In the section:
- Chemical classification
- Labelling requirements
- Responsibility for labelling
- Reviewing labels
- Further information
A label is the written, printed or graphical information concerning a hazardous chemical that is affixed to, printed on, or attached to the container or pipe work of a hazardous chemical. Labels must clearly identify the chemical and include information on its hazards, plus instructions and information on its safe storage, handling, use and disposal.
The label must be written in English and should be large enough to contain all of the relevant hazard and other information in a size and style that is easily visible. Labels should be appropriate to the size of the container. The label must be attached to the outside of the container and should be visible in the normal storage position. The information and any symbols on the label should be printed in a colour or colours that provide a distinct contrast to the background colour.
You can find further information on chemical labelling requirements on the Safe Work Australia website or you can call our Help Centre on 1300 365 255.
Responsibility for labelling
A PCBU must correctly label any hazardous chemical used, handled or stored at the workplace. Most hazardous chemicals purchased from a manufacturer or supplier and still in their original container should already be correctly labelled. Correct labelling is also required for all hazardous chemical manufactured at the workplace or transferred or decanted from its original container at the workplace.
Labels of workplace hazardous chemicals do not need to be formally approved to meet work health and safety requirements.
Labels must be reviewed periodically in order to ensure they are up-to-date e.g. when there is a change in the formulation or ingredients that changes the hazardous properties of the chemical, or 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 regarding 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, but at least every five years.
If you operate a business that uses hazardous chemicals you should refer to the Labelling of workplace hazardous chemicals - Code of Practice.
Chemical classification and hazard communication on labels and Safety Data Sheets (SDS) is based on the Globally Harmonised System of Classification and Labelling of Chemicals (GHS).
The GHS is a single internationally agreed system of chemical classification and hazard communication through labelling and SDS. The GHS is published by the United Nations and includes harmonised criteria for the classification of physical hazards, health hazards and environmental hazards.
All Australian states and territories have agreed to adopt the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Revision 7 under the model WHS laws for workplace hazardous chemicals.
Please note that some hazardous chemicals are excluded from the labelling provisions of the WHS Regulations and therefore the Code does not apply to those chemicals.
For modifications to the requirements of the GHS, refer to Schedule 6 of the WHS Regulations.
Delayed start to GHS 7 transitional period
The two-year transitional period for the move to GHS 7 was originally scheduled to commence on 1 July 2020. However, due to the impact of the COVID-19 pandemic, the transitional period is now expected to commence on 1 January 2021.
As a result, hazardous chemicals must continue to be labelled in accordance with GHS 3, as modified by the model WHS Regulations, until the transitional period commences, or unless an exemption or a similar regulatory allowance is made.
SafeWork SA has issued an exemption.
Some manufacturers, importers, suppliers and end users may be ready to use GHS 7 earlier than 1 January 2021. Early adopters of GHS 7 will not be penalised for using this classification system ahead of the commencement of the transitional period.
The exemption will apply from 1 July 2020 until 31 December 2020. It will enable industry to use the GHS 7 from 1 July 2020 if they had been planning to do so already. This should mean that no business is disadvantaged.
Manufacturers, importers, suppliers and end users will need to comply with the requirements set out in either the current model WHS Regulations or the exemption under regulation 684 of the model WHS Regulations for the period of the exemption.
Application of the exemption
The exemption applies where a person who manufactures, imports, supplies, labels, transfers or decanters a hazardous chemical after 1 July 2020 uses GHS 7, and therefore, does not comply with the current model WHS Regulations.
The exemption provides that the model WHS Regulations should be read as if each reference to ‘GHS’ is a reference to ‘GHS 7’. The person must meet the requirements of the model WHS Regulations as if each reference to ‘GHS’ is a reference to ‘GHS 7’ for the exemption to be applied.
Specifically, it exempts:
- manufacturers and importers from the requirement to use the GHS in the current model WHS Regulations for the purposes of regulations 329, 330(1), 330(2), 330(3) and 335 (which deals with the classification, preparation and provision of SDSs, and labelling of a hazardous chemical) if they instead use GHS 7
- suppliers from the requirement to use the GHS in the current model WHS Regulations for the purpose of regulation 338 (which deals with the labelling of a hazardous chemical) if they instead use GHS 7
- PCBUs from the requirement to use the GHS in the current model WHS Regulations for the purpose of regulations 341, 342(1), 342(2) and 345 (which deal with the labelling of a hazardous chemical and changes to SDSs) if they instead use GHS 7.
Safety Data Sheets
The exemption also ensures that where a person who manufactures or imports a hazardous chemical after 1 July 2020 uses GHS 7, the requirements that apply under Schedule 7 to the model WHS Regulations (which deal with SDS requirements) are consistent with GHS 7.
The exemption means that a manufacturer or importer who needs to review and amend an SDS between 1 July and 31 December 2020 can use GHS 7 (regulations 330(3) and 345). While an SDS may not need to be reviewed and amended during this period, it is possible that some will come up for their five yearly review. As such it makes sense that manufacturers and importers could amend an SDS in accordance with GHS 7.
Where the exemption applies and a manufacturer or importer uses GHS 7 to classify, prepare and provide an SDS, a reference to a ‘current safety data sheet’ in the model WHS Regulations (for example, regulation 330(4)) would take into account any exemption in place in a jurisdiction.
Definition of GHS 7
As the GHS 7 is not currently referred to in the model WHS Regulations, the exemption includes a definition. It states that the GHS 7 means “the Globally Harmonised System of Classification and Labelling of Chemicals, Seventh revised edition, published by the United Nations as if it were modified by Schedule 6 to the WHS Regulations.”
Schedule 6 to the model WHS Regulations modifies the application of the current version of the GHS referred to in the Regulations (that is GHS 3) by replacing some of the tables. In doing so, Schedule 6 includes notes with page number references that are specific to GHS 3. For the purposes of GHS 7, those page reference numbers should be read as:
- in the note to Table 6.1, the page reference is p.159 instead of p.151.
- in note 2 to Table 6.2, the page reference number is p.174 instead of p. 166.
- in note 2 to Table 6.3, the page reference number is p.187 instead of p.180.
- in note 2 to Table 6.4, the page reference number is p. 197 instead of p. 192.
- in note 2 to Table 6.5, the page reference number is p. 207 instead of p. 203.
Labelling chemicals - Safe Work Australia
National Code of Practice for Labelling of Workplace Substances - Safe Work Australia
Classification and labelling for workplace hazardous chemicals poster - Safe Work Australia
Hazardous chemical information system - Safe Work Australia
The GHS Third Edition - United Nations Economic Commission for Europe