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Answer by labsupport on question GHS Implementation

Submitted by sat on 13 August 2014

The onus is on manufacturers and importers to update labels when they supply chemicals. In industry, users of chemicals are much more likely to consume the chemicals that they purchase long before labels are updated. You ask a very good question as schools are likely to have chemicals in stock for a long time and therefore need to address the labelling requirements of the old stores of chemicals. Given the number of different chemicals, this can be a very large task.

Whilst Australia is in a transition phase with the implementation of the GHS, a sensible approach is to update the label when a GHS compliant safety data sheet (SDS) has been produced. In this way, labels can be progressively updated and reflect updated information on these labels.

Information regarding labelling can be found on the Safe Work Australia website:

See: http://www.safeworkaustralia.gov.au/sites/swa/whs-information/hazardous-...

‘Codes of Practice for Labelling

Safe Work Australia’s Code of Practice for Labelling of Workplace Hazardous Chemicals provides detailed guidance on how to label workplace chemicals. This code of practice should be used where the chemical has been classified according to the GHS.’ 1

If you download the pdf ‘Labelling of Workplace Hazardous Chemicals – Code of Practice’ you will find the following information regarding the updating of information on labels

‘5.2 Reviewing and updating information on labels

From time to time, the hazard classification of a hazardous chemical may change, for example where new information becomes available. Where the hazard classification of a hazardous chemical changes, the label must be reviewed and, if necessary, revised to reflect any required changes.

Importers, manufacturers and suppliers should review any new or significant information in relation to 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.

It is good practice to review the label information of a hazardous chemical at the same time as the safety data sheet (SDS) is updated. SDSs are updated:

If you have the duty to label a workplace hazardous chemical, then you must ensure that the label contains correct information at the time it is affixed to the container of the hazardous chemical.’2

1. ‘Labelling of workplace hazardous chemicals’, Safe Work Australia website, http://www.safeworkaustralia.gov.au/sites/swa/whs-information/hazardous-... (Accessed August 2014) (© Commonwealth of Australia 2014. CC BY 3.0 AU)

2. Safe Work Australia 2011 ‘Labelling of Workplace Hazardous Chemicals – Codes of Practice, p21 Safe Work Australia website (© Commonwealth of Australia 2014. CC BY 3.0 AU)