Labelling of workplace hazardous chemicals

All information relating to the recent amendments to the model WHS laws exempting certain veterinary chemicals from labelling requirements are in the process of being updated on our website. These updates will be complete before 1 January 2017, when the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) takes full effect.

What is a Label?

A label is the written, printed or graphical information elements concerning a hazardous chemical that is affixed to, printed on, or attached to the container or pipe work of a hazardous chemical. For workplace hazardous chemicals, labels include information on the hazards, plus instructions and information on the safe storage, handling, use and disposal of the chemical.

The label and Safety Data Sheets (SDS) are important sources of information that may be used to inform hazard and risk assessments in the workplace, and establish appropriate work practices and processes to control the risks during use.

Duties under the WHS Regulations

Under the Work Health and Safety (WHS) Regulations, the manufacturer or importer of a hazardous chemical must ensure that it is correctly labelled. A supplier must not supply hazardous chemicals manufactured or imported after 1 January 2017 to a workplace if the hazardous chemicals are not correctly labelled according to the WHS Regulations.

Codes of Practice for Labelling

Safe Work Australia’s Code of Practice: Labelling of workplace hazardous chemicals provides detailed guidance on how to label workplace chemicals. This code of practice should be used where the chemical has been classified according to the GHS.

Manufacturers and importers of chemicals are able to continue to use the existing NOHSC labelling system for workplace hazardous substances and dangerous goods up until 31 December 2016. This applies for chemicals which have been classified according to the Approved Criteria for Classifying Hazardous Substances and the ADG Code. Suppliers of hazardous chemicals can continue to supply chemicals after 31 December 2016 that are correctly labelled in accordance with these requirements. However, from 1 January 2017 suppliers should only accept stock with labels that are GHS compliant. Links to labelling documents are provided below.

Until 31 December 2016 From 1 January 2012
(mandatory after 31 December 2016)
Hazardous Substances
National Code of Practice: Labelling of workplace substances [NOHSC: 2012 (1994)]
Hazardous Chemicals
model Code of Practice: Labelling of workplace hazardous chemicals
Dangerous Goods
Australian Code for the Transport of Dangerous Goods by Road and Rail (ADG Code)

Review and Approval of Labels

Labels must be reviewed periodically in order to keep them up to date, for example when there is a change in the formulation or ingredients that changes the hazardous properties of the chemical, and when new information on the hazards of the product or any of its ingredients becomes available. When the classification of a hazardous chemical changes, the label must be reviewed and, if necessary, revised to reflect any changes.

Importers, manufacturers and suppliers should review any new or significant information in relation to any hazardous chemicals they import, manufacture or supply. A review of the literature and other relevant sources of information should be undertaken on a regular basis.

A label should also be reviewed when the SDS is revised. SDS must be reviewed and revised every 5 years.

Labels of workplace chemicals do not need to be formally approved by a regulator to meet requirements under the WHS legislation. However, the work health and safety authority in each State and Territory is responsible for determining whether a label complies with their laws through normal compliance activities.

Safe Work Australia’s Code of Practice: Labelling of workplace hazardous chemicals provides comprehensive guidance on the application of the regulations in regards to labelling.

Chemicals Imported from Overseas

In some situations imported chemicals may need to be re-labelled. Not all countries use the same criteria for classification of hazardous chemicals, or have equivalent requirements for labelling. As a consequence, some overseas labels may not meet Australian requirements. This situation is expected to decrease over the coming years as more countries adopt the GHS.

Chemicals imported from overseas with labels that contain equivalent information to that prescribed in the Code of Practice: Labelling of workplace hazardous chemicals may not need to be re-labelled.

Other labelling requirements

The regulation of chemicals in Australia is a complex arrangement between Commonwealth agencies and state and territory regulators. The regulations that apply to a chemical depend to a large extent on the end use of the chemical. For example, a chemical supplied to and used in a workplace is covered by the workplace labelling requirements, whereas the same chemical supplied to the domestic market may also be covered by drugs and poisons labelling regulations.

Various types of chemical or chemical use situations are shown below, with other relevant labelling requirements that may apply in addition to those under work health and safety legislation.

Type of chemical Responsible
department/agency
Websites
Agricultural and veterinary chemicals Australian Pesticides and Veterinary Medicines Authority www.apvma.gov.au
Consumer and domestic chemicals (poisons) Department of Health and Ageing www.health.gov.au
http://www.tga.gov.au/industry/scheduling-poisons-standard.htm
http://www.health.gov.au/internet/main/publishing.nsf/content/ohp-ocs.htm
Therapeutic goods Department of Health and Ageing www.health.gov.au
http://www.tga.gov.au/industry/labelling.htm
Dangerous goods during land transport Department of Infrastructure and Transport www.infrastructure.gov.au
http://www.infrastructure.gov.au/transport/australia/dangerous/index.aspx

Labelling requirements for agricultural and veterinary (AgVet) chemicals

Safe Work Australia has published a policy statement and information sheets on labelling of Agricultural and Veterinary (AgVet) chemicals. This information assists duty holders in understanding and complying with work health and safety legislative requirements.

Note: These information sheets are in the process of being updated. The updates will be completed before 1 January 2017, when the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) takes full effect.

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