Posted on Leave a comment

Special labeling situations under GHS and Safety DID YOU COVER with the TEAM!

As yet, workers are still having a few learning hiccups regarding GHS Labels and when the labels cross over to worksite  labels.   And yes the new laws have a few new things in place BUT the old system taught us a few things too.  Here is what you need to know!   Remember the new system is only difficult if you make it so for your workers.

At the work place this requirements and guidelines for labelling hazardous chemicals in special situations where the full requirements do not apply.

You should always aim to provide as much information on the hazards and safe use of the chemical on the label as possible. Under the GHS Laws and  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.

A workplace label is required when:

  • a hazardous product is produced (made) at the workplace and used in that workplace,
  • a hazardous product is decanted (e.g., transferred or poured) into another container, or
  • a supplier label becomes lost or illegible (unreadable).

There are two situations when a workplace label is not necessary. When a hazardous product is:

  • poured into a container and it is going to be used immediately, or
  • “under the control of the person who decanted it”. For example, when the person who poured the product into another container will be the only person who will use it, and the product will be used during one shift, a full workplace label may not be required. However, the container must still be identified with the product identifier (name).

If a hazardous chemical has been decanted or transferred from the container in which it was packed and it will not be used immediately or it is supplied to someone else, the label must, at a minimum, be written in English and include the following:

  • the product identifier, and
  • a hazard pictogram or hazard statement consistent with the correct classification of the chemical. For the purposes of the Legislation, decant means to transfer a hazardous chemical from a correctly labelled container to another container within a workplace.

Such a container may range from a small flask in a research laboratory to a large vessel that is used to contain reaction components prior to use in a mixing or reaction process. Where the entire amount of a decanted hazardous chemical will be used immediately, labelling of its container is not required. A decanted hazardous chemical can only be considered to be used immediately in situations where:

  • it is not left unattended by the person who decanted it
  • the decanted hazardous chemical is used only by a person present at the decanting process
  • the container is subsequently rendered free from any hazardous chemical immediately after use, so the container is in the condition it would be in if it had never contained the chemical.

Examples • A sample of hydrocarbon solvent is dispensed from a bulk container into a 15 L container by Worker A. All of the decanted hydrocarbon solvent in the 15 L container is then used immediately by Worker A in the same shift. No hydrocarbon solvent is left in the 15 L container (as though it has never contained the chemical). The container with the dispensed solvent is not left unattended by Worker A before it is used. In this example, the decanted hydrocarbon solvent is considered to be used immediately.

  • A sample of hydrocarbon solvent is dispensed from a bulk container into a 15 L container by Worker A. The solvent in the 15 L container is not completely used up by Worker A at the end of his/her work shift. Worker A has not left the container with the dispensed solvent unattended during the shift. The remainder of the solvent is left for Worker B. In this example, the decanted hydrocarbon solvent is not considered to be used immediately. Where a container is repeatedly used for decanting as part of normal work procedures or processes, a permanent label with all the general labelling information must be attached to the container. Permanently labelled containers must not be used to contain any other substances or mixtures than those specified on the label.

“Decant means to transfer a hazardous chemical from a correctly labelled container to another container within a workplace.”,

“The minimum requirements for the label of a decanted chemical are:

  • the product identifier [e.g. the chemical name]
  • a hazard pictogram or hazard statements consistent with the correct classification of the chemical”

This is so that another person at the workplace will be able to read the label and determine the contents of the container. Therefore the manufacturer’s details are not a requirement for labels of decanted chemicals.

Other relevant information can be included on the label where space allows.   The Legislation advises that

You should always aim to provide as much information on the hazards and safe use of the chemical on the label as possible”, and that

Priority should be given to those labelling elements relating to the most significant hazards of the hazardous chemical.”

Where a hazardous chemical is packaged in a container that is too small to attach a label with information that is required of hazardous chemical labels in general, then the label must be written in English and include the following:

  • the product identifier
  • the name, country of orgin address and business telephone number of either the manufacturer or importer.
  • a hazard pictogram or hazard statement that is consistent with the correct classification of the chemical, and
  • any other information required for hazardous chemicals labels in general that is reasonably practicable to include.

The most significant hazard

  • The information relating to a hazardous chemical’s inhalation hazard properties may be considered most significant for a paint that is intended for application using a spray gun, but not where it is intended for application using a brush.
  • The information relating to dermal toxicity may be considered most significant for a chemical that is packaged in an ampoule (ie where spillage could occur during opening), but not where the chemical is packaged in a ready-to-use syringe. For hazardous chemicals with multiple hazard categories, the most stringent set of precautionary statements should be selected. This is appropriate for situations where rapid action or response may be crucial following accidental exposure, and therefore, information relating to these actions should be included in preference to non-critical information. Example of the most stringent set of precautionary statements If a chemical can cause long term systemic effects, and is also acutely toxic, then the first aid measures for acute toxicity will normally take precedence over those for longer term effects. However, medical attention for the delayed health effects may be required in some cases of incidental exposure, even if it is not associated with immediate symptoms of exposure. Therefore, the information relevant to medical attention that is required due to delayed health effects may be applicable. Where certain hazard or other information has been omitted from the label, then it is recommended that alternative means for communicating the information should be used. The complete set of hazard and other information may be included on an outer box (for example for a box containing several very small ampoules), a swing tag or insert, or a leaflet inside a box.

A research chemical or sample for analysis must be correctly classified and the identity of the substance or mixture must be determined. The product identifier of a research chemical or sample for analysis may be:

  • the actual name of the chemical
  • a recognised abbreviation or acronym
  • a chemical formula, structure or reaction components. Where a research chemical or sample for analysis cannot be identified this should be indicated clearly on the label. Labels for research chemicals or samples for analysis should include as much hazard information as possible, based on the identity and the known or suspected hazards.

Terry Penney

Leave a Reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.