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On 29 January 2021 Safe Work Australia (SWA) released a webinar presentation about Australia’s two-year transition from the third to the seventh revision of the United Nation's Globally Harmonized System of Classification and Labeling of Chemicals (GHS) that began 1 January 2021.
Verisk 3E Review
The 15-minute presentation captures a summary of key changes in Australia’s move from GHS 3 to GHS 7 as further detailed on the SWA information page. The two-year transition to GHS 7 implementation commenced in Australia on 1 January 2021 and will end on 31 December 2022. The implementation timeline was postponed for six months from the initially intended date (1 July 2020), but a special arrangement was put in place for those who already started to comply with GHS 7 ahead of the final transitional period. Compliance with GHS 3 classification is allowed during the transitional period, but from 1 January 2023, chemicals manufactured or imported must be classified, labeled, and have standard data sheets (SDS) prepared in accordance with GHS 7. To date, many works have been put in place to help industries comply with GHS 7 requirements.
These works include the update of these chemical workplace laws:
- Model Work Health and Safety Regulations (as of 1 January 2021)
- Model Code of Practice: Labeling of Workplace Hazardous Chemicals (28 August 2020)
- Model Code of Practice: Preparation of Safety Data Sheets for Hazardous Chemicals (28 August 2020)
Mostly, the transition from GHS 3 to GHS 7 will affect the hazard classification and communication of those who import and manufacture chemicals classified in the following ways:
Per GHS 7, the "flammable aerosol" hazard class is being renamed to "aerosol" with the new hazard category, i.e., "non-flammable aerosols (Category 3)" added. This means "all aerosol dispensers will now be captured in the aerosol hazard class and will meet the definition of hazardous chemicals under the Model Work Health and Safety (WHS) laws." And, "Any chemicals that have been previously classified as a gas under pressure should now be classified as non-flammable aerosol." The same goes for flammable aerosols as they should no longer be classified as flammable gas, flammable liquid, or flammable solid.
Flammable, Pyrophoric, and Chemically Unstable Gases
Per GHS 7, flammable gases are now divided into two categories:
- Flammable Gas Category 1A is subdivided into three categories: pyrophoric gas, chemically unstable gas A, and chemically unstable gas B
- Flammable Gas Category 1B consists of gases that meet the flammability criteria for Category 1A but are not pyrophoric nor chemically unstable
Flammable gas Category 2 is being excluded from the definition of hazardous chemicals under the WHS regulations.
A new hazard class and categories (1-4) are being added per GHS 7. Chemicals that were previously classified with other classes (e.g., flammable solid, oxidizing solid) may be affected by this change and in need of reclassification.
With the transition to GHS 7, the definition of “hazardous chemical” under the model WHS laws is being clarified to ensure it captures all Category 2 eye irritants, including those that fall under Category 2B. By the end of the transitional period (from 1 January 2023), "all Category 2 eye irritants should be treated as hazardous chemicals and have corrected label and SDS in accordance to GHS 7."
In addition, any new precautionary statements introduced under GHS 7 (e.g., P 212 and P 364), may need to be added to SDS and labels. Precautionary statements under GHS 3 will still be accepted as long as the changes between GHS 3 and GHS 7 are "not significantly different."
Additional information can be found from SWA's transition to GHS 7.
Verisk 3E Analysis
Obligations related to hazardous chemicals in Australia are laid down in Chapter 7, part 7.1 of the Model Work Health and Safety Regulations. Manufacturers and importers of hazardous chemicals should begin to review their classifications for these chemicals as well as update SDS and labels to ensure that they meet the criteria of GHS 7. Compliance with GHS 7 may be different in some Australian states.