The Globally Harmonised System (GHS) is now in full swing in NSW, QLD, NT, SA and TAS after the states transitioned, 1st January 2017. The new system has meant big changes to the classification, labelling and communicating of hazardous products.
Agar has carefully examined the classification standard, and re-assessed all of its products. Accordingly, the majority of its commercial cleaning products are now classified as hazardous whereas previously only about 50 percent were. This has left businesses and cleaners alike confused about the risks associated with using cleaning chemicals and their responsibilities in becoming GHS compliant. To assist customers in understanding the new GHS system, Agar has put together some frequently asked questions to clarify uncertainty and outline what actions they need to take to be GHS compliant.
Good to know:
- If the cleaning products available at the supermarkets were sold in bulk containers for commercial use, they too would be covered by the GHS and would be mostly classified as hazardous.
- The GHS includes mild hazards not previously recorded under past systems, such as the irritation to skin which can occur after prolonged contact with a detergent.
- The hazards labelled on bottles are for the concentrated product, the diluted solution is often much milder, and in some cases not hazardous at all.
- The risks of using hazardous products can greatly be avoided through correct handling, following safety procedures and wearing personal protective equipment such as gloves and glasses, which the majority of cleaners already do.
- Product risk assessments, available in the member’s area of the Agar website, are a great resource for understanding how to manage the risks of using cleaning chemicals.
What is the GHS?
The Globally Harmonised System (GHS) is an international system designed to unify the classification and communication of chemical hazards throughout the world. It uses new hazard assessment criteria to classify chemicals as either hazardous or non-hazardous. The GHS uses signal words, pictograms, hazard statements and precautionary statements to communicate the risks of hazardous products. The GHS system only applies to products sold for use in the workplace.
What states are using the GHS?
- NSW, QLD, NT, SA and TAS
- VIC is expected to convert 1/7/2017
- WA permits the use of GHS and/or the old system at this time
When is the GHS effective?
- 1st January 2017 – NSW, QLD, NT, SA and TAS
- 1st July 2017 – VIC (proposed date – yet to be confirmed)
- WA and ACT – no date has been announced
How does the GHS affect my business?
If you are operating in the states which have implemented the GHS (NSW, QLD, NT, SA and TAS) you will need to ensure that your business is GHS compliant. To be GHS compliant you must ensure:
- All cleaning chemicals onsite have current GHS Safety Data Sheets (SDS’s). Agar’s can be found here http://agar.com.au/sds/
- All new cleaning chemicals purchased, that are manufactured after 1/1/2017, have GHS labels.
- All new decanting containers manufactured and labelled after 1/1/2017 must have GHS compliant labels. Screen printed bottles, purchased or manufactured before 1/1/2017, can continue to be sold and used after this date.
- While not a requirement for GHS compliance, customers that keep product risk assessments on site for hazardous chemicals will need to obtain them for the newly classified hazardous products. These can be found in the member’s area of Agar’s website http://agar.com.au/member-area/ – note you must login to the Agar site to access this page.
How do I tell if a product is GHS compliant?
Only hazardous products are required to carry the new GHS labels and have GHS SDS’s. To identify if the product is hazardous and GHS compliant you will need to look out for the following things on the label and SDS:
- Signal Word (either WARNING or DANGER)
- Hazard Statements such as: ‘May be harmful if swallowed’ or ‘Causes skin irritation’.
- Pictogram (not all hazardous products are required to have a pictogram depending on the severity of the hazard).
These items will be found on both product labels and SDS’s as shown below:
The format of Agar’s SDS’s has changed with GHS. This is an easy way to tell if you have the updated SDS, however it is always best to look for the signal word, pictogram and hazard statements found under Section 2 on the first page.
Are products more hazardous now that they are classified under GHS?
No, the product formulations have remained the same, it’s the hazardous classification that has changed. The products are no more dangerous or harmful than before the GHS. Under the GHS, risks that were not previously recognised are now being classified as a hazard. An example of this would be Agar’s hair and bodywash detergent, Ambergold. Under the previous system Ambergold was not classified as hazardous, however under the GHS it is. GHS recognises that getting the shampoo in your eyes or leaving the concentrated product on your skin for an extended period of time would cause irritation and as such it is labelled as a hazard.
How can I tell the severity of the risk?
There are a few ways to identify the severity of the hazard for a chemical.
- The signal word used: DANGER denotes a higher risk than WARNING.
- Hazard statements. These go up in severity from mild to severe: ‘Causes mild skin irritation’, ‘Causes skin irritation’, ‘Causes severe skin burns and eye damage’.
- Pictograms: The ‘Harmful’ pictogram communicates a milder hazard than ‘Corrosive’ or ‘Health Hazard’.
The pictograms present on the label communicate the most severe warning from the product. A corrosive symbol on a label does not necessarily mean that the product will burn the skin, rather it might be there to highlight the possible effects that the concentrated product could have if it was to come in direct contact with the eyes. It is also important to note that this doesn’t necessarily mean that the product will definitely cause reactions such as severe eye damage, rather that it is a possible risk.
Agar’s manual dishwashing liquid Lift is a good example of this. It carries the corrosive pictogram to communicate that the concentrated product may cause serious eye damage, however that does not mean that it will have the same effects on the skin. Unlike strong acids that can potentially burn the skin, Lift might cause irritation to the skin after prolonged contact with the undiluted product.
It is important to note that these hazards are often easily neutralised through using the chemicals correctly and wearing personal protective equipment (PPE). The hazards listed on the product label are for the concentrated product, not the diluted version which will generally have a much milder risk or no recorded risk at all.
Is it safe to use hazardous products?
Yes, hazardous products are still safe to use however, like all cleaning products, they must be handled with care, especially the concentrated products directly from the bottles. Always follow the instructions and safety guidelines, use the correct PPE and read the SDS before use.
The GHS provides an opportunity to re-think our attitude to all chemicals. Whilst they’re an important ‘tool’ for our cleaning tasks, they need to be treated with respect and we need to be aware of any risks they pose, including minor risks such as skin irritation.
Can I still use the old products I have that don’t have GHS labels?
Yes, you can continue to store and use products manufactured and purchased prior to 1/1/2017 that do not have GHS labels. You will need to get an updated GHS SDS for them however http://agar.com.au/sds/.
What if someone tries to sell me a product that does not have a GHS label?
Safe Work Australia released a statement in November 2016 outlining that suppliers could continue to sell products without GHS labels that were manufactured before 1/1/2017. This was to reduce the workload on manufacturers and suppliers so that they didn’t have to relabel products already labelled under the old system.
If the product has a manufacturing date after 1/1/2017, is classified as hazardous under GHS and your workplace is in the GHS compliant states of NSW, QLD, NT, SA and TAS and it is NOT carrying a GHS label then do NOT purchase it. It is your business’s responsibility to ensure that it is GHS compliant and as such, your business’s responsibility to ensure that it only purchases GHS compliant products.
A pH neutral product I thought was safe now has a corrosive pictogram on it. Is it still safe to use?
In the past the ‘Corrosive 8’ symbol was used exclusively with Dangerous Goods products and was generally reserved for chemicals such as strong acids that could cause severe burns to the skin. A similar symbol is now also used to communicate corrosive products under the GHS and appears on some pH neutral products that have been newly classified as hazardous, causing some alarm and confusion.
The GHS corrosive pictogram is used to communicate the effects a product may have on the skin, eyes and surfaces. In the case of pH neutral cleaning products, the effect on the skin may be mild and for surfaces it might be nil, but it could potentially damage the eyes if the concentrated product were to come into contact with them. It is important to remember that the GHS uses a very conservative approach to classifying risks. These neutral products will not cause severe burns to the skin on contact and are still safe to use. Care should be taken during dilution and safety glasses should be worn to ensure that the product doesn’t get into the eyes. As you can expect, most people already do this.
Does GHS mean changes for Dangerous Goods freight?
No, the Dangerous Goods Act remains the same and is still used for storage, handling and transport. The Dangerous Goods symbols used on some of Agar’s products can be seen below.
If a product is classified as hazardous under GHS, is it then considered to be Dangerous Goods?
No, Hazardous refers to a product’s effects on health and the environment while Dangerous Goods focuses on immediate danger that a substance presents during storage, handling and transport. Both systems are in operation together.
If a product has the signal word ‘DANGER’ on it, does that mean that it is classified as Dangerous Goods?
No, the signal word ‘DANGER’ corresponds with the GHS hazardous classification and labelling, NOT Dangerous Goods. A product that is classified as Dangerous Goods will have a Dangerous Goods diamond (pictured above) on the label.
Should I stop using a product which was previously non-hazardous but is now classified as hazardous under GHS?
No, the product and any inherent danger has not changed. The GHS now provides a framework for recognising minor risks which were previously not considered or ignored. You may wish to introduce additional PPE or modify procedures, based on the outcome of your risk assessment.
Please contact your Agar Distributor or Representative if you have any questions about the GHS labels.