Labelling and safety data sheets
- What is an SDS?
- What are the duties in relation to the preparation of SDS?
- Access to SDS
- Reviewing and amending a SDS
- Labelling of hazardous chemical containers
- What is on the label?
- When is labelling not required?
An SDS (previously called a material safety data sheet) is a document containing important information about a hazardous chemical (which may be a hazardous substance and/or dangerous good) and must:
- be in English
- contain unit measures expressed in Australian legal units of measurement
- state the date it was last reviewed (must be at least once every five years), or if it has not been reviewed, the date it was prepared
- state the name, Australian address and business telephone number of the manufacturer or importer
- state an Australian business telephone number from which information about the
- chemical can be obtained in an emergency.
An SDS for a hazardous chemicals must also state the following information about the chemical (refer to the Work Health and Safety Regulation 2011 (PDF, 2.53 MB) - Schedule 7):
- Section 1 - Identification: Product identifier and chemical identity
- Section 2 - Hazard(s) identification
- Section 3 - Composition and information on ingredients, in accordance with Schedule 8
- Section 4 - First-aid measures
- Section 5 - Fire-fighting measures
- Section 6 - Accidental release measures
- Section 7 - Handling and storage, including how the chemical may be safely used
- Section 8 - Exposure controls and personal protection
- Section 9 - Physical and chemical properties
- Section 10 - Stability and reactivity
- Section 11 - Toxicological information
- Section 12 - Ecological information
- Section 13 - Disposal considerations
- Section 14 - Transport information
- Section 15 - Regulatory information
- Section 16 - Any other relevant information.
The format and content for a hazardous chemical product SDS is set out in the Preparation of Safety Data Sheets for Hazardous Chemicals Code of Practice 2011 (PDF, 710 kB).
An SDS is an important information source for eliminating or minimising the risks associated with the use of hazardous chemicals in workplaces.
Manufacturers and importers of hazardous chemicals have duties under the WHS Regulation (Section 330) to provide current information about the hazardous chemical in the form of an SDS.
A manufacturer and importer of a hazardous chemical must:
- prepare an SDS for the hazardous chemical before first manufacturing or importing the hazardous chemical or if that is not practicable, as soon as practicable after first manufacturing or importing the hazardous chemical
- review the SDS at least once every five years and amend whenever necessary to ensure it contains correct current information.
Under section 339, a supplier must provide the current SDS to any person, if the person is likely to be affected by the chemical or asks for the SDS.
A person conducting a business or undertaking may change an SDS for a hazardous chemical only if the person is an importer or manufacturer and:
- changes the SDS in a way that is consistent with the duties of the importer or manufacturer, or
- the change is to attach a translation of the SDS and clearly states that the translation is not part of the original SDS.
Note: A person who packages or relabels a hazardous chemical with their own product name is considered to be a manufacturer and therefore has the same obligations as a manufacturer or importer under the WHS Regulations to prepare an SDS.
Access to an SDS can be provided to workers in the work area in several ways:
- paper copy collections of SDS
- computerised and internet-based SDS databases.
When a workplace adopts a computerised or internet-based SDS database, ensure that the relevant workers have ready access to the information in the work area. Ensure workers have the necessary computer skills to login and access the SDS when required. Also consider how this information can be accessed in an emergency situation if the power is isolated.
The WHS Regulation provides for an exemption for having to obtain and give access to an SDS when:
- hazardous chemicals are in transit
- the PCBU is a retailer and the hazardous chemical is a consumer product and intended for supply and not intended to be opened on the premises
- the hazardous chemical product is a consumer product used in quantities and a manner which is consistent with household use.
In these circumstances, the PCBU must ensure sufficient information about the safe use, handling and storage is readily accessible to a worker, emergency service worker or anyone else likely to be exposed to the hazardous chemical at the workplace (refer to Regulation 344).
The register of an SDS is required under section 346 and should be used as an information tool to make sure everyone is involved in managing hazardous chemicals exposure at the workplace. A register is a list of the hazardous chemical products and the current SDS for each of those products that is readily accessible to a worker and anyone else who is likely to be affected by the hazardous chemical.
An SDS should be reviewed whenever there is:
- a change in formulation that:
- affects the hazardous properties of the substance
- alters the form, appearance or mode of application of the substance
- a change to the hazardous chemical which alters its health and/or safety hazard or risk
- new health and/or safety information on the hazardous substance such as exposure standard changes or a substance previously considered not harmful is now established to be harmful (e.g. carcinogenic)
- at least every five years from date of original preparation or last revision.
It is not necessary to review the SDS if the manufacturer or importer has not manufactured or imported the chemical in the last five years. An SDS should still be available after the hazardous chemical is withdrawn from sale as it may be required by workplaces at a later date.
For an overseas SDS, it is acceptable to have a translation of the SDS attached to the original SDS, provided the appended information clearly states the translation is not part of the original SDS. The original SDS is the SDS prepared in accordance with the WHS Regulation. If an overseas manufacturer's SDS does not comply with the requirements of the WHS Regulation, the importer is responsible for preparing an SDS that does comply.
Manufacturers, importers, suppliers, and PCBUs have specific labelling duties in relation to the correct labelling of workplace hazardous chemicals. Refer to sections 335, 338 and 342 of the WHS Regulation.
The format and content for a hazardous chemical product label is set out in the Labelling of Workplace Hazardous Chemicals published by Safe Work Australia.
The label must be in English and contain the following:
- name of the product
- the name, Australian address and business telephone number of either the manufacturer or importer
- identity and proportion disclosed, in accordance with Schedule 8 of the WHS Regulations for each chemical ingredient
- any hazard pictogram(s), hazard statement(s), signal word and precautionary statement(s)
- any information about the hazards, first aid, and emergency procedures relevant to the chemical, which are not otherwise included in the above
- the expiry date of the chemical, if applicable.
If the manufacturer has amended an SDS, the label should be changed to ensure that it is consistent with the information in the amended SDS.
The WHS Regulations (Schedule 9) include special provisions for specific circumstances including:
- small containers
- research chemicals or samples for analysis
- decanted or transferred hazardous chemicals
- hazardous chemicals with known hazards that are not supplied to another workplace
- hazardous waste products
- hazardous chemicals classified in the explosive hazard class
- hazardous chemicals that are dangerous goods packaged for transport and in transit
- consumer products
- agricultural or veterinary chemical products
- products containing nanomaterials.
Further information on what a label is required to include for those specific circumstances described above are included in the Labelling of Workplace Hazardous Chemicals Code of Practice 2011 (PDF, 931 kB).
There are several types of hazardous chemicals that are excluded from the labelling provisions or exempted from coverage from all provisions in Part 7.1 of the WHS Regulation.
Dual use products
Some hazardous chemicals may be intended for supply to both the consumer household markets and workplaces in identical containers and packaging. These products are sometimes referred to as dual use products. A dual use product label need only comply with the Standard for the Uniform Scheduling of Medicines and Poisons (SUSMP) labelling requirements. If the manufacturer or importer determines that the use handling and storage of the product are predominantly related to a work activity, the label must meet WHS requirements.
Food and beverages
Food and beverage products that are packaged in a form intended for consumption do not require labelling under the WHS Regulation. However, large or bulk quantities must be labelled to meet workplace requirements. For example, a 1000 L container of flammable alcoholic spirits must be labelled to meet WHS requirements, while a 750 mL consumer bottle of the same spirits does not.
Therapeutic goods are regarded as correctly labelled under the WHS Regulation when labelled in accordance with Therapeutic Goods Administration (TGA) requirements and in a form:
- intended for intake or administration to or by a patient or consumer, or
- intended for use for therapeutic purposes.
When not in a form intended for intake or administration to or by a patient or consumer, or for therapeutic purposes, workplace labelling must be used.
For example, a pharmacist repacks a 1 kg container of formulated tablets in smaller containers for dispensing to patients. The 1 kg container must comply with TGA labelling requirements. However, a 1 kg container of the same material in powdered form used by a pharmacist in manufacturing or formulating products must be labelled according to workplace labelling requirements.