The labelling of substances used in the workplace is described in the National Code of Practice for the Labelling of Workplace Substances produced by the National Commission ([NOHSC:212(1994)]). State and Territory legislation will apply the recommendations by adopting the National Model Regulations.
3.1 Purpose of labelling
Workplace labelling primarily serves two purposes, to;
 | Identify the names of the contents of the container; and |
| Communicate the significant hazards in use. |
Workplace labelling aims to assist with the safer use of substances generally as a complement to other sources of information such as the MSDS and other labelling requirements, by identifying hazards likely to be associated with the use of the substance.
Workplace label
For hazardous substances to show...
| Contents |
| Significant hazards in use |
| Complementing other information (including the MSDS) |
Workplace Label
3.2 Scope
With exceptions, (see 3.3) workplace labels are required for containers for;
| Hazardous substances; |
| Substances (drugs and poisons) included (scheduled) in the SUSDP if; |
| reasonably expected to be used in the workplace, labelled in addition to SUSDP labelling requirements; and |
| packed and sold solely for dispensary, industrial, laboratory, or manufacturing purposes, must only be labelled with workplace labelling (and not that required by SUSDP labelling; see page 416). |
Workplace labelling required for...
| Hazardous substances; and |
| SUSDP substances if used in the workplace; |
| only workplace labelling (solely for dispensary, industrial, laboratory or manufacturing; else |
| both SUSDP and workplace labelling. |
3.2.1 Also included
Substances whether or not imported, for use in any workplace, including;
| Decanted and not consumed immediately (label need only have the product name and risk and safety phrases); |
| Articles (and substances) which can produce hazardous substances during use (eg. welding rods); and |
| Containers not cleaned (until no longer containing the hazardous substances). |
Labelling also required for...
| Decanted and not for immediate use (only contents name and R and S phrases); |
| Articles (and substances) that can produce hazardous substances in use; |
| Containers not cleaned. |
3.3 Exemptions
Workplace labelling is not required for the following;
| Packed and sold as end use products being; |
| agricultural chemical products as defined by the Agricultural and Veterinary Chemicals Act 1988 (Commonwealth) and labelled in accordance with the Code of Practice for Labelling Agricultural Chemical Products; |
| veterinary chemicals as defined by the Agricultural and Veterinary Chemicals Act 1988 (Commonwealth) and labelled in accordance with the Code of Practice for Labelling Veterinary Chemical Products; |
| therapeutic goods as defined by the Therapeutic Goods Act 1989 (Commonwealth); |
| foods (including food additives included in food) for consumption by humans or animals; |
| cosmetic products;or |
| munitions and explosives. |
| Transported or in transit (including less than 48 hour temporary storage in transit in Australia) if covered by the ADG Code or other specific international legislation for surface, maritime or air transport until the importer has taken possession of the goods); |
| Decanted if for immediate use (ie. substances consumed immediately leaving the container empty); or |
| Imported if in transit in accordance with the ADG Code (or international legislation) before possession by the importer. |
| Consumer packages used by retailers and operators of warehouses for goods intended for retail sale are exempt from workplace labelling (and MSDS) requirement if the consumer packages each hold less than 30 kilograms or 30 litres and are handled unopened; and |
Labelling not required for..
| Certain regulated agricultural, veterinary, therapeutic goods, and foods, cosmetics, explosives and munitions |
| Transported or in transit |
| Decanted for immediate use |
| Imported in transit to owner |
| Consumer packages (<30 kg/L) by retailers and warehouse operators and not not opened |
| Certain containers; |
| Tanks and bulk stores are to be placarded; and |
| Enclosed systems, such as pipes, process vessels and reactor vessels must be marked according to AS 1345, Identification of the Contents of Piping, Conduits and Ducts. Refer also AS 1216, Safety Signs for the Occupational Environment and with work practices (eg. permits). |
3.4 Responsibility
Suppliers of workplace substances and employers have primary responsibility to ensure workplace hazardous substances are correctly labelled.
Who is responsible for labelling?
Suppliers of the substances, but...
Employers must ensure;
| appropriate and correct labelling |
| labelling not removed or modified |
| label decanted substances (name and R and S phrases) |
| ensure prescribed measures for lost labels and unknown substances. |
 | ensure all containers of hazardous substances are appropriately labelled if; |
| . used, |
| . delivered to the workplace; and |
| . produced within the workplace) ; |
| . known; labelled as required by the National Regulations; or |
| . not known; marked; CAUTION DO NOT USE : UNKNOWN SUBSTANCE. |
Employers should always confirm the labelling is correct as supplied before introducing the goods into the workplace.
3.5 Lost Labels
If the label is lost and the contents are unknown, the container should be;
| marked, CAUTION DO NOT USE: UNKNOWN SUBSTANCE; |
| stored in isolation until the contents can be identified. |
| if contents cannot be identified, the contents should be suitably disposed (with advice from relevant authorities). |
3.6 Replacement of labels
A new label must be issued when;
| the substance changes (including new ingredients); |
| new information becomes available that affect the information provided on the label (often instigated through a change of MSDS); or |
| new expiry date (if used) is required. |
3.7 Label Requirements - General
The requirements for all workplace labels are;
| Physical |
| On outside face of container; |
| Firmly secured; and |
| Colouring to contrast with background colour. |
| English language; |
| Durable print; and |
| Legible, through size and style. |
Variations through removal, defacing, modifications or other alterations are not permitted.
3.8 Label Detail - the Elements by Container Size
The manufacturer or importer is responsible for providing the detail contained on the label.
Components of workplace labels
Label Elements 500 mL (g) Less than
or more 500 mL (g)
Element Normal Extra small
No.
Signal words and/or 1 *** *** ***
DG Class and Sub-Risk
Identification
Product name 2.1 *** *** ***
Substance name 2.2 *** ***
UN No. 2.3 ***
Ingredient and 2.4 ***
formulation details
Risk phrases 3 *** *** M
Directions for use 4 ***
Safety phrases 5 *** *** M
First aid phrases 6 *** ***
Emergency procedures 7 ***
Manufacturer/importer 8 *** *** ***
details
Expiry date 9 ***
MSDS reference 10 *** ***
Note: *** = required elements
M = at least the most significant phrases should be used
[blank] = optional elements or support information required (extra small contain ers).
1. Signal words and Dangerous Goods Class and Sub-Risk labels.
The signal words indicate the relative degrees of hazards and the Class label and Sub-Risk labels indicate the major hazards of the substance.
| Where the contents are dangerous goods, the class and Sub-Risk labels are used; |
| Where the contents are not dangerous goods, refer the following table with words according to whether scheduled to SUSDP (and for retail sale). |
Signal Words for dangerous goods - if SUSDP Scheduled
Hazard Rating SUSDP Scheduled Not SUSDP
scheduled
CATEGORY 3 WARNING HARMFUL
carcinogens and
mutagens
CATEGORY 2 POISON TOXIC
carcinogens,
mutagens and
teratogens
CATEGORY 1 DANGEROUS POISON VERY TOXIC
carcinogens,
mutagens and
teratogens
These signal words should contrast to background (preferably red on a white background), twice the height of the general text and not less than one-quarter the height of the largest letter.
2 Identification
Provides the basis for identification of the substance. The components consist of;
2.1 Product name.
The name by which substance is known. Often also the trade name. Need not be duplicated if same as substance name (2.2).
2.2 Chemical name
In order of preference (generally not if mixture);
| Correct Shipping Name assigned by the ADG Code name; |
| SUSDP if a drug or poison scheduled in SUSDP; |
| Recognised chemical name, including abbreviations but not trade names, sufficiently informative to enable identification to enable emergency response. |
2.3 UN Number
A four digit number assigned to dangerous goods.
2.4 Ingredient and formulation details
Full identification of ingredients and composition is normally required. If commercially confidential some restraint on identification of name and composition is provided for in the Code. Variation is dependent on Type (see below). If scheduled in the SUSDP as a Drug or Poison (see page 415) full disclosure is required.
The rules are more fully outlined under the Ingredients section of volume 1 of Guide to Chemicals in Australia - The Material Safety Data Sheet. Broadly, the principles for variation from full ingredient disclosure are;
Type I ingredients Hazardous substances (other than certain harmful substances [ie. without an R-phrase]), or those with a listed exposure standard and exceeding the concentration cut-off level) must be identified by the chemical name as defined above.
Type II ingredients Harmful substances, other than Type I harmful substances (above concentration cut-off level to distinguish from Type III) may be described with a generic name if commercially confidential. Worksafe Australia must be notified on a prescribed form.
Type III ingredients Any ingredient not being Type 1 or Type II (ie. not a hazardous substance), may be identified with a generic name and Worksafe need not be notified. If commercially confidential, type II ingredients may be described as `other ingredients determined not to be hazardous' except if possessing synergistic effects.
If commercially confidential, the ingredients may also be indicated by range;
| greater than 60 %, |
| 30 - 60 %, |
| 10 - 30 %, or |
| less than 10 %). |
| : Classes of chemicals should be distinguished. |
| : Compositional variability to be indicated. |
| : Ingredients should be listed in descending order of proportion unless the substance is classified as a dangerous good which requires the technical name to be listed first. |
3 Risk phrases
Risk phrases (R-Phrases) provide a general description of the hazard under normal or reasonable foreseeable handling or use of the substance (eg. May cause fire, Irritating to eyes etc.) These phrases are listed in an appendix of the National Code./
The risk phrases are grouped for selection according to hazard categories (eg. Flammable Substances, Corrosive Substances etc).
Note
| The National Commission recommends a limit of four phrases. |
| Each hazard category should be carefully considered for relevance. |
| Additional phrases may be used if the risk category is not identified. |
4 Directions for Use.
Directions for use are used to provide specific directions for use of the substance. As directions for use often complement Safety Phrases, they should be located together.
5 Safety Phrases
Safety Phrases (S-Phrases) inform about the safe use of the substance.
eg. Avoid shock and friction, or Wear suitable gloves.
The selection of these phrases is according to the Appendix of the National Code although additional phrases may be used. Safety Phrases are grouped by categories (eg. Safe handling, Disposal etc.)
Selection
| No more than four phrases should be used. |
| The phrases in the National Code tend to be general and should be made more specific as appropriate (eg. replacing the word suitable with more specific detail such as the material used in the protective clothing). |
| According to the anticipated users |
Phrases should be grouped with directions for use with a suitable heading (eg. SAFETY).
6 First Aid Procedures
First Aid phrases provide advice on immediate action using commonly available treatments following exposure to the substance.
The phrases are provided in the appendix to the National Code and are grouped by categories (eg. General, Skin, Ingestion etc.). If the phrase are inappropriate, SUSDP first aid phrases may be used. Other phrases may then only be used if the National Code or SUSDP are inappropriate. One source of additional information are the Emergency Procedure Guides (see page 260).
Four additional (used as appropriate) phrases are provided in the Code that provide referral to doctors and a poisons information centre.
Grouping under an appropriate heading is recommended (eg. FIRST AID).
7 Emergency Procedures
Emergency procedure advice should detail simple and brief information on the control of leaks spills or fire. Advice could include materials, equipment and extinguishing agents relevant to spills, leaks and fires.
No phrases are provided by the National Commission though one source of useful phrases may be available from the Emergency Procedure Guides (see page 260).
Note: Rationalisation with the Safety Phrases may be necessary.
Note: In contrast to the MSDS, there is no specific provision in the workplace labelling code for ingredient disclosure for emergency purposes (see 12.6.1.1 and Volume 1 of the Guides).
8 Manufacturer/importer
Name, address, telephone details in Australia of the manufacturer or importer from which advice (and the MSDS) may be obtained.
9 Expiry Date
If the substance may change in composition, an expiry date should be provided as appropriate.
10 Reference to MSDS
Refer the user to the MSDS (eg. Additional information is listed
in the Material Safety Data Sheet).
From Guide to Chemicals in Australia
Editor Remco Van Santen Published by Chemlink Pty Ltd PO Box 673 West Perth
Western Australia 6872 tel +61 9 447 6666.
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