Workplace label

horizontal rule

horizontal rule

Custom Search
Labels often represent the first source of information about chemicals in the workplace with more comprehensive information available from the Material Safety Data Sheet (ie. if the contents is a hazardous substance).

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;

bulletIdentify the names of the contents of the container; and
bulletCommunicate 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...

bulletContents
bulletSignificant hazards in use
bulletComplementing other information (including the MSDS)

Workplace Label

3.2 Scope

With exceptions, (see 3.3) workplace labels are required for containers for;

bulletHazardous substances;
bulletSubstances (drugs and poisons) included (scheduled) in the SUSDP if;
bulletreasonably expected to be used in the workplace, labelled in addition to SUSDP labelling requirements; and
bulletpacked 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...

bulletHazardous substances; and
bulletSUSDP substances if used in the workplace;
bulletonly workplace labelling (solely for dispensary, industrial, laboratory or manufacturing; else
bulletboth SUSDP and workplace labelling.

3.2.1 Also included

Substances whether or not imported, for use in any workplace, including;

Substances which are dangerous goods and subject to the ADG Code (ie. intended for transport, [see 28]), must be labelled in accordance with the Code in addition to workplace labelling requirements.

bulletDecanted and not consumed immediately (label need only have the product name and risk and safety phrases);
bulletArticles (and substances) which can produce hazardous substances during use (eg. welding rods); and
bulletContainers not cleaned (until no longer containing the hazardous substances).

Labelling also required for...

bulletDecanted and not for immediate use (only contents name and R and S phrases);
bulletArticles (and substances) that can produce hazardous substances in use;
bulletContainers not cleaned.

3.3 Exemptions

Workplace labelling is not required for the following;

bulletPacked and sold as end use products being;
bulletagricultural 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;
bulletveterinary 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;
bullettherapeutic goods as defined by the Therapeutic Goods Act 1989 (Commonwealth);
bulletfoods (including food additives included in food) for consumption by humans or animals;
bulletcosmetic products;or
bulletmunitions and explosives.
bulletCertain activities;
bulletTransported 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);
bulletDecanted if for immediate use (ie. substances consumed immediately leaving the container empty); or
bulletImported if in transit in accordance with the ADG Code (or international legislation) before possession by the importer.
bulletConsumer 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..

bulletCertain regulated agricultural, veterinary, therapeutic goods, and foods, cosmetics, explosives and munitions
bulletTransported or in transit
bulletDecanted for immediate use
bulletImported in transit to owner
bulletConsumer packages (<30 kg/L) by retailers and warehouse operators and not not opened
bulletCertain containers;
bulletTanks and bulk stores are to be placarded; and
bulletEnclosed 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;

bulletappropriate and correct labelling
bulletlabelling not removed or modified
bulletlabel decanted substances (name and R and S phrases)
bulletensure prescribed measures for lost labels and unknown substances.
bulletSuppliers assume the responsibility for correct labelling of hazardous substances supplied to others. bulletEmployers must;
bulletensure all containers of hazardous substances are appropriately labelled if;
bullet. used,
bullet. delivered to the workplace; and
bullet. produced within the workplace) ;
bulletensure labels are not removed, modified, defaces a correct label; bulletif, the substance is decanted (placed into another container), provide labelling (to indicate the product name, risk and safety phrases); bullettake action to correctly label if the label is lost or improperly labelled by either, if the contents are:
bullet. known; labelled as required by the National Regulations; or
bullet. 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;

bulletmarked, CAUTION DO NOT USE: UNKNOWN SUBSTANCE;
bulletstored in isolation until the contents can be identified.
bulletif 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;

bulletthe substance changes (including new ingredients);
bulletnew information becomes available that affect the information provided on the label (often instigated through a change of MSDS); or
bulletnew expiry date (if used) is required.

3.7 Label Requirements - General

The requirements for all workplace labels are;

bulletPhysical
bulletOn outside face of container;
bulletFirmly secured; and
bulletColouring to contrast with background colour.
bulletDetail
bulletEnglish language;
bulletDurable print; and
bulletLegible, through size and style.
bulletAlterations

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.

bulletWhere the contents are dangerous goods, the class and Sub-Risk labels are used;
bulletWhere 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);

bulletCorrect Shipping Name assigned by the ADG Code name;
bulletSUSDP if a drug or poison scheduled in SUSDP;
bulletRecognised 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;

bulletgreater than 60 %,
bullet30 - 60 %,
bullet10 - 30 %, or
bulletless than 10 %).
bullet: Classes of chemicals should be distinguished.
bullet: Compositional variability to be indicated.
bullet: 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

bulletThe National Commission recommends a limit of four phrases.
bulletEach hazard category should be carefully considered for relevance.
bulletAdditional 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

bulletNo more than four phrases should be used.
bulletThe 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).
bulletAccording 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.

fax +61 (0)8

Commments and suggestions welcomed.

 

horizontal rule

Home page Chemicals in Australia

horizontal rule

Created: Sunday, 24 December 1995, 3:39:27 PM Last Updated: Sunday, 24 December 1995, 3:39:27 PM