these are: “Guidance on the classification of hazardous

chemicals under the WHS regulations - implementation of the Globally Harmonised System of classification and labelling of chemicals (GHS)”, published by Safe Work Australia in April 2012.

Classification of a Chemical under the WHS Regulations - Part 1

25

Chemicals may be classified from “first principles”, which means using the raw test data for the chemical and applying the criteria. There are four basic steps to classifying a substance, mixture or article in this way: Collect all available information, Evaluate the adequacy and reliability of the

information, Review the information against the classification

criteria, and Make a determination on its classification.

Classification of a Chemical under the WHS Regulations - Part 2

26

Approved Criteria for Classifying Hazardous Substances [NOHSC:1008(2004)] - Old system HSIS – contains a list of hazardous

substances classified according to the Approved Criteria

GHS (3rd revised edition) – New system (not the current 5th revised edition)

Classification of a Chemical under the WHS Regulations - Part 3

27

Translation Tool The following electronic resource is freely available and

allows classifiers to input existing classification information to determine a classification under the GHS.

GHS converter Berufsgenossenschaft Rohstoffe und Chemische Industrie (BCRI) (http://www.gischem.de/ghs/index.htm)

Note: due to slight variations in how individual countries are implementing the GHS the classification determined using these tools may not be completely accurate for Australian WHS regulatory purposes (for example some hazard categories may be regulated in Australia but not in Europe and vice versa).

Classification of a Chemical under the WHS Regulations - Part 4

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GHS classification information NICNAS list – chemicals classified by NICNAS according to the GHS criteria

(under development) European Commission CLP Regulations Annex VI table 3.1 – contains a list of

more than 4000 GHS-classified chemical substances Hazardous substances

HSIS – contains a list of hazardous substances classified according to the Approved Criteria

Dangerous goods ADG Code 7th Edition – contains a list of substances, mixtures and articles

classified as dangerous goods for transport purposes Other useful links

European Commission Joint Research Centre (ESIS) OECD (eChemportal) New Zealand (HSNO CCID) United States (TOXNET)

Classification of a Chemical under the WHS Regulations - Part 5

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Classification of mixtures according to the GHS The official GHS text provides details of how the criteria should be

applied to the classification of mixtures. This includes details of concentration cut-off values. For some hazard classes and categories in the GHS however, competent authorities are given an option of which concentration cut-off value to use.

Australia is implementing specific classification cut-off values and

concentration limits for mixtures for the following hazard classes: respiratory and skin sensitisers; carcinogens; reproductive toxicants; specific target organ toxicants (STOT) single and repeat exposures.

Classification of a Chemical under the WHS Regulations - Part 6

30

Classifications based on flash points under various criteria Flash Point Criteria

Approved Criteria

ADG-7 AS 1940 WHS (GHS Rev 3)

> 60°C and ≤ 93°C Not classified C1 combustible liquid, not dangerous goods for transport purposes

Class C1 flammable liquid category 4

> 93°C and ≤ 150°C Not classified C1 combustible liquid, not dangerous goods for transport purposes

Class C1 Not classified

> 150°C Not classified Not classified Class C2 Not classified

31

Chemical Classifiers, SDS Writers, & Label Composers:

Should have appropriate expertise and have access to the product formulation and information on its correct hazard classification.

Legal Status

32

Preparation of safety data sheets

33

Material Safety Data Sheet (MSDS) =

Safety Data Sheet (SDS) It provides information on: properties of hazardous chemicals how they affect health and safety in workplace how to manage the hazardous chemicals in the

workplace

What is a safety data sheet?

34

Duty holder Manufacturer and importer of a hazardous chemical

Responsibilities • Must prepare an SDS for the hazardous chemical before first

manufacturing or importing the hazardous chemical or if that is not practicable, as soon as practicable after first manufacturing or importing the hazardous chemical.

• Must review the SDS at least once every 5 years and amend whenever necessary to ensure it contains correct current information.

• Must provide the current SDS to any person, if the person is likely to be affected by the chemical or asks for the SDS.

Duties and responsibilities in relation to the preparation of safety data sheets Part 1

35

Duty holder Person conducting a business or undertaking

Responsibilities May change an SDS for a hazardous chemical only if:

the person is an importer or manufacturer; and changes the safety data sheet in a way that is consistent with the duties of the importer or manufacturer; or

the change is to attach a translation of the SDS, and clearly states that the translation is not part of the original SDS.

Note: a person who packages or relabels a hazardous chemical with their own product name is considered to be a manufacturer and therefore has the same obligations as a manufacturer or importer under the WHS Regulations to prepare an SDS.

Duties and responsibilities in relation to the preparation of safety data sheets Part 2

36

Preparing and providing on SDS is mandatory where a substance, mixture or article is a hazardous chemical.

A number of exceptions exist including: Food and beverages within the meaning of the Food

Standards Australia New Zealand Food Standards Code that are in a package and form intended for human consumption.

Therapeutic goods at the point of intentional intake by or administration to humans.

Veterinary chemical products at the point of administration animals.

Tobacco or products made of tobacco.

When is it necessary to prepare a safety datasheet?

37

For example if the chemical has ototoxic

properties.

Ototoxicity is the potential damage to the ears, specifically to the cochlea or auditory nerve, by a toxin. Safe Work Australia published a Code of Practice: Managing Noise and Preventing Hearing Loss at Work in December 2011.

Other information on hazard properties of a chemical to be included if not already captured within the SDS

38

Hazardous chemical means any substance, mixture or article that satisfies the criteria of one or more Globally Harmonised System of Classification and Labelling of Chemicals (GHS) hazard classes (including a classification in schedule 7 of the WHS Regulations), but excludes a substance, mixture or article in the following hazard classes: Acute toxicity – Category 5 (oral, dermal and inhalation) Skin corrosion/irritation – Category 3 Serious eye damage/eye irritation – Category 2B Aspiration hazard – Category 2 Aquatic toxicity (all categories) Flammable gas – Category 2 Hazardous to the Ozone layer.

What is a Hazardous Chemical under the WHS Regulations?

39

Dangerous Goods, Hazardous Substances & Hazardous Chemicals under the WHS Regulations

Where: Red = Dangerous Goods (according to ADG) Blue = Hazardous Substances (according to GHS) Green = Hazardous Chemicals (according to WHS

40

Substances, mixtures and articles Used, handled or stored at the workplace Defined as hazardous chemicals under the WHS

Regulations Applies to a person conducting a business or

undertaking involved in manufacture or import of hazardous chemicals used, or could reasonably be expected to be used, in workplaces

Scope & Application

41

Substance: Means a chemical element or compound in its

natural state or obtained or generated by a process: Including any additive necessary to preserve

the stability of the element or compound and any impurities deriving from the process; but Excluding any solvent that may be separated

without affecting the stability of the element or compound or changing its composition

Definitions – Part 1

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Mixture: Means a combination of or a solution composed

of two or more substances do not react with each other.

Article: Means a manufactured item, other than a fluid or

particle, that is formed into a particular shape or designed during manufacture and has hazard properties and a function that are wholly or partly dependent on the shape or design.

Definitions – Part 2

43

Acceptable only if prepared in accordance with the WHS Regulations.

Importer is responsible for preparing SDS that complies.

Must be checked for compliance with WHS Regulations and amended if necessary for compliance.

Can an overseas prepared SDS be used?

44

Australian contact address details; and for Dangerous Goods a 24 hour Emergency Response Number;

Need to use English names for chemical ingredients, and Possible Different Units of Measurement; Non GHS classifications or Non EU Hazardous Substances classifications; Disclosure of hazardous ingredients; Ingredient composition ranges; Exposure Standards; Storage to local regulations and Australian Standards; Where ingredients are known and the mixture not tested then Tox and Ecotox data is expected for

each ingredient that contributes to a classification; Local variations to Transport of Dangerous Goods; Hazchem Code for Dangerous Goods (but totally irrelevant & misleading for small packages of

≤100kg or L); Scheduled Poisons requirements; Compliance with Australian Chemical Control systems: NICNAS. APVMA, TGA, FSANZ; Illicit Drug

Precursors End User; Declarations; Carcinogen Notification / Licensing; Chemicals of Security Concern.

*(Reproduced from ‘Hazmat & Environment Notes Oct -Dec 2011’ with permission from Haztech Environmental)

Australian SDS differences may include*:

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Review at least once every 5 years (But consider reviewing earlier as customers don’t like a 4 year 11 month SDS!)

Amend as necessary to ensure correct current information.

Should still be made available after hazardous chemical withdrawn from sale.

Can use GHS for classification, labelling and safety data sheets (SDS) of workplace hazardous chemicals now. However, the GHS is not mandatory until 1 January 2017.

Reviewing and amending an SDS - Part 1

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Note: Whilst customers may also expect 5 yearly SDS reviews for products classified as ‘non hazardous’ according to Regulations, there is no review timeframe. However, many currently non-hazardous products will change to hazardous under the new WHS Regulations. Particularly for those with Risk of serious damage to eyes that will now be caught as eye irritant from 1% rather than 5%.

Reviewing and amending an SDS - Part 2

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1. Identification of the substance or mixture and of the supplier GHS product identifier. Other means of identification. Recommended use of the chemical and restrictions on use. Supplier’s details (including name, address, phone number

etc). Emergency phone number available outside of working hours. N.B. If an emergency information service or Poisons Information

Centre phone number is provided in the SDS, this arrangement should be confirmed with the service beforehand and copies of the SDS should be provided to them.

SDS Headings - Part 1

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2. Hazards identification GHS classification of the substance/mixture and any

national or regional information. GHS label elements, including precautionary

statements. (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 hazard) or are not covered by the GHS.

SDS Headings - Part 2

49

3. Composition/information on ingredients Substance Chemical identity. Common name, synonyms, etc. CAS number and other unique identifiers. Impurities and stabilizing additives which are themselves

classified and which contribute to the classification of the substance.

Mixture The chemical identity and concentration or concentration

ranges of all ingredients which are hazardous within the meaning of the GHS and are present above their cut-off levels.

SDS Headings - Part 3

Presenter
Presentation Notes

50

3. Composition/information on ingredients No requirement to disclose the identity of ingredients for the following GHS health

hazard categories because they fall outside the scope of the WHS Regulations: – Acute toxicity – Category 5 (oral, dermal and inhalation) – Skin corrosion/irritation – Category 3 – Serious eye damage/eye irritation – Category 2B – Aspiration hazard – Category 2 – Aquatic toxicity (all categories) – Flammable gas – Category 2 – Hazardous to the Ozone layer.

NB: Environmental Hazards fall outside but must still be included to meet Dangerous Goods Transport Regs (specific) and State & Federal Environmental Regs (general requirements).

The other information is also needed if the product may be sent to NZ.

SDS Headings - Part 4

Presenter
Presentation Notes

51

3. Composition/information on ingredients Generic names may be used in an SDS if the identity of an ingredient is

genuinely commercially confidential, and if: the ingredient is in any of the following health hazard categories:

– Acute toxicity - Category 4 (oral, dermal, inhalation) – Aspiration hazard - Category 1 – Serious eye damage/eye irritation - Category 2A – Skin corrosion/irritation - Category 2 – Specific target organ toxicity (single exposure) - Category 3;

the ingredient does not cause the correct classification of the hazardous chemical to include any other hazard class or category; and

an exposure standard for the ingredient has not been established.

SDS Headings - Part 5

52

4. First aid measures Description of necessary measures for each route of exposure i.e. inhalation, skin and eye contact and ingestion. Most important symptoms and effects of exposure to the chemical; acute, delayed and aggravated medical conditions Indication of immediate medical attention; special treatment; clinical testing; medical monitoring for delayed effects; antidotes (where known); contraindications 5. Fire-fighting measures Suitable (and unsuitable) extinguishing equipment. Specific hazards arising from a hazardous chemical (e.g. explosive properties or hazardous combustion products). Special protective equipment and precautions for fire fighters.

SDS Headings - Part 6

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6. Accidental release measures Personal precautions, protective equipment and emergency procedures. Environmental precautions. Methods and materials for containment and cleaning up. 7. Handling and storage Precautions for safe handling Conditions for safe storage, including any incompatibilities. 8. Exposure controls/personal protection. Exposure control measures e.g. Australian exposure standards (or if

unavailable, overseas occupational exposure limits), biological limit values. Appropriate engineering controls. Individual protection measures, such as personal protective equipment.

SDS Headings - Part 7

54

9. Physical and chemical properties (some are new) Appearance (physical state, colour etc); Odour; Odour threshold; pH;

Melting point/freezing point; Initial boiling point and boiling range; Flash point; Evaporation rate; Flammability (solid, gas); Upper/lower flammability or explosive limits; Vapour pressure; Vapour density; Relative density; Solubility; Partition coefficient: n-octanol/water; Auto-ignition temperature; Decomposition temperature; Viscosity.

Other physical or chemical parameters relevant to health and safety e.g.: Specific heat value; �� Saturated vapour concentration (include

reference temperatures) Release of invisible flammable vapours and gases; �� Particle size (average and range); �� Size distribution; �� Shape and aspect ratio; �� Crystallinity; � Dustiness; �� Surface area; �� Degree of aggregation or agglomeration, and dispersibility; �� Redox potential; �� Biodurability or biopersistence; �� Surface coating or chemistry (if different to rest of particle).

SDS Headings - Part 8

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10. Stability and reactivity Chemical stability. Possibility of hazardous reactions. Conditions to avoid (e.g. static discharge, shock or vibration). Incompatible materials. Hazardous decomposition products.

SDS Headings - Part 9

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11. Toxicological information Concise but complete and comprehensible description of the

various toxicological (health) effects and the available data used to identify those effects, including: Information on the likely routes of exposure (inhalation,

ingestion, skin and eye contact); Symptoms related to the physical, chemical and

toxicological characteristics; Delayed and immediate effects and also chronic effects

from short- and long-term exposure; Numerical measures of toxicity (such as acute toxicity

estimates).

SDS Headings - Part 10

57

12. Ecological information Ecotoxicity (aquatic and terrestrial, where available). Persistence and degradability. Bioaccumulative potential. Mobility in soil. Other adverse effects. 13. Disposal considerations Description of waste residues and information on their safe

handling and methods of disposal, including the disposal of any contaminated packaging.

SDS Headings - Part 11

58

14. Transport information

UN number. UN Proper shipping name. Transport hazard class/division (and subsidiary risks) under ADG Code. Packing group, if applicable. Environmental hazards for Transport Purposes under IMDG Code & Marine Pollutant determination. Special Precautions for use Hazchem or Emergency Action Code

SDS Headings - Part 12

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15. Regulatory information Safety, health and environmental regulations specific for the

product in question.

16. Other information including information on preparation and revision of the SDS

SDS Headings - Part 13

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SDS complying with both the former Approved Criteria and the GHS - Part 1

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SDS complying with both the former Approved Criteria and the GHS - Part 2

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SDS complying with both the former Approved Criteria and the GHS - Part 3

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SDS complying with both the former Approved Criteria and the GHS - Part 4

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SDS complying with both the former Approved Criteria and the GHS - Part 5

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SDS complying with both the former Approved Criteria and the GHS - Part 6

66

SDS complying with both the former Approved Criteria and the GHS - Part 7

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SDS complying with both the former Approved Criteria and the GHS - Part 8

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SDS complying with both the former Approved Criteria and the GHS - Part 9

69

Preparation of labels

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In general, a label is required for any substance, mixture or article classified as a hazardous chemical under the WHS Regulations.

Exclusions: Dual use products (Cosmetics and toiletries, consumer

household markets and workplaces – comply with ACCC or SUSMP labelling, where appropriate)

Food and beverages Therapeutic goods

When is a label not required under the WHS Regulations?

71

Label in English. Product identifier. Name, Australian address and business telephone number of

manufacturer or importer. Identity and proportion disclosed for each chemical ingredient. Hazard pictogram(s) consistent with the correct classification(s) of

the chemical. Hazard statement(s), signal word and precautionary statement(s)

that is consistent with the correct classification(s) of the chemical. Hazards, first aid and emergency procedures relevant to the

chemical, which are not included in hazard statement or precautionary statement.

Expiry date of the chemical, if applicable.

What information must be included on a label? - Part 1

72

Any other information on the label that does not contradict or cast doubt on any key information that is required on the label.

Additional information, where available: an emergency phone number, for specific poisons or

treatment advice. the overseas name, address and telephone number of the

manufacturer or supplier. a valid website or internet address. reference to the safety data sheet.

What information must be included on a label? - Part 2

73

National Measurement Institute Publication “Guide to the sale of pre-packaged goods” issued in November 2010 from the National Measurement Institute - Trade Measurement (www.measurement.gov.au).

Labelling requirements:

Also: Location of measurement marking as well as name and address of packer In particular, with regard to the address, it must be a street address within Australia. N.B. PO boxes, email addresses or website addresses are not permitted as substitutes for

street addresses. Note (1): Minimum character height is mandatory. Note (2): 1 mm = 2.835 point (based on MS Word).

What information must be included on a label? - Part 3

Maximum dimension height of package

Minimum character height of printed numbers/letters (1)

(as published in mm) (calculated point) (2)

120 mm or less 2.0 mm 5.67

over 120 to 230 mm 2.5 mm 7.09

over 230 to 360 mm 3.3 mm 9.36

over 360 mm 4.8 mm 13.61

74

SIGNAL WORDS Hazard statements Precautionary statements Hazard pictograms Expiry Date

Label elements - Part 1

75

Signal words are used to indicate the relative level of severity of a hazard.

‘DANGER’ is used for a more severe or significant hazard, while ‘WARNING’ is used for the less severe hazards.

Only one signal word should be present on any one label. If the signal word ‘DANGER’ applies, then the signal word ‘WARNING’ should not appear on the label.

Signal words should be represented in bold and UPPERCASE text.

Label elements - Part 2 – Signal Words

76

Hazard statements describe the nature of a hazard, including the degree of hazard, where appropriate.

Generally, a unique hazard statement is assigned to each hazard class and category, but exceptions exist.

A unique hazard statement code is assigned to each hazard statement, but not shown on label.

Hazard statements should be represented in bold and sentence case text.

Label elements – Part 3 – Hazard statements

77

Precautionary statements are separated into five categories: General statements for use as appropriate. Prevention statements refer to precautions to be taken to

prevent an accident or exposure. Response statements refer to instructions in case of an

accident. Storage statements refer to instructions for safe storage of

the chemical. Disposal statements refer to appropriate disposal

instructions. A unique precautionary statement code is assigned to each

precautionary statement, but not shown on label.

Label elements – Part 4 – Precautionary statements

78

• The GHS specifies nine hazard pictograms, having regard to physical, health and environmental hazards.

• Class labels recommended for the transport of dangerous goods as specified in the ADG Code may be used instead of the relevant hazard pictograms specified in the GHS. Never use both ADG and GHS for the same hazard in the same label.

Label elements – Part 5 – Hazard pictograms 1

79

Label elements – Part 5 – Hazard pictograms 2

80

Label elements Part 5 – Hazard pictograms 3 – comparison of hazard pictograms with ADG code class labels 1

81

Label elements Part 5 – Hazard pictograms 3 – comparison of hazard pictograms with ADG code class labels 2

82

Label elements Part 6 – Expiry date

Expiry date for a chemical must be provided, where, for example degradation or decomposition of the chemical may occur over time: So that hazard classification of the chemical changes Or where the chemical is no longer within acceptable

specifications for potency and stability. Expiry date may be provided in a less prominent position of

the label, e.g. back portion of label. Should be grouped with any manufacturer or importer

identification information. An expiry date should be represented in sentence case text.

83

Reduced labelling

Under the WHS Regulations, reduced labelling is permitted for hazardous chemicals that are: supplied in small containers. research chemicals or samples for analysis. decanted or transferred. not supplied to another workplace, and where the hazards

are known to the workers using the chemical. hazardous wastes. classified into the explosives hazard class and are not

explosive articles.

84

Labelling design & layout

The label to be written in English. The size of a label should be: large enough to contain all of the relevant hazard and other

information and easily visible and legible in the workplace. appropriate to the size of the container, with larger labels

present on larger containers The information may be presented using one or more panels. The information and hazard pictograms on any label should

be printed to provide a distinct contrast to the background colour.

85

Grouping information

A label should group specific information together so that hazard or precautionary information can be easily located.

86

Orientation & size of label elements

Container capacity

Minimum hazard pictogram dimensions (1)

Minimum text size (as published in mm) (2)

Minimum text size (calculated point) (3)

≤ 500 mL 15 x 15 mm 2.5 mm 7.09

> 500 mL and ≤ 5 L 20 x 20 mm 3 mm 8.51

> 5 L and ≤ 25 L 50 x 50 mm 5 mm 14.18

> 25 L (4) 100 x 100 mm 7 mm 19.85

(1): Minimum hazard pictogram dimensions are recommended as a guide and are not mandatory, but under ADG minimum hazard diamond label dimensions and lettering sizes are mandatory. (2): Minimum text size is recommended as a guide, but is not mandatory. (3): 1 mm = 2.835 point (based on MS Word). (4): Code states ≥ 25 L

87

Checklist for preparation of a label – Part 1

1. Select suitable product identifier. 2. Determine which ingredients require disclosure. 3. Select the label elements in accordance with

correct hazard classification 4. Combine all applicable elements, omitting some to

avoid duplication or redundancy (see precedence rules).

5. Determine which label elements may be omitted where a special labelling situation may apply.

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Checklist for preparation of a label – Part 2

6. Determine other relevant health and safety information to be required.

7 Select appropriate supplier details for inclusion, including web address or emergency contact phone number.

8. Determine if expiry date is required. 9. Identify any other relevant information such as

reference to SDS or product use information. 10. Design label layout and grouping of information.

89

Flammosol label containing the full set of workplace labelling information

90

Flammosol label containing the full set of workplace labelling information using 2 separate panels - Front Panel

91

Flammosol label containing the full set of workplace labelling information using 2 separate panels - Rear Panel

92

Flammosol label that meets both transport and workplace labelling requirements (single container) - The transport markings label panel

93

Flammosol label that meets both transport and workplace labelling requirements (single container) - The workplace information label panel

94

Flammosol label containing the minimum labelling information permitted and a reference to the safety data sheet

95

Flammosol label with sufficient room to include additional labelling information

96

Hazardous waste label that meets both transport and workplace labelling requirements (single container)

97

Hazardous waste label that meets both workplace labelling requirements and transport inner packaging (single container) with hazard pictograms

98

Hydrochloric acid waste label that meets workplace labelling requirements and transport inner packaging requirements

99

Label for research chemicals or samples for analysis where the chemical identity and some of the hazardous properties are known

100

Label for research chemicals or samples for analysis where the chemical identity is known but the hazardous properties have not been determined

101

Label for research chemicals or samples for analysis where neither the identity nor the hazardous properties of the substance are known

102

Label for a substance not otherwise classifiable under the GHS and which meets road transport labelling requirements

103

Label for a substance not otherwise classifiable under the GHS and which meets workplace labelling requirements and road transport inner packaging

requirements

104

Data required for a typical label – Part 1

Refer to the Safety Data Sheet before use. In a transport emergency dial 000, police or fire brigade. Madeup Chemical Company, 999 Chemical Street, Chemical Town, My State. Telephone: 1300 000 000 www.madeup-chemical-company.com.au

RESSOL RESIN SOLUTION, flammable UN 1866 Contains: Xylene 75%

FLAMMABLELIQUID

3

> 25 L WARNING (Must be bold and uppercase text)

105

Data required for a typical label – Part 2

IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Wash with plenty of soap and water. IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. If skin irritation occurs: Get medical advice/attention. Call a POISON CENTER or doctor/physician if you feel unwell. Take off contaminated clothing and wash before reuse. In case of fire: Use foam or dry agent for extinction.

Hazard Statements Flammable liquid and vapour. Harmful if inhaled. Harmful in contact with skin. Causes skin irritation.

Precautionary statement - Response

General precautionary statements Read label before use. Keep out of reach of children. (not mandatory)

106

Data required for a typical label – Part 3

Keep away from heat/sparks/open flames/hot surfaces. – No smoking. Keep container tightly closed. Take precautionary measures against static discharge and ground/bond container and receiving equipment. Use explosion-proof electrical/ventilating/lighting/equipment and only non-sparking tools. Avoid breathing mist/vapours/spray. Wash hands thoroughly after handling) Use only outdoors or in a well-ventilated area. Wear protective gloves/protective clothing/eye protection/face protection.

Store in a well-ventilated place. Keep cool.

Precautionary statement - Prevention

Precautionary statement - Storage

Dispose of contents/container in accordance with Jurisdictional Regulations.

Precautionary statement - Disposal

107

A typical label > 25 L capacity (complying with ADG Code for transport)

IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Wash with plenty of soap and water. IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. If skin irritation occurs: Get medical advice/attention. Call a POISON CENTER or doctor/physician if you feel unwell. Take off contaminated clothing and wash before reuse. In case of fire: Use foam or dry agent for extinction.

Refer to the Safety Data Sheet before use. In a transport emergency dial 000, police or fire brigade. Madeup Chemical Company, 999 Chemical Street, Chemical Town, My State. Telephone: 1300 000 000 www.madeup-chemical-company.com.au

RESSOL RESIN SOLUTION, flammable UN 1866 Contains: Xylene 75%

Keep away from heat/sparks/open flames/hot surfaces. – No smoking. Keep container tightly closed. Take precautionary measures against static discharge and ground/bond container and receiving equipment. Use explosion-proof electrical/ventilating/lighting/equipment and only non-sparking tools. Avoid breathing mist/vapours/spray. Wash hands thoroughly after handling) Use only outdoors or in a well-ventilated area. Wear protective gloves/protective clothing/eye protection/face protection.

Store in a well-ventilated place. Keep cool.

(Minimum hazard pictogram dimensions 100 x 100 mm and minimum text size 7 mm)

FLAMMABLELIQUID

3Flammable liquid and vapour. Harmful if inhaled. Harmful in contact with skin. Causes skin irritation.

Dispose of contents/container in accordance with Jurisdictional Regulations.

> 25 L WARNING

Read label before use. Keep out of reach of children.

108

A typical label > 5L (and ≤ 25L) capacity (complying with ADG Code for transport)

IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Wash with plenty of soap and water. IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. If skin irritation occurs: Get medical advice/attention. Call a POISON CENTER or doctor/physician if you feel unwell. Take off contaminated clothing and wash before reuse. In case of fire: Use foam or dry agent for extinction.

Refer to the Safety Data Sheet before use. In a transport emergency dial 000, police or fire brigade. Madeup Chemical Company, 999 Chemical Street, Chemical Town, My State. Telephone: 1300 000 000 www.madeup-chemical-company.com.au

RESSOL RESIN SOLUTION, flammable UN 1866 Contains: Xylene 75%

Keep away from heat/sparks/open flames/hot surfaces. – No smoking. Keep container tightly closed. Take precautionary measures against static discharge and ground/bond container and receiving equipment. Use explosion-proof electrical/ventilating/lighting/equipment and only non-sparking tools. Avoid breathing mist/vapours/spray. Wash hands thoroughly after handling) Use only outdoors or in a well-ventilated area. Wear protective gloves/protective clothing/eye protection/face protection.

Store in a well-ventilated place. Keep cool.

(Minimum hazard pictogram dimensions 50 x 50 mm and minimum text size 5 mm)

FLAMMABLELIQUID

3Flammable liquid and vapour. Harmful if inhaled. Harmful in contact with skin. Causes skin irritation.

Dispose of contents/container in accordance with Jurisdictional Regulations.

> 5L (and ≤ 25L) WARNING

Read label before use. Keep out of reach of children.

109

A typical label > 500 mL (and ≤ 5 L) capacity (complying with ADG Code for transport)

IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Wash with plenty of soap and water. IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. If skin irritation occurs: Get medical advice/attention. Call a POISON CENTER or doctor/physician if you feel unwell. Take off contaminated clothing and wash before reuse. In case of fire: Use foam or dry agent for extinction.

Refer to the Safety Data Sheet before use. In a transport emergency dial 000, police or fire brigade. Madeup Chemical Company, 999 Chemical Street, Chemical Town, My State. Telephone: 1300 000 000 www.madeup-chemical-company.com.au

RESSOL RESIN SOLUTION, flammable UN 1866 Contains: Xylene 75%

Keep away from heat/sparks/open flames/hot surfaces. – No smoking. Keep container tightly closed. Take precautionary measures against static discharge and ground/bond container and receiving equipment. Use explosion-proof electrical/ventilating/lighting/equipment and only non-sparking tools. Avoid breathing mist/vapours/spray. Wash hands thoroughly after handling) Use only outdoors or in a well-ventilated area. Wear protective gloves/protective clothing/eye protection/face protection.

Store in a well-ventilated place. Keep cool.

(Minimum hazard pictogram dimensions 20 x 20 mm and minimum text size 3 mm)

FLAMMABLELIQUID

3Flammable liquid and vapour. Harmful if inhaled. Harmful in contact with skin. Causes skin irritation.

Dispose of contents/container in accordance with Jurisdictional Regulations.

> 500 mL (and ≤ 5 L) WARNING

Read label before use. Keep out of reach of children.

110

A typical label > 500 mL (and ≤ 5 L) capacity (complying with ADG Code for transport) – Front Panel

In a transport emergency dial 000, police or fire brigade. Madeup Chemical Company, 999 Chemical Street, Chemical Town, My State.

RESSOL RESIN SOLUTION, flammable UN 1866 Contains: Xylene 75%

(Minimum hazard pictogram dimensions 20 x 20 mm, minimum text size 3 mm)

FLAMMABLELIQUID

3

Flammable liquid and vapour. Harmful if inhaled. Harmful in contact with skin. Causes skin irritation.

> 500 mL (and ≤ 5 L) WARNING

Read label before use. Keep out of reach of children.

111

A typical label > 500 mL (and ≤ 5 L) capacity (complying with ADG Code for transport) – Rear Panel

IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Wash with plenty of soap and water. IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. If skin irritation occurs: Get medical advice/attention. Call a POISON CENTER or doctor/physician if you feel unwell. Take off contaminated clothing and wash before reuse. In case of fire: Use foam or dry agent for extinction.

Keep away from heat/sparks/open flames/hot surfaces. – No smoking. Keep container tightly closed. Take precautionary measures against static discharge and ground/bond container and receiving equipment. Use explosion-proof electrical/ventilating/lighting/equipment and only non-sparking tools. Avoid breathing mist/vapours/spray. Wash hands thoroughly after handling) Use only outdoors or in a well-ventilated area. Wear protective gloves/protective clothing/eye protection/face protection.

Store in a well-ventilated place. Keep cool.

Dispose of contents/container in accordance with Jurisdictional Regulations.

(Rear Panel)

Refer to the Safety Data Sheet before use. Madeup Chemical Company, 999 Chemical Street, Chemical Town, My State. Telephone: 1300 000 000 www.madeup-chemical-company.com.au

112

A typical label > 500 mL (and ≤ 5 L) capacity (complying with workplace labelling requirements)

IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Wash with plenty of soap and water. IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. If skin irritation occurs: Get medical advice/attention. Call a POISON CENTER or doctor/physician if you feel unwell. Take off contaminated clothing and wash before reuse. In case of fire: Use foam or dry agent for extinction.

Refer to the Safety Data Sheet before use. Madeup Chemical Company, 999 Chemical Street, Chemical Town, My State. Telephone: 1300 000 000 www.madeup-chemical-company.com.au

RESSOL Contains: Xylene 75%

Keep away from heat/sparks/open flames/hot surfaces. – No smoking. Keep container tightly closed. Take precautionary measures against static discharge and ground/bond container and receiving equipment. Use explosion-proof electrical/ventilating/lighting/equipment and only non-sparking tools. Avoid breathing mist/vapours/spray. Wash hands thoroughly after handling) Use only outdoors or in a well-ventilated area. Wear protective gloves/protective clothing/eye protection/face protection.

Store in a well-ventilated place. Keep cool.

(Minimum hazard pictogram dimensions 20 x 20 mm, minimum text size 3 mm)

Flammable liquid and vapour. Harmful if inhaled. Harmful in contact with skin. Causes skin irritation.

Dispose of contents/container in accordance with Jurisdictional Regulations.

> 500 mL (and ≤ 5 L) WARNING

Read label before use. Keep out of reach of children.

113

A typical label ≤ 500 mL capacity (complying with workplace labelling requirements)

IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Wash with plenty of soap and water. IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. If skin irritation occurs: Get medical advice/attention. Call a POISON CENTER or doctor/physician if you feel unwell. Take off contaminated clothing and wash before reuse. In case of fire: Use foam or dry agent for extinction.

Refer to the Safety Data Sheet before use. Madeup Chemical Company, 999 Chemical Street, Chemical Town, My State. Telephone: 1300 000 000 www.madeup-chemical-company.com.au

RESSOL Contains: Xylene 75%

Keep away from heat/sparks/open flames/hot surfaces. – No smoking. Keep container tightly closed. Take precautionary measures against static discharge and ground/bond container and receiving equipment. Use explosion-proof electrical/ventilating/lighting/equipment and only non-sparking tools. Avoid breathing mist/vapours/spray. Wash hands thoroughly after handling) Use only outdoors or in a well-ventilated area. Wear protective gloves/protective clothing/eye protection/face protection.

Store in a well-ventilated place. Keep cool.

(Minimum hazard pictogram dimensions 15 x 15 mm, minimum text size 2.5 mm)

Flammable liquid and vapour. Harmful if inhaled. Harmful in contact with skin. Causes skin irritation.

Dispose of contents/container in accordance with Jurisdictional Regulations.

≤ 500 mL WARNING

Read label before use. Keep out of reach of children.

114

A typical label ≤ 500 mL capacity (complying with workplace labelling requirements) – Reduced Labelling 1

IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. Call a POISON CENTER or doctor/physician if you feel unwell.

Refer to the Safety Data Sheet before use. Madeup Chemical Company, 999 Chemical Street, Chemical Town, My State. Telephone: 1300 000 000 www.madeup-chemical-company.com.au

RESSOL Contains: Xylene 75%

Flammable liquid and vapour. Harmful if inhaled. Harmful in contact with skin. Causes skin irritation.

(Minimum hazard pictogram dimensions 15 x 15 mm, minimum text size 2.5 mm)

≤ 500 mL (not stated in Code of Practice)

115

A typical label ≤ 500 mL capacity (complying with workplace labelling requirements) – Reduced Labelling 2

Refer to the Safety Data Sheet before use. Madeup Chemical Company, 999 Chemical Street, Chemical Town, My State. Telephone: 1300 000 000 www.madeup-chemical-company.com.au

RESSOL ≤ 500 mL (not stated in Code of Practice)

(Minimum hazard pictogram dimensions 15 x 15 mm, minimum text size 2.5 mm)

116

OXIDIZINGAGENT

5.1

May intensify fire; oxidizer. Toxic if swallowed Fatal if inhaled. Harmful in contact with skin. Causes severe skin burns and eye damage. May cause cancer. May cause genetic defects. May damage fertility. May damage the unborn child. May cause damage to organs. May cause allergy or asthma symptoms or breathing difficulties if inhaled. May cause an allergic skin reaction. Very toxic to aquatic life with long lasting effects.

IF SWALLOWED: Rinse mouth. Do NOT induce vomiting. Immediately call a POISON CENTER or doctor/physician. IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Rinse skin with water/shower. IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Immediately call a POISON CENTER or doctor/physician. Wash contaminated clothing before reuse. In case of fire: Use water for extinction. Collect spillage.

Refer to the Safety Data Sheet before use. In a transport emergency dial 000, police or fire brigade. Madeup Chemical Company, 999 Chemical Street, Chemical Town, My State. Telephone: 1300 000 000 www.madeup-chemical-company.com.au

Ammonium Dichromate (100%) UN 1439 > 25 kg DANGER

Obtain special instructions before use. Do not handle until all safety precautions have been read and understood. Do not breathe dust. Wear protective gloves. Use personal protective equipment as required. Wear respiratory protection. Wash hands thoroughly after handling. Do not eat, drink or smoke when using this product. Use only outdoors or in a well-ventilated area. Contaminated work clothing should not be allowed out of the workplace. Keep away from heat. Keep/Store away from clothing/ combustible materials. Take any precaution to avoid mixing with combustibles. Avoid release to the environment.

Store in a well-ventilated place. Keep container tightly closed. Store locked up. Dispose of contents/container in accordance with Jurisdictional Regulations. In a transport emergency dial 000, police or fire brigade.

(Minimum hazard pictogram dimensions 100 x 100 mm, minimum text size 7 mm)

Read label before use. Keep out of reach of children.

Label for a substance with five pictograms that meets both transport and workplace labelling requirements (single container)

117

Previously covered under the National Code of Practice for the Storage and Handing of Dangerous Goods [NOHSC: 2017 (2001)]. Now, under WHS it has been superseded by the “Managing Risks Of Hazardous Chemicals” - Code of Practice, published by Safe Work Australia in July 2012. Still need to refer to the latest edition of the Australian Dangerous Goods code, for transportation of dangerous goods and defining dangerous goods in relation to manifest requirements under WHS.

Storage and Handling under WHS – Part 1

118

Storage and Handling under WHS – Part 2

The new Health Hazard pictogram & Hazard Classes and Categories with P405 of “Store locked up” (P405 = Store locked up.)

Hazard Class Hazard Category Precautionary Statement

Germ cell mutagenicity 1A, 1B, 2 P405

Sensitisation - Respiratory 1A, 1B, 2 None

Carcinogenicity 1A, 1B, 2 P405

Reproductive toxicity 1A, 1B, 2 P405 Specific target organ toxicity — single exposure 1, 2 P405 Specific target organ toxicity — repeat exposure 1, 2 None

Aspiration Hazard 1,2 P405

119

Storage and Handling under WHS – Part 3

Other Hazard Classes and Hazard Categories with precautionary statement P405 of “Store locked up” Hazard Class Hazard Category Hazard Pictogram

Acute toxicity — oral 1, 2, 3 Skull and crossbones

Acute toxicity — dermal 1, 2, 3 Skull and crossbones

Acute toxicity — inhalation 1, 2, 3 Skull and crossbones

Skin corrosion 1A, 1B, 1C Corrosion Specific target organ toxicity — single exposure; respiratory tract irritation 3 Exclamation mark Specific target organ toxicity — single exposure; narcosis 3 Exclamation mark

Acute toxicity — oral 1, 2, 3 Skull and crossbones

120

Jeff Simpson, Haztech Environmental.

Richard Greenwood, Noel Arnold & Associates.

Will Ray, P-E Handley-Walker Pty Ltd.

Acknowledgments

121

Company Details: Chemicalia Pty Ltd Postal Address: PO Box 23, Mount Waverley BC, VIC 3149, Australia Phone: (03) 9543 1587 (Local); 61 3 9543 1587 (International) Email: [email protected] Website: www.chemicalia.com Contact: Adrian Thomas (Director) Mobile Phone: 0409 549 768 (Local) Skype Name: adrian.thomas.chemicalia Email: [email protected]

Contact details

122

Thank you for your attention

Any questions?