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Labels on hazardous chemicals identify hazards and give instructions on how to use them safely. They help businesses identify any safety controls needed in the workplace, and tell workers how to deal safely with a chemical.

  • Manufacturers and importers of hazardous chemicals need to make sure they are labelled correctly so workers using them know the hazards.
  • A GHS label is required for any hazardous chemical intended for predominantly workplace use.

In Australia, labels for workplace hazardous chemicals must be prepared in accordance with the model Code of Practice: Labelling of Workplace Hazardous Chemicals.

Information on hazardous chemical labels

A hazardous chemical is correctly labelled if it is packed in a container that has a label written in English that includes:

  • The product identifier.
  • The name, Australian address and business telephone number of the manufacturer or importer.
  • The identity and proportion of each ingredient—as per Schedule 8 to the model WHS Regulations.
  • Any hazard pictogram consistent with the correct classification of the chemical.
  • Any hazard statement, signal word and precautionary statement consistent with the correct classification of the chemical.
  • Any information about the hazards, first aid and emergency procedures relevant to the chemical, which are not included in the hazard statement or precautionary statement.
  • An expiry date, if applicable.

The label may include an emergency phone number for specific poisons or treatment advice.

The label should be clearly legible and firmly fixed to the container; it shouldn’t be obscured or in a spot where it could be removed, for example on the lid.

For comprehensive information about preparing labels for workplace hazardous chemicals, please refer to the model Code of Practice: Labelling of Workplace Hazardous Chemicals.

Responsibility for labelling hazardous chemicals

Businesses at each stage of the supply chain of hazardous chemicals have duties relating to the labelling of hazardous chemical containers.

Duty holder Duties

Manufacturers and importers

Must ensure the chemical is correctly labelled in accordance with the model WHS Regulations.

Suppliers

Must not supply a hazardous chemical to a workplace if they know, or should reasonably know, that the chemical is not correctly labelled.

Businesses that use hazardous chemicals

Must ensure hazardous chemicals are correctly labelled in accordance with the model WHS Regulations, including where the chemical is stored in pipework, or transferred or decanted from the chemical’s original container at the workplace.

This duty does not apply where:

  • The hazardous chemical is a consumer product, retaining its original label and only used in workplaces in household quantities, and in a way that is incidental to the nature of the work.
  • A hazardous chemical is in transit.
  • The hazardous chemical is used immediately after being put into the container and the container is thoroughly cleaned after the chemical has been used, handled or stored so that the container is in the condition it would be in if it had never contained the hazardous chemical.

GHS transition period

All workplace hazardous chemicals manufactured, imported, or supplied after 1 January 2017 must comply with the GHS.

If the chemical was supplied before that date businesses can still use it as long as the label complies with the requirements that were in force at the time it was supplied.

You should not accept new chemicals that are not GHS-labelled as these are not compliant with the model WHS Regulations.

GHS has not been implemented in Victoria, Western Australia or the Australian Capital Territory, however all states and territories recognise and accept GHS labels and safety data sheets.

Reviewing labels

Labels should be reviewed periodically in order to keep them current, for example when:

  • A change in the formulation or ingredients changes the chemical’s hazardous properties.
  • New information on the hazards of the product or any of its ingredients becomes available.
  • The classification of a hazardous chemical changes.

Importers, manufacturers and suppliers should review any new or significant information in relation to any hazardous chemicals they import, manufacture or supply, and review the literature and other relevant information regularly.

The label should also be reviewed alongside SDS, which must be reviewed at least every five years.

Hazardous chemical label not required

In general a label is required for any hazardous chemical used in the workplace, however there are some that don’t need workplace labelling under the model WHS Regulations.

Consumer products

A hazardous chemical doesn’t need to comply with the labelling requirements of the model WHS Regulations if it’s a consumer product with the original label on its container, and it’s foreseeable it will be used in the workplace in:

  • a quantity that is consistent with consumer household use
  • a way that is consistent with consumer household use
  • a way that is incidental to the nature of the work carried out by a worker using the chemical.

Consumer products are regulated by the Standard for the Uniform Scheduling of Medicines and Poisons (SUSMP) and must comply with SUSMP labelling requirements.

If the manufacturer or importer determines the handling and storage of the product are predominantly related to a work activity, the label must meet WHS requirements.

Agricultural and veterinary chemicals

Agricultural and veterinary (AgVet) chemicals registered by the Australian Pesticides and Veterinary Medicines Authority (APVMA), and labelled in accordance with the Agricultural Labelling Code and the Veterinary Labelling Code, are not required to have full GHS labelling.

  • Signal words and pictograms are not required on AgVet chemicals.
  • GHS hazard and precautionary statements are only required when equivalent information is not already included in the APVMA label.

Manufacturers or importers must make sure any additional hazard and precautionary statements required by the model WHS Regulations are included on the label, provided they are not contrary to the information required by the APVMA.

More information is available in the Labelling requirements for agricultural and veterinary (AgVet) chemicals information sheets.

Food and beverages

Food and beverage products packaged for consumption do not need labelling under the WHS Regulations.

However, the labelling of large or bulk quantities must meet WHS requirements.

  • For example, a 200 L container of flammable alcoholic spirits must be labelled to meet WHS requirements, while a 750 mL bottle of the same spirits does not.

Therapeutic goods

Therapeutic goods are regarded as correctly labelled under the WHS Regulations when they are in accordance with Therapeutic Goods Administration (TGA) requirements and in a form intended for:

  • a patient or consumer
  • therapeutic purposes.

When not in these forms WHS labelling must be used.

  • For example when a pharmacist repacks a 1 kg container of formulated tablets in smaller containers for dispensing to patients, the 1 kg container must comply with TGA labelling requirements. However a 1 kg container of the same material in powdered form used in manufacturing or formulating products must be labelled according to workplace labelling requirements.

Cosmetics and toiletries

Under WHS Regulations, cosmetics and toiletries packaged for consumer use are exempt from WHS labelling.

  • For example sample bottles of cosmetics at retail stores and toiletries being used at a workplace do not require workplace labelling.

However when cosmetics or toiletries that are hazardous chemicals are stored, handled or used in the workplace and not packaged for consumer use, WHS labelling must be used.

This includes cosmetics and toiletries in bulk quantities that need to be repackaged, and any chemical intermediates and ingredients being used to manufacture cosmetics and toiletries.

Bulk containers

Safe Work Australia Members agreed to amend the model WHS Regulations in March 2017. These changes clarify:

  • if a bulk container needs a placard it does not need a label
  • a bulk container has a capacity that exceeds 500 litres or 500 kilograms.

These amendments are currently being progressed to allow them to be implemented in each jurisdiction.

This exemption does not apply to intermediate bulk containers (IBCs).

  • Businesses that placard IBCs containing hazardous chemicals must ensure they meet workplace labelling requirements.

More information about placards can be found on our registers, manifests and placards page.

Small containers

The WHS Regulations allow small containers to have less information on their labels.

  • There is no designated size for small containers, but are relevant when it isn't possible to include all the label elements in a way that is clear and easy to read.

This may depend on many factors including the:

Labels for small containers must include as much of the information needed for hazardous chemical labels as is possible. Priority should be given to including information about the most significant hazards on the label.

There are no mandatory sizes for label elements. Pictograms and label text should be clear and easily readable.

  • The ADG Code prescribes mandatory minimum sizes for ADG labelling elements, which must be complied with when preparing labels to meet both WHS and ADG requirements.

More information about labelling small containers is available in the model Code of Practice: Labelling of Workplace Hazardous Chemicals.

Pipework

Hazardous chemicals in pipework must be identified by a label, sign or some other way, on or near the pipework as is reasonably practicable.

It isn’t necessary to label pipework in the same way as a hazardous chemical container, but the identification used should clearly communicate information relevant to:

  • the chemical
  • its hazards
  • any necessary precautions.

Methods for identifying hazardous chemicals in pipework may include:

  • signs adjacent to it
  • markings on the pipework, for example colour coding (refer to AS 1345–1995 Identification of the contents of pipes, conduits and ducts)
  • schematic layouts displayed prominently.

Government approval

Labels for hazardous chemicals don’t need to be approved by a WHS Regulator. However, regulators can review hazardous chemical labels at a workplace to determine whether they are compliant with WHS Regulations.

Chemicals imported from overseas

A label for a hazardous workplace chemical is only acceptable if it has been prepared in accordance with the model WHS Regulations.

  • The WHS Regulations require specific information to be included on a label that may not be present on an overseas label, such as the contact details of the Australian manufacturer or importer of the hazardous chemical.

When a hazardous chemical has been imported, the Australian importer is responsible for making sure the chemical is classified and labelled in accordance with the GHS, and includes relevant Australian information such as the contact details of the Australian importer.

  • A label prepared in accordance with the GHS in other countries may have the majority of the label elements required under the WHS Regulations, but it should still be reviewed and amended as necessary.

Using labels from the ADG Code

Under the model WHS Regulations, pictograms from GHS may be substituted with correct Australian Dangerous Goods (ADG) Code class labels where both represent the same hazard.

For example, the GHS flame pictogram can be substituted with the ADG flammable liquid class label when both are applicable to the product.

ADG Flammable Liquid Class Label

GHS Flame Pictogram

ADG Flammable Liquid Class Label

A label for a workplace chemical may include a mixture of GHS pictograms and ADG class labels for separate hazards, but should not include a class label and pictogram for the same hazard.

  • For example, both the flame pictogram and the flammable liquid class label should not be included on a label for a workplace chemical.

The ADG Code prescribes minimum sizes for ADG class labels. When preparing labels to meet both workplace and transport requirements, you need to make sure the requirements of the ADG Code are met.

GHS pictograms and ADG class labels are compared in Appendix G of the model Code of Practice: Labelling of Workplace Hazardous Chemicals. The Code of Practice also includes examples of combination labels prepared for transport and workplace use.

Further advice

SWA is not a regulator and cannot advise you about labelling compliance for chemicals. If you need help, please contact your state or territory work health and safety authority.

Important

You must check with your WHS regulator if a model Code of Practice has been implemented in your jurisdiction. Check with your WHS Regulator.

This site is undergoing constant refinement. If you have noticed something that needs attention or have ideas for the site please let us know.

Last modified on Tuesday 23 May 2017 [1441|51046]