Old Chemicals

Old Chemicals: I have some old chemicals that either don't have a supplier's name, or the companies don't exist anymore.  How do I label them? Do I use an updated SDS from another company and put the relevant classifications, hazard statements, etc. on the label?

Thanks.

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Publication Date: 20 November 2015
Asked By: Michelle
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Old Chemicals

Expert Answer

If you have chemicals whose original supplier is either 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 that 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/sites/swa/about/publications/pages/l...

Old Chemicals

Hi Michelle,

As I understand there are several associated factors to be considered for the SDS for the chemical.

Supply of the SDS 

I understand from various authorized source of information that supplier must supply and update if required to be reviewed after 5 years. One of such authorised sources of information is Safe Work Australia. On its website there are lot of related information available.

It says – 

Duties under the WHS Regulations 

The Work Health and Safety Regulations (WHS Regulations) require the manufacturer or importer of a hazardous chemical to prepare an SDS for the chemical. Additionally, a supplier must provide the manufacturer or supplier’s current SDS for the hazardous chemical on first supply to a workplace and upon request. 

Source - http://www.safeworkaustralia.gov.au/sites/swa/whs-information/hazardous-chemicals/sds/pages/sds

 

Duration/validity of an SDS

Another point on the same page of the above webpage says –

Reviewing an SDS 

An SDS must be reviewed periodically to keep it up to date, for example when any new or significant information becomes available on the hazards of the material. Otherwise, a SDS must be reviewed and re-issued every 5 years. 

That means for hazardous chemicals, as I understand, if supplier's name is not available on the container of chemical or the company does not exist anymore than it raises question of validity of the SDS in case of hazardous chemical after 5 years (legal valid duration) of the issue/preparation date of the SDS supplied by the company.  

and then next para says –

SDS do not need to be formally approved. However, the work health and safety authority in each State and Territory is responsible for enforcing compliance with the WHS Regulations. You should therefore contact the work health and safety authority in your jurisdiction for advice on whether your SDS is compliant with the WHS Regulations. 

Source - http://www.safeworkaustralia.gov.au/sites/swa/whs-information/hazardous-chemicals/sds/pages/sds

That means best way (and right way) to find correct answer to your query is to check and find out with the local authority in your jurisdiction.

I hope the answer will be helpful for your query.

With regards

N Trivedi

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