GHS Labeling
-
bigmack
- Posts: 817
- Joined: 15 Dec 2015, 10:49
- Job Title: Lab Technician
- School: FCAC
- State/Location: QLD
Re: GHS Labeling
I was wondering the same . The riskassess labels look fine for decanted amounts or the class room but not for relabelling stock supplys ( that from time to time do go out into the classroom .
-
Merilyn1
- Posts: 1477
- Joined: 12 Mar 2013, 08:10
- Job Title: Labbie
- School: Wollondilly Anglican College
- Suburb: Tahmoor
- State/Location: NSW
Re: GHS Labeling
Download a copy of the "Labelling of Workplace Hazardous Chemicals Code of Practice" from Worksafe NSW and see if that helps. When in doubt you should be checking with your own WHS people. Don't try to work it out yourself, you'll just get more confused!
We already subscribe to Riskassess and our WHS people at head office sent me on the information about the Safety Training course - so for me, I consider that to be work-endorsed, so I am running with what Riskassess recommend (and, to me, someone who has had a fair bit of WHS training, Phillip makes good sense).
We already subscribe to Riskassess and our WHS people at head office sent me on the information about the Safety Training course - so for me, I consider that to be work-endorsed, so I am running with what Riskassess recommend (and, to me, someone who has had a fair bit of WHS training, Phillip makes good sense).
-
Kathryn
- Posts: 390
- Joined: 01 Jun 2006, 10:00
- Job Title: Lab Technician
- School: Cedars Christian College
- Suburb: Farmborough Hts, Wollongong
- State/Location: NSW
Re: GHS Labeling
I am the WHS people in our school and supposedly the expert on chemical safety!
I have had a look at the "Labelling of Workplace Hazardous Chemicals Code of Practice" from Worksafe NSW as suggested by Merilyn. Personally I don't think the Riskassess labels satisfy the legal requirements according to that document, for original containers anyway. They may be ok for small containers going into the classrooms but the original container must include safety and first aid. It also must have manufacture / supplier information. I am leaving the original labels on as well so most of my chemicals have that. However I have a bunch on ancient chemicals which even if they do have supplier information it may be out of date.
This is very annoying to say the least how we have been left in the dark to try and sort this out ourselves. I have wasted so much time over it. However I am not panicking about it. I figure as long as it looks as though I have made an attempt I won't get into strife. I have done all our dropper bottles and stock solutions - with far too much info so will be glad to reduce that next time I print them (H codes eg H319 which is totally meaningless!). But I will retain safety info.
Kathryn
I have had a look at the "Labelling of Workplace Hazardous Chemicals Code of Practice" from Worksafe NSW as suggested by Merilyn. Personally I don't think the Riskassess labels satisfy the legal requirements according to that document, for original containers anyway. They may be ok for small containers going into the classrooms but the original container must include safety and first aid. It also must have manufacture / supplier information. I am leaving the original labels on as well so most of my chemicals have that. However I have a bunch on ancient chemicals which even if they do have supplier information it may be out of date.
This is very annoying to say the least how we have been left in the dark to try and sort this out ourselves. I have wasted so much time over it. However I am not panicking about it. I figure as long as it looks as though I have made an attempt I won't get into strife. I have done all our dropper bottles and stock solutions - with far too much info so will be glad to reduce that next time I print them (H codes eg H319 which is totally meaningless!). But I will retain safety info.
Kathryn
-
bigmack
- Posts: 817
- Joined: 15 Dec 2015, 10:49
- Job Title: Lab Technician
- School: FCAC
- State/Location: QLD
Re: GHS Labeling
+1 Many of our original containers are from "Q-stores" and there's no way I can find them on Chemwatch .The majority of our other containers are from Ajax chemicals ....again no up to date SDS's and certainly no GHS info . So forced to print another manufacturers ( or chemgold ) based label.Kathryn wrote: Personally I don't think the Riskassess labels satisfy the legal requirements according to that document, for original containers anyway. They may be ok for small containers going into the classrooms but the original container must include safety and first aid. It also must have manufacture / supplier information. I am leaving the original labels on as well so most of my chemicals have that. However I have a bunch on ancient chemicals which even if they do have supplier information it may be out of date.
Kathryn
I am also leaving the original label on all the bottles we have ....at least its proof who the original supplier was ....and our Chem teacher was an industrial chemist and he finds it diabolical to cover up Chemical analysis info on AR chemicals
He are some of the labels I am printing .They are a mongrel label in most cases .IE I have had to doctor the name in adobe to remove some of the Chemwatch crap but at least the GHS info is as accurate as I can get it .
I have been printing them in black and white as we don't have a colour printer and highlighting the GHS symbols in red biro. I then attach with PVA ad a clour dot and paint over the label with PVA to seal it . I have found that contact is hopeless
Please let me know if you can see any serious errors .
You do not have the required permissions to view the files attached to this post.
Re: GHS Labeling
There is a big difference in the labels, I have to admit I am confused. I like the Riskassess labels, they are very easy to read, but I also feel they are missing information. Phillip must know what is right and wrong though, makes me wonder if I should go back to using chemwatch? the more you think about it the more confused you get!! 
-
bigmack
- Posts: 817
- Joined: 15 Dec 2015, 10:49
- Job Title: Lab Technician
- School: FCAC
- State/Location: QLD
Re: GHS Labeling
I rung SafeWork NSW yesterday about two issues
1) That I was having problems finding SDS's for older Chemicals we have in our store and how was I to find an appropriate GHS label ?
Nice fellow rung back today .He said that they have had a lot of feedback from the community on this and they have realized that it is a major issue .
They have decided that if you are the end user of that Chemical , IE in our case we are as a school , We DO NOT need to re-label our existing bottles .He said this is new Legislation they are putting through now ......so in the near future we should see it from them in black and white .
We still need to label that bottle if it goes into the classroom , however , it DID NOT need the manufactures details as obviously it was no longer valid . He also said it was best to leave the original label on it as Proof of where it came from and it was quite OK to Print off an SDS from another company.
2) I was wondering at which point is a particular Molarity of a substance considered "Not Hazardous" .Queried how some suppliers of Low molarity solutions have SDS saying " assessed by WHS as non hazardous and did they therefore have a list or table on each Chemical we could check .
Another person rung me back on this matter . She sounded a bit uncomfortable in her answers , but No , they do not have any list we can check on .
She said if I could find a supplier of the same molarity product than I could use that to base my Labeling on .She said that if we are making up solutions and can't find a relevant SDS then we are to print a label that has the same GHS info as the basic stock we were using .
She thanked me for my questions and said without feedback from the public , they have no idea of the problems we are facing .
I would have talked more but between her accent and my bad case of Man Flue , communication was strained .
So this would seem to suggest why Phillip has no Manufacture info on his labels . It would be fair to assume that any new bottles we receive after 1/6/17 will be already labeled
1) That I was having problems finding SDS's for older Chemicals we have in our store and how was I to find an appropriate GHS label ?
Nice fellow rung back today .He said that they have had a lot of feedback from the community on this and they have realized that it is a major issue .
They have decided that if you are the end user of that Chemical , IE in our case we are as a school , We DO NOT need to re-label our existing bottles .He said this is new Legislation they are putting through now ......so in the near future we should see it from them in black and white .
We still need to label that bottle if it goes into the classroom , however , it DID NOT need the manufactures details as obviously it was no longer valid . He also said it was best to leave the original label on it as Proof of where it came from and it was quite OK to Print off an SDS from another company.
2) I was wondering at which point is a particular Molarity of a substance considered "Not Hazardous" .Queried how some suppliers of Low molarity solutions have SDS saying " assessed by WHS as non hazardous and did they therefore have a list or table on each Chemical we could check .
Another person rung me back on this matter . She sounded a bit uncomfortable in her answers , but No , they do not have any list we can check on .
She said if I could find a supplier of the same molarity product than I could use that to base my Labeling on .She said that if we are making up solutions and can't find a relevant SDS then we are to print a label that has the same GHS info as the basic stock we were using .
She thanked me for my questions and said without feedback from the public , they have no idea of the problems we are facing .
I would have talked more but between her accent and my bad case of Man Flue , communication was strained .
So this would seem to suggest why Phillip has no Manufacture info on his labels . It would be fair to assume that any new bottles we receive after 1/6/17 will be already labeled
-
pkij
- Posts: 119
- Joined: 10 Aug 2006, 10:00
- Job Title: Lab Tech
- School: Good Shepherd Catholic College
- Suburb: Mount Isa
- State/Location: QLD
Re: GHS Labeling
Just read this on the Safe Work Australia site;
"Users of hazardous chemicals are not required to relabel or dispose of existing stock.
It is okay to keep using, handling and storing hazardous chemicals labelled in accordance with a previous labelling code in your own workplace if the product was supplied to you before 1 January 2017.
From 1 January 2017, end-users should not accept new hazardous chemical products that are not GHS labelled, e.g. labelled in accordance with previous labelling codes."
So really it is up to chemical supplier to provide GHS labelled products from Jan 2017. This is the link to the Safe Work Australia site.
http://www.safeworkaustralia.gov.au/sit ... substances
Each jurisdiction (states) will have their own version of legislation covering GHS but will be based on the Safe work Australia Codes of Practice.
Codes of Practice are not "Law" only Acts and Regulations are, codes are provided to inform on best practice. A workplace would be advised to follow Codes of Practice or better to meet WHS requirements
From this I would think that if you are diluting or decanting hazardous chemicals then they should be labelled GHS accordingly from Jan 2017. As I use diluted chemicals I am replacing them with GHS labels from Chemwatch. The new risk assess labels look good but have not used them yet.
"Users of hazardous chemicals are not required to relabel or dispose of existing stock.
It is okay to keep using, handling and storing hazardous chemicals labelled in accordance with a previous labelling code in your own workplace if the product was supplied to you before 1 January 2017.
From 1 January 2017, end-users should not accept new hazardous chemical products that are not GHS labelled, e.g. labelled in accordance with previous labelling codes."
So really it is up to chemical supplier to provide GHS labelled products from Jan 2017. This is the link to the Safe Work Australia site.
http://www.safeworkaustralia.gov.au/sit ... substances
Each jurisdiction (states) will have their own version of legislation covering GHS but will be based on the Safe work Australia Codes of Practice.
Codes of Practice are not "Law" only Acts and Regulations are, codes are provided to inform on best practice. A workplace would be advised to follow Codes of Practice or better to meet WHS requirements
From this I would think that if you are diluting or decanting hazardous chemicals then they should be labelled GHS accordingly from Jan 2017. As I use diluted chemicals I am replacing them with GHS labels from Chemwatch. The new risk assess labels look good but have not used them yet.
Re: GHS Labeling
We should NOT be relabeling original containers!!!
Risk assess labels are for "aliquot containers" as per the GHS requirements. As of 1/1/2017 all manufacturers must send chemicals correctly labels or else they are acting illegally. If you receive anything after this date not labeled correctly, then it must be sent back.
I have read a lot of stuff on the GHS requirements, including the "Blue Book" or what ever the official document is called (I actually have it downloaded, yes I am a WHS nerd at times)
I think the confusion is coming from the fact that people are looking at the details for manufacturers and not end users.
Essentially end users (like us) must do 2 things really:
1. only accept chemicals from suppliers which meet the GHS labelling requirements after 1/1/2017
and
2. Label every aliquot in accordance to GHS requirements for aliquots
It really is that simple.
Risk assess labels are for "aliquot containers" as per the GHS requirements. As of 1/1/2017 all manufacturers must send chemicals correctly labels or else they are acting illegally. If you receive anything after this date not labeled correctly, then it must be sent back.
I have read a lot of stuff on the GHS requirements, including the "Blue Book" or what ever the official document is called (I actually have it downloaded, yes I am a WHS nerd at times)
I think the confusion is coming from the fact that people are looking at the details for manufacturers and not end users.
Essentially end users (like us) must do 2 things really:
1. only accept chemicals from suppliers which meet the GHS labelling requirements after 1/1/2017
and
2. Label every aliquot in accordance to GHS requirements for aliquots
It really is that simple.
Re: GHS Labeling
As I said to Phillip in a recent PD, the risk of relabeling a original containers is huge (considering under the rules no other label must be visible). Technically, if you want to adhere to the letter of the law, everything that leaves your chemical store must be GHS compliant. Anything that is in the chem store doesn't legally need to be. My argument was that for the 2 minutes it takes me to measure out a chemical and put it back in the store, it is highly improbably that somebody with the authority to fine me will come walking into my school and through the prep room door. It just will not happen. And if you still are not happy with that, place a weight balance in your chem store so that the original container never has to leave. This will fulfil ALL requirements under the new system.
Like all the rules and regs, they do not differentiate between me with my 500g of Hazardous chemical and industry with their 2 tonnes. As with everything legal, the "reasonable person" test would apply.
Like all the rules and regs, they do not differentiate between me with my 500g of Hazardous chemical and industry with their 2 tonnes. As with everything legal, the "reasonable person" test would apply.
Re: GHS Labeling
This is from Guidance on the Classification of Hazardous Chemicals under the WHS Regulations from Safe Work Australia
3.2 Concentration cut-off values for classification of mixtures
The official GHS text provides details of how the criteria should be applied to the classification of mixtures. This includes details of concentration cut-off values. For some hazard classes and categories in the GHS however, competent authorities are given an option of which concentration cut-off value to use.
Australia is implementing specific classification cut-off values and concentration limits for mixtures for the following hazard classes:
• respiratory and skin sensitisers;
• carcinogens;
• reproductive toxicants
• specific target organ toxicants single and repeat exposures.
These values and limits are prescribed in Schedule 6 of the WHS Regulations, and are reproduced in Appendix G of this guide. These tables replace the specified tables in the GHS. The cut-off values and concentration limits of Schedule 6 show the amount of the hazardous ingredient in a mixture or article that would result in classification of the mixture.
Mixtures
For some mixtures, it may not be possible to directly translate its hazardous substance classification into a GHS classification because of differences in cut-off concentrations used in the Approved Criteria and the GHS. In these cases, additional steps may be required.
Where the mixture itself has been tested then the data on the mixture should always be used to classify the mixture in preference to calculations based on individual ingredients.
If there is no available test data or information on the mixture itself, then it is essential to obtain the list of ingredients and their percentage content in the mixture so that the correct GHS classification of the mixture can be determined. Each substance in the mixture can then be classified using options 1 or 2 detailed in section 3.1 above.
Using the hazard classification for each ingredient in the mixture, the mixture’s classification can be determined using the criteria and decision logic described in the official GHS text for each hazard class.
3.2 Concentration cut-off values for classification of mixtures
The official GHS text provides details of how the criteria should be applied to the classification of mixtures. This includes details of concentration cut-off values. For some hazard classes and categories in the GHS however, competent authorities are given an option of which concentration cut-off value to use.
Australia is implementing specific classification cut-off values and concentration limits for mixtures for the following hazard classes:
• respiratory and skin sensitisers;
• carcinogens;
• reproductive toxicants
• specific target organ toxicants single and repeat exposures.
These values and limits are prescribed in Schedule 6 of the WHS Regulations, and are reproduced in Appendix G of this guide. These tables replace the specified tables in the GHS. The cut-off values and concentration limits of Schedule 6 show the amount of the hazardous ingredient in a mixture or article that would result in classification of the mixture.
Mixtures
For some mixtures, it may not be possible to directly translate its hazardous substance classification into a GHS classification because of differences in cut-off concentrations used in the Approved Criteria and the GHS. In these cases, additional steps may be required.
Where the mixture itself has been tested then the data on the mixture should always be used to classify the mixture in preference to calculations based on individual ingredients.
If there is no available test data or information on the mixture itself, then it is essential to obtain the list of ingredients and their percentage content in the mixture so that the correct GHS classification of the mixture can be determined. Each substance in the mixture can then be classified using options 1 or 2 detailed in section 3.1 above.
Using the hazard classification for each ingredient in the mixture, the mixture’s classification can be determined using the criteria and decision logic described in the official GHS text for each hazard class.
Re: GHS Labeling
It is such a big headache, I have been contacting other labbies in my area regarding GHS & labels, and here we have been told not to do any mass relabelling yet. See advice from one of our emails below:
"DoE, UNSW and SafeWork NSW are having discussion in regards to these changes till then schools should not be proactively labelling containers.
Schools MUST await advice that will be provided as soon as something is finalised.
Any queries in regards to GHS can be directed to Alan via email compliance@det.nsw.edu.au"
I have no idea when we will actually be issued with the advice, and how we will manage to relabel everything in time!!!!
Mel
"DoE, UNSW and SafeWork NSW are having discussion in regards to these changes till then schools should not be proactively labelling containers.
Schools MUST await advice that will be provided as soon as something is finalised.
Any queries in regards to GHS can be directed to Alan via email compliance@det.nsw.edu.au"
I have no idea when we will actually be issued with the advice, and how we will manage to relabel everything in time!!!!
Mel
Re: GHS Labeling
I don't think NSW or VIC have officially signed up to the new WHS legislation (which included GHS)
I find it pretty ridiculous myself, given this is an international initiative, but as WHS is state based, all states have control over whether they pass the legislation or not. From memory I think they have issues with parts of the WHS act, not the GHS in itself.
Will be interesting come 1/1/2017 when the rest of Australia refuses to take any goods not correctly labelled under their state laws.
I find it pretty ridiculous myself, given this is an international initiative, but as WHS is state based, all states have control over whether they pass the legislation or not. From memory I think they have issues with parts of the WHS act, not the GHS in itself.
Will be interesting come 1/1/2017 when the rest of Australia refuses to take any goods not correctly labelled under their state laws.
-
Wayne
- Posts: 305
- Joined: 17 May 2006, 10:00
- School: Mount Carmel College
- Suburb: Sandy Bay
- State/Location: TAS
Re: GHS Labeling
Thanks! As you would know I wasn't in Launceston at that PD (I went to the one in Hobart 2014, so "didn't need to go again"linotas wrote:We should NOT be relabeling original containers!!!
Risk assess labels are for "aliquot containers" as per the GHS requirements. As of 1/1/2017 all manufacturers must send chemicals correctly labels or else they are acting illegally. If you receive anything after this date not labeled correctly, then it must be sent back.
I have read a lot of stuff on the GHS requirements, including the "Blue Book" or what ever the official document is called (I actually have it downloaded, yes I am a WHS nerd at times)
I think the confusion is coming from the fact that people are looking at the details for manufacturers and not end users.
Essentially end users (like us) must do 2 things really:
1. only accept chemicals from suppliers which meet the GHS labelling requirements after 1/1/2017
and
2. Label every aliquot in accordance to GHS requirements for aliquots
It really is that simple.
), 2 teachers went though and they informed me that I had to relabel everything in the chemstore! Thankfully only done a few so will now stop.-
Merilyn1
- Posts: 1477
- Joined: 12 Mar 2013, 08:10
- Job Title: Labbie
- School: Wollondilly Anglican College
- Suburb: Tahmoor
- State/Location: NSW
Re: GHS Labeling
NSW has definitely adopted GHS. Off top of my head, I can't remember which states hadn't.linotas wrote:I don't think NSW or VIC have officially signed up to the new WHS legislation (which included GHS)
-
Labbie
- Posts: 3238
- Joined: 28 Nov 2006, 10:00
- Job Title: Retired
- Suburb: At Home
- State/Location: NSW
Re: GHS Labeling
Yes NSW has like you Merilyn I can not remember which other states did not.
Regards Labbie
Lab Manager/Lab Tech, mind reading etc etc
Now retired
Lab Manager/Lab Tech, mind reading etc etc
Now retired
Re: GHS Labeling
I thought it was WA and NT that hadn't signed up.
Re: GHS Labeling
Victoria hasn't signed up as yet
Rell
Rell
Re: GHS Labeling
Just looked at Safe Work Australia and a document on there says WA and VIC are the only states not signed up. (NT s under federal jurisdiction which was the first to implement)
-
Merilyn1
- Posts: 1477
- Joined: 12 Mar 2013, 08:10
- Job Title: Labbie
- School: Wollondilly Anglican College
- Suburb: Tahmoor
- State/Location: NSW
Re: GHS Labeling
Hopefully the people in WA and VIC are aware of this!
Re: GHS Labeling
SO - what should we do?? Phil Crisp told people to put black tape over existing label and put new GHS label on the bottle - do we do it or not???
we are told so many conflicting things aren't we!And no one makes the final decision.. we are left having to decide what is correct - we are supposed to be able to read and understand legalese .. where DOES our responsibility end????
we get no input from management - we are out there by ourselves.. why do we do it for this tiny pay packet?? we really do need to all get on to a petition and hassle union to get us more recognition and more pay..I have been fighting for this for about 8 years now - but am treated like " oh here she is whinging again".. and it is NOT just for me - it is for all of us, anduntil ALL of us speak up as a united body we wont get anywhere..
we are told so many conflicting things aren't we!And no one makes the final decision.. we are left having to decide what is correct - we are supposed to be able to read and understand legalese .. where DOES our responsibility end????
we get no input from management - we are out there by ourselves.. why do we do it for this tiny pay packet?? we really do need to all get on to a petition and hassle union to get us more recognition and more pay..I have been fighting for this for about 8 years now - but am treated like " oh here she is whinging again".. and it is NOT just for me - it is for all of us, anduntil ALL of us speak up as a united body we wont get anywhere..
