Answer reviewed 9 February 2023
Australian workplace health and safety legislation specifies the minimum requirements for labels for hazardous chemicals, including decanted or transferred chemicals (such as in your case).
In all states and territories except for Victoria, the label of a decanted or transferred hazardous chemical must include:
- the product identifier (name of the chemical), and
- a hazard pictogram or hazard statement consistent with the correct classification of the chemical.1
Under Victorian legislation, the label of a decanted hazardous chemical need only include the product identifier.2
From your description, the Chemwatch label has the relevant hazard statements, and therefore it would not need to also include the pictograms.
As explained in the model Code of Practice,1 to meet compliance with the Australian Work Health and Safety legislation, “It is not mandatory to include information relating to environmental hazard categories on the label of a workplace hazardous chemical.”1 However, the Code of Practice1 allows for the addition of “any other information…that is reasonably practicable to include”1 to convey the relevant hazards on the labels of decanted chemicals. The guidance material also advises that environmental hazard information “should be included if a fully GHS-compliant label is desired”.1 Therefore, if there is room on the label, you could add the GHS09 (Environment) pictogram.
As general considerations: the label should be consistent with information in the manufacturer specific SDS; the classification for a solid chemical will differ from that of a solution of the chemical, and for different concentrations of solutions; the hazardous properties of chemicals may diminish as they are diluted and this should be reflected in the SDS and the label.
For further information on labelling see the Science ASSIST Information Sheet.3
1 Safe Work Australia, 2020, Model Code of Practice: Labelling of workplace hazardous chemicals, Retrieved from the Safe Work Australia website: https://www.safeworkaustralia.gov.au/doc/model-code-practice-labelling-workplace-hazardous-chemicals
2 WorkSafe Victoria, 2019, Compliance Code: Hazardous Substances (Edition 2) Retrieved from the WorkSafe Victoria website: https://www.worksafe.vic.gov.au/resources/compliance-code-hazardous-substances
3 Science ASSIST. 2023. Science ASSIST Information Sheet: Chemical Labels. Retrieved from the Science ASSIST website: https://assist.asta.edu.au/resource/2455/science-assist-information-sheet-chemical-labels