labeling old chemicals in store

MSDSs, Storage, Handling, Transport, Labeling, computer management systems, and anything else to do with safety.
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AnnNos
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Re: labeling old chemicals in store

Post by AnnNos »

It seems that everything is as clear as mud.
I chair our WHS Committee and I can't get answers from anyone. Our WHS consultant just passed on the information that:
'You keep doing what you have been doing until directed by the Department and the new CSIS is delivered.'
I can't see how we can be held responsible for not being GHS prepared. I'm not going to do everything the way I think it should be done and then have to do it all again.
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rae
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Re: labeling old chemicals in store

Post by rae »

Could we pose a question on the ASSIST site? They will then research and maybe give us an answer for now?
Merilyn1
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Re: labeling old chemicals in store

Post by Merilyn1 »

Has someone already done that? I haven't got time at the moment to check. I suspect they would answer it according to legislative requirements and may not go into the practicalities of putting it in place. I'll have a look later though because it is a good idea.
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ELIZABETH
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Re: labeling old chemicals in store

Post by ELIZABETH »

Yes it has been well answered on ASSIST, search labeling.
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sunray18
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Re: labeling old chemicals in store

Post by sunray18 »

I was told it was not legal to cover up the original label - so I am slowly working through putting GHS labels on the back of the bottle, so they have both the old and the new - THAT way I cover all bases.
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sunray18
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Re: labeling old chemicals in store

Post by sunray18 »

Has anyone else ever thought that we ALL struggle to do the right thing - we ALL help each other in knowing what we shoudl and shouldn't do, and yet it is our EMPLOYER who should be telling US what is the legal requirements.
In any other industry or workplace we would be TOLD what we had to do - especially on our low rate of pay [and may I add low status in a school] but here we are being at the forefront of researching and discovering what we need to do to keep the schools legally compliant..
NOW - WHY? we are not the incompetent ones - those who are above us are!
Merilyn1
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Re: labeling old chemicals in store

Post by Merilyn1 »

Sunray, I couldn't agree more! Why is that we are working in large organisations but we are expected to figure this out for ourselves? I felt more supported in the WHS field when I worked in the nursery industry in a business of 12 staff where we were well supported by the industry association which employed a WHS consultant.

I have just spent 10 minutes reading up on Science Assist and it seems like they still have to make final decisions also. I now feel like my head is going to explode. It shouldn't be like this!

I just found out that the WHS person from our head office who was going to organise training for us, left last November. The best they can now offer is they are having a meeting in March and may have an outcome then.

Rant, rant, rant.... :mad: Maybe a should be posting this on the "whinge"forum
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rae
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Re: labeling old chemicals in store

Post by rae »

This comes directly from ASSIST. The question was about labelling old chemicals. Sorry its so long but it is relevant.
If you have chemicals whose original supplier is unknown or no longer exists, you should make an assessment of the chemicals to determine if they are stable, have not degraded and are still fit for purpose. For chemicals which have not degraded and are still in use, then it would be reasonable to keep them in stock. However, for chemicals which are old and likely to have degraded, or where there is doubt as to their stability, then we recommend that they be disposed of.

In determining whether a chemical is stable, consideration should be given to its hygroscopicity (capacity to absorb moisture), volatility, sensitivity to light or air, propensity to form peroxides or polymerise, etc. For more information about the factors which can affect the shelf life of chemicals, see Chemical Storage Timeframes.

We have sought advice from the safety regulators on the subject of the labelling of chemicals to meet compliance with the GHS. According to this advice, where the supplier or manufacturer of a chemical is unknown or no longer in business, it would be acceptable to refer to a relevant SDS from another supplier or other reputable source. You should ensure that the chemical covered by the SDS is in the same form as the one you have in stock. Relabelling the bottle with a GHS-compliant label using the information from this SDS would be acceptable.

The advice we have received is that in NSW, all bottles of chemicals are required to be relabelled with GHS-compliant labels by January 1st 2017, while in other jurisdictions, the end user will not be required to relabel bottles which still have their original pre-GHS label.

Nevertheless, Science ASSIST recommends that schools endeavour to relabel old stock bottles in accordance with the GHS requirements, so that labels are consistent, which will help staff and students to become familiar with the GHS system.

SafeWork Australia has provided guidelines for implementing the GHS system of labelling chemicals in their Code of Practice for the Labelling of Workplace Hazardous Chemicals. This Code of Practice has been adopted in each of the jurisdictions which have incorporated the GHS into their WHS legislation. The following extract from Section 2 of the Code of Practice gives details of the elements which are required for a GSH-compliant label:

Regulation 335, Part 3 of Schedule 9: A hazardous chemical is correctly labelled if the chemical is packed in a container that includes the following:
•is written in English
•the product identifier
•the name, Australian address and business telephone number of either the manufacturer or importer
•the identity and proportion disclosed, in accordance with Schedule 8 of the WHS Regulations, for each chemical ingredient
•any hazard pictogram(s) consistent with the correct classification(s) of the chemical
•any hazard statement(s), signal word and precautionary statement(s) that is consistent with the correct classification(s) of the chemical
•any information about the hazards, first aid and emergency procedures relevant to the chemical, which are not otherwise included in the hazard statement or precautionary statement, and
•the expiry date of the chemical, if applicable.

You may include any information on the label that does not contradict or cast doubt on any other information that is required on the label.

Where the manufacturer’s details are unknown or obsolete, Science ASSIST recommends including the phone number of the Poisons Information Centre. The SDS should be readily accessible in case the Poisons Information Centre needs to be contacted.

Reference

‘Code of Practice for the Labelling of Workplace Hazardous Chemicals’. 2015. Safe Work Australia website, http://www.safeworkaustralia.gov.au/sit ... ions/pages
MariaQ
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Re: labeling old chemicals in store

Post by MariaQ »

And what about storage requirements???
curie
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Re: labeling old chemicals in store

Post by curie »

What about my old "mate" the groundsman. (I use the term loosely) who I struggle to get to fill in any form of chemical register, let alone one a reasonable person would believe is valid. I shudder to think what he has down there that he hasn't declared and how old it is.
curie
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Re: labeling old chemicals in store

Post by curie »

sunray18 wrote:Has anyone else ever thought that we ALL struggle to do the right thing - we ALL help each other in knowing what we shoudl and shouldn't do, and yet it is our EMPLOYER who should be telling US what is the legal requirements.
In any other industry or workplace we would be TOLD what we had to do - especially on our low rate of pay [and may I add low status in a school] but here we are being at the forefront of researching and discovering what we need to do to keep the schools legally compliant..
NOW - WHY? we are not the incompetent ones - those who are above us are!
Those above us probably wouldn't have a clue. If they do they don't care!
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fibreweb
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Re: labeling old chemicals in store

Post by fibreweb »

I can't see anything there that says the old labels should be covered.
My experience with the original labelling following the CSIS was that incorrect labels were affixed to bottles, probably all in good faith by inexperienced people. Maybe picking up the wrong bottle, the label belonged to another bottle on the bench!
Not even the right chemical.
If the old label is completely covered you have to trust the label maker to have been correct. This is why I try to keep at least the chemical name uncovered so that someone in the future can be certain that what my hand made label says is what the supplier put into the bottle.
The old class symbols are covered and new hazard codes and precautionary statements attached.
It is a huge responsibility to ensure that we don't accidentally label a chemical incorrectly and obliterate what that chemical actually is.
Imagine the liability if it is found your label and chemical don't match.
Even Sodium Carbonate accidentally labelled sodium hydrogen carbonate, this would totally stuff up a titration assessment task.
If, at some time in the future, someone in absolute authority, with accurate information from Workplace Australia or some other governing body has in writing that the actual chemical information needs to be covered with a handmade, home generated label then I will put a blank label over it.
I have read all that I can about labelling and attended multiple conferences/workshops/training days and this is what I feel comfortable with.
Merilyn1
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Re: labeling old chemicals in store

Post by Merilyn1 »

Rae - I also read a response to question posted on the 8th October which said they were discussing this issue with Safe Work Australia. The post you copied is only a few weeks after this one. We might not be the only ones who are not sure what is going on.
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rae
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Re: labeling old chemicals in store

Post by rae »

More info found on ASSIST. There is a lot of information on there!
http://assist.asta.edu.au/sites/assist. ... micals.pdf
CC
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Re: labeling old chemicals in store

Post by CC »

Hi all,
Glad to see I'm not alone. My anxiety is so bad over this that I burst into tears in front of the HT today when asking if she new where to put the labels. I felt like a real goose.
Is everybody printing their labels from chemwatch? I am so if i'm doing it wrong can someone let me know please
More Anxiety

CC.
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gotolady
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Re: labeling old chemicals in store

Post by gotolady »

How do we find out what is expected from us and when do we have to have the changes done by? I have not seen a single email or directive from the DEC or any relevant department . Just how are we supposed to do our every day tasks and try to fit in the new labelling and SDS into our day!!!!! I know how you feel CC but think we are all in the same boat....up the creek with no hope of a paddle.
bigmack
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Re: labeling old chemicals in store

Post by bigmack »

I recon the hottest selling Item at next years SLAMN will be Approved labels to suit all our typical containers :D

With every purchase , a notification to the WHS Auditers to leave you till last :lol:
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remlap12
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Re: labeling old chemicals in store

Post by remlap12 »

Do we have to put GHS labels on EVERYTHING?
For example, paraffin oil, agar, aluminium oxide, barium sulphate, etc etc etc,
when looked up in Chemwatch the label has absolutely no information on it?
Regards
remlap12
science support and problem solver :mail:
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Labbie
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Re: labeling old chemicals in store

Post by Labbie »

yes. :coffee:
Regards Labbie

Lab Manager/Lab Tech, mind reading etc etc
Now retired :wub:
Merilyn1
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Re: labeling old chemicals in store

Post by Merilyn1 »

CC wrote:Hi all,
Glad to see I'm not alone. My anxiety is so bad over this that I burst into tears in front of the HT today when asking if she new where to put the labels. I felt like a real goose.
Is everybody printing their labels from chemwatch? I am so if i'm doing it wrong can someone let me know please
More Anxiety

CC.
You poor thing, Cindy. That just sounds awful, but it is a reflection of how a lot of us are feeling - time running out and still no solid information. I'm feeling abandoned by our head office, but at least I feel well supported within the school.

At the moment, our best option is Chemwatch.
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