What date are chemical manufacturers required to have updated all hazardous chemical labels?

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Responsibility for labelling
Reviewing labels
Chemical classification
Commencement of GHS 7 transitional period

A label is the written, printed or graphical information concerning a hazardous chemical that is affixed to, printed on, or attached to the container or pipe work of a hazardous chemical. Labels must clearly identify the chemical and include information on its hazards, plus instructions and information on its safe storage, handling, use and disposal.

The label must be written in English and should be large enough to contain all of the relevant hazard and other information in a size and style that is easily visible. Labels should be appropriate to the size of the container. The label must be attached to the outside of the container and should be visible in the normal storage position. The information and any symbols on the label should be printed in a colour or colours that provide a distinct contrast to the background colour.

You can find further information on chemical labelling requirements on the Safe Work Australia website or you can call our Help Centre on 1300 365 255.

Responsibility for labelling

A PCBU must correctly label any hazardous chemical used, handled or stored at the workplace. Most hazardous chemicals purchased from a manufacturer or supplier and still in their original container should already be correctly labelled. Correct labelling is also required for all hazardous chemical manufactured at the workplace or transferred or decanted from its original container at the workplace.

Labels of workplace hazardous chemicals do not need to be formally approved to meet work health and safety requirements.

Reviewing labels

Labels must be reviewed periodically in order to ensure they are up-to-date e.g. when there is a change in the formulation or ingredients that changes the hazardous properties of the chemical, or when new information on the hazards of the product or any of its ingredients becomes available.

When the classification of a hazardous chemical changes the label must be reviewed and, if necessary, revised to reflect any changes.

Importers, manufacturers and suppliers should review any new or significant information regarding 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, but at least every five years.

If you operate a business that uses hazardous chemicals you should refer to the Labelling of workplace hazardous chemicals - Code of Practice.

Chemical classification

Chemical classification and hazard communication on labels and Safety Data Sheets (SDS) is based on the Globally Harmonised System of Classification and Labelling of Chemicals (GHS).

The GHS is a single internationally agreed system of chemical classification and hazard communication through labelling and SDS. The GHS is published by the United Nations and includes harmonised criteria for the classification of physical hazards, health hazards and environmental hazards.

All Australian states and territories have agreed to adopt the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Revision 7 under the model WHS laws for workplace hazardous chemicals. Some hazardous chemicals are excluded from the labelling provisions of the WHS Regulations and therefore the Code does not apply to those chemicals.

For modifications to the requirements of the GHS, refer to Schedule 6 of the WHS Regulations.

Commencement of GHS 7 transitional period

Australia officially entered the transition period from GHS 3 to GHS 7 on 1 January 2021. The transition period is for two years and will end on 31 December 2022. See the Safe Work Australia website for details and resources on the transition.

SafeWork SA has amended the Work Health and Safety Regulations 2012 (SA) to give effect to this transition and update references to the GHS.

Amendment to the WHS Regulations

Regulation	Explanation of amendment(s)
5 - definition of GHS	This amendment changes the definition of GHS, to remove the words “third revised edition” and replace them with “seventh revised edition”. The seventh revised edition of the GHS (GHS 7) was published by the United Nations in July 2017. The definition of GHS in regulation 5 refers to the GHS 7 published by the United Nations as modified under Schedule 6 to the WHS Regulations.
5 - definitions	This amendment adds the definition of GHS 3 to regulation 5
5 - definition of hazardous chemical	This amendment changes the definition of hazardous chemical to clarify that a substance, mixture or article will be a hazardous chemical if it satisfies the criteria for any one or more hazard classes in the GHS (including those referred to in Schedule 6 to the WHS Regulations), but it will not be a hazardous chemical under the WHS Regulations if the only hazard class or classes for which it satisfies the criteria are one or more of the listed hazard classes. This amendment also removes “serious eye damage/eye irritation – category 2B” from the definition of hazardous chemical on the basis that Australia, as a general rule, does not require sub-categorisation of hazard classes. Should manufacturers and importers have sufficient data available, sub-categorisation into categories 2A and 2B can be undertaken but is not mandatory.
338 - Supplier labelling hazardous chemicals	This amendment changes regulation 338, by adding in sub-regulation 338(2). Sub-regulation 338(2) provides that sub-regulation 338(1) does not apply where the hazardous chemical was manufactured or imported before 1 January 2023 and was, at the time it was manufactured or imported, labelled in accordance with GHS 3. This item enables suppliers to on-sell GHS 3 labelled stock already in the supply chain. Existing labels may be used until stock runs out and end users are able to use existing labelled stock indefinitely.
341(2) – Labelling hazardous chemicals – general requirement	This amendment removes the existing sub-regulation 341(2) and replaces it with a new sub-regulation which provides that sub-regulation 341(1) does not apply to a hazardous chemical that was: manufactured before 1 January 2017 and is labelled in accordance with NOHSC: 2012 (1994) as in force at the time it was manufactured; or in the case of an imported hazardous chemical – imported before 1 January 2017 and is labelled in accordance with NOHSC: 2012 (1994) as in force at the time it was imported; or manufactured or imported before 1 January 2023 and was, at the time it was manufactured or imported, labelled in accordance with GHS 3. This sub-regulation enables persons conducting a business or undertaking (PCBUs) to use, handle or store a hazardous chemical that was manufactured or, in the case of an imported hazardous chemical, imported provided that the chemical meets the labelling requirements at the time it was manufactured or imported.
342 (1A) – Labelling hazardous chemicals – containers	This amendment deletes existing sub-regulation 342(1A) and replaces it with a new sub-regulation which provides that sub-regulation 342(1) does not apply to a hazardous chemical: manufactured at the workplace, or transferred or decanted from its original container at the workplace, before 1 January 2017 that was, at the time it was manufactured, or transferred or decanted from its original container, labelled in accordance with NOHSC: 2012 (1994), or manufactured at the workplace before 1 January 2023 that was, at the time it was manufactured, labelled in accordance with GHS 3, or transferred or decanted from its original decanter at the workplace that was – (i) manufactured or imported before 1 January 2023 and ii) at the time it was manufactured or imported, labelled in accordance with GHS 3. This sub-regulation means that a PCBU does not need to relabel a hazardous chemical that was manufactured at the workplace, or transferred or decanted from its original container at the workplace provided that it was correctly labelled in accordance with the labelling requirements that applied at the time of manufacture, transfer or decanting (as applicable).
342 (2A) – Labelling hazardous chemicals – containers	This amendment deletes sub-regulation 342(2A) and replaces it with a new sub-regulation that provides sub-regulation 342(2) does not apply to a container that contains a hazardous chemical: that stores a hazardous chemical manufactured or, in the case of an imported hazardous chemical, imported before 1 January 2017 if the container is labelled in accordance with NOHSC: 2012 (1994) as in force at the time it was manufactured or imported; manufactured or imported before 1 January 2023 that was, at the time it was manufactured or imported, labelled in accordance with GHS 3. This sub-regulation means that a PCBU does not need to relabel a container that stores a hazardous chemical manufactured or, in the case of an imported hazardous chemical, imported provided that the container meets the labelling requirements at the time it was manufactured or imported.
Schedule 6 – Classification of mixtures	These amendments update the page references included in the notes to Tables 6.1 – 6.5 in Schedule 6 to ensure that they are consistent with the GHS 7. Table 6.1 replaces Table 3.4.5 in the GHS (p 159) and GHS 3 (151). Table 6.2 replaces Table 3.6.1 in the GHS (p 174) and GHS 3 (p 166). Table 6.3 replaces Table 3.7.1 in the GHS (p 187) and GHS 3 (p 180). Table 6.4 replaces Table 3.8.2 in the GHS (p 197) and GHS 3 (p 192). Table 6.5 replaces Table 3.9.3 in the GHS (p 207) and GHS 3 (p 203).
Schedule 7 – Safety data sheets	These amendments omit phrases from the text of clause 1 of Schedule 7 as they are inconsistent with the text of GHS 7. omits the phrase “: product identifier and chemical identity” from clause 1(2)(a) of Schedule 7. omits the phrase “, including how the chemical may be safely used” from clause 1(2)(g) of Schedule 7
Schedule 8 – Disclosure of ingredients in safety data sheet	Consistent with the amendment to the definition of hazardous chemical in regulation 5, these items remove the sub-categorisation for serious eye damage/eye irritation from item 13 of Table 8.1 in clause 2 and from item 3 of Table 8.2 in clause 3 of Schedule 8.
Schedule 11 – Placard and manifest quantities	This amendment omits existing Table 11.1 in Schedule 11 and replaces it with a new table. The new table amends item 1, column 3 to make clear that there are two sub-categories of ‘Flammable gases,’ consistent with the GHS 7 – that is ‘Flammable gases – Category 1A’ and ‘Flammable gases – Category 1B.’ The placard and manifest quantities for Category 1A or Category 1B or any combination of these are 200L and 5000L respectively. The new table also includes ‘Aerosols’ as a new hazard class, consistent with the GHS 7 classifications. Aerosols were previously included with ‘Gases under pressure.’ This means there are now three categories of aerosols at items 43 of Table 11.1 to Schedule 11. The placard and manifest quantity for each of these categories or any combination of these are 5000L and 10,000L respectively.