Responding to incorrect or unlabeled chemicals

Jan 14, 2019 Posted by Walter Ingles

Business owners and operators have a legal obligation to ensure that their hazardous chemicals held at the workplace are labeled correctly, and in accordance with the model WHS Regulations. This blog explains what to do if you encounter a chemical container that has:

  • A substance you don’t recognise.
  • No label at all.
  • A damaged or faded label.
  • Been imported from overseas and the label doesn’t follow Australian protocols.

REMEMBER: In Australia, chemical labels must follow the GHS (Globally Harmonised System of Classification and Labelling of Chemicals) and clearly display: a product identifier; hazard class pictogram and hazard statement, signal word, relevant precautionary statements, first aid and emergency information.

Unlabeled chemical containers

All chemical containers must display correct labels, this includes chemicals decanted or transferred out of their original container; chemicals manufactured in the workplace (including lab research and samples); and chemical waste. We’ll look at these separately below.

Decanted chemicals

Many fuels and cleaning chemicals are purchased in bulk and decanted into portable containers for workers to take back to individual work stations. These smaller containers also require labels, and must display (as a minimum) the hazard class pictogram and hazard statement.

The only circumstances where decanted chemicals do NOT require labels is when the chemical:

  • Will be used immediately by (only) the person who decanted it.
  • Is not left unattended at any time.
  • The entire contents of the container will be used within their immediate shift.
  • The container is cleaned so thoroughly that no trace elements of the chemical remain inside — eg, the container would be in a same condition as if the chemical had never been inside.

NOTE: When a portable container is regularly used for decanting it must be permanently labeled with the full chemical label. Once permanently labeled, the container must never filled with another substance.

Research chemicals and analysis samples

You’ll need to create labels for any chemicals manufactured in the lab for research and analysis purposes. These labels must be in English and have a product identifier and hazard pictogram/statement. In some situations the product identifier may include recognisable acronyms and the chemical formula/structure.

IMPORTANT: A chemical that you supply commercially to another workplace is not considered a research chemical or sample.

Hazardous waste

If you suspect any of your waste materials could be a hazardous chemical, it must be labeled properly. You should include as much information about the hazard as you can, and this could be: precautionary statements, chemical ingredients and hazard classes; first aid and safety directions. If you are unable to identify the hazards (and you have actually made a reasonable attempt to do so) you should clearly write this on the label.

IMPORTANT: If you are unable to identify the hazards of the chemical waste you are producing, you may need to treat the waste as an unknown substance and seek professional advice from your waste management authority.

Unknown substances in the workplace

An unknown substances could be a container with a label that has fallen off or faded so much you can’t read it. Alternately it could be a liquid in a plastic cup with a strange smell. It could be a by-product from a chemical reaction gone wrong. If you do encounter an unknown substance in the workplace you’ll need to take steps to either identify and correctly label the substance, or dispose of it safely.

Take the following steps:

  1. Attach a label to the substance with the following statement: Caution - Do Not Use - Unknown Substance.
  2. Take reasonable steps to identify the chemical. This could be asking staff about the origin of the container, or calling a chemical supplier
  3. Isolate the chemical from work areas and most especially flammable materials and Dangerous Goods.
  4. Consult your relevant waste management authority for assistance with safe disposal.

Remember: If you don’t know what a substance definitely is, it’s unlikely you’ll be able to dispose of it safely.

Incorrect or damaged labels on hazardous chemicals

You should ensure that all commercially purchased chemicals are received with proper labels, and train your staff not to accept deliveries of chemicals if the labels are obscured or damaged in any way. When purchasing from different suppliers or introducing new chemicals to the workplace (particularly chemicals imported from overseas) you’ll need to be especially careful.

Ask yourself as you inspect the label on an imported chemical:

  • Is the label in English?
  • Does it follow GHS protocols?
  • Is the text clear and easy to read (eg, some developing countries use tiny fonts and cheap printing materials and the text can be quickly rendered unreadable)

Over time (and with heavy use) chemical labels can become damaged or obscured. Train your staff (or conduct regular safety audits) to flag these containers for corrective action and re-labeling. If you don’t have approved job procedures for label printing you should contact the supplier to assist you with a replacement label.

If you find that any container of a hazardous chemical with an incorrect label, attach a product identifier and store it in isolation until it can be correctly labeled.

Remember: A label for a hazardous workplace chemical is only acceptable if it has been prepared in accordance with the model WHS Regulations.

Next Steps

Once you have all the correct labels on your hazardous chemicals and subsidiary containers, you’ll need to ensure your workplace has procedures in place to regularly audit and review HAZCHEM stores and handling areas. To learn more about how to incorporate regular site inspections and audits into your chemical risk management plan, please download our free eBook How to manage the risk of Hazardous Chemicals in the workplace.

How to manage the risk of hazardous chemicals in the workplace

Walter Ingles

Walter Ingles Compliance Specialist

Walter is STOREMASTA’s Dangerous Goods Adviser. He loves helping businesses reduce the risk that Dangerous Goods pose upon their employees, property and the environment through safe and compliant dangerous goods storage solutions.

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