Frequently Asked Questions (FAQ) on the Globally Harmonised System of Classification and Labelling of Chemicals (GHS)

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1 Frequently Asked Questions (FAQ) on the Globally Harmonised System of Classification and Labelling of Chemicals (GHS) No. CATEGORY QUESTION ANSWER 1* Compliance The main objective of GHS is to have a single harmonised system worldwide. However the implementation timeframe and standards differs for some countries. The Globally Harmonized System of Classification and Labelling of Chemicals or GHS is an internationally agreed-upon system created by the United Nations. It is designed to replace the various classification and labelling standards used in different countries by using consistent criteria for classification and labelling on a global level. The adoption of the GHS is expected to facilitate international trade by increasing consistency between the laws in different countries that currently have different hazard communication requirements. There is no set international implementation schedule for the GHS. Different countries will require different time frames to update current regulations or implement new ones. 2 Compliance Is GHS classification & labelling of chemicals mandatory in Singapore? GHS hazard communication is developed by the United Nations which encourages member states to adopt for safeguarding persons against hazardous chemicals. Singapore has adopted the GHS and under the WSH (General Provisions) Regulations which are administered by MOM, chemical suppliers must provide SDS for their hazardous chemical products, and any occupier of a workplace must label the containers of hazardous substances. The law has recently been amended by making reference to SS 586 on GHS. SS 586 has also been gazetted as an Approved Code of Practice under the WSH Act. Page 1

2 What is the GHS implementation timeline in Singapore? The GHS implementation timeline in Singapore is as follows: Manufacturers/Suppliers Single Substances All hazardous substances except ozone depleting substances, chemically unstable gases, aerosols, sensitisers (based on GHS purple book Rev 2) Timeline Feb Compliance Ozone depleting substances, chemically unstable gases, aerosols, sensitisers (based on GHS purple book Rev 4) 1 Jul 2015 Mixtures 1 Jul 2015 Users Timeline Single Substances All hazardous substances except ozone depleting substances, chemically unstable gases, aerosols, sensitisers (based on GHS purple book Rev 2) Ozone depleting substances, chemically unstable gases, aerosols, sensitisers (based on GHS purple book Rev 4) End Jul 2015 Mixtures 1 Jul 2016 Page 2

3 4 Compliance Why is the GHS transition period for single substances different from that for mixtures? Single substances are easier to classify compared to mixtures. Furthermore, data and information on hazard classification, labelling and SDS for most single substances are readily available in the public domain. Therefore, a shorter timeline is given for GHS implementation. Mixtures are composed of different substances. They are often complex and therefore a longer time timeline is needed for hazard classification and SDS preparation. 5 Compliance Who is responsible for complying with GHS when a chemical is imported into, exported out or traded in Singapore? Anyone (including importer, exporter, trader or company) responsible for or involved in the importation, trading or marketing of chemicals in Singapore is expected to comply with the local requirements of GHS. The same applies when exporting chemicals to a country which has implemented the GHS. Further to the above, Users of chemicals must also comply with the relevant requirements of the GHS under their respective country s local regulations. 6 Compliance GHS has been implemented in many countries but at different timelines. If I import chemicals from countries which have yet to implement GHS, I will not be able to comply with the GHS requirements in respect of labelling and SDS for the chemicals imported. What should I do in order to meet the local GHS implementation timeline? Importers of hazardous chemicals must ascertain that the chemicals imported are provided with GHS labels and SDS. Any local importer importing hazardous chemicals without GHS labels and SDS has to re-label the product package and prepare the SDS in accordance with the GHS format if the chemicals are to be sold or marketed in Singapore. It would therefore be more cost-effective and less troublesome for local importers to import chemicals from overseas suppliers who are able to provide GHS labels and SDS for their products. Page 3

4 7 Compliance 8 Compliance 9 Compliance 10 Compliance Page 4 Beyond 1 Jul 2015 would suppliers be allowed to deliver products with non- GHS labels which had been manufactured prior to 1 Jul 2015 or would re-labelling be absolutely necessary? Does Singapore adopt High or Low thresholds for GHS classification purpose? We had delivered some chemicals to our customers a few years ago and some of these chemicals (single substances) did not have a GHS label at that time. Will it be the company s responsibility when our customers who requested GHS labels from us for those bottles, pasted them onto the wrong chemical bottles? Is there anything we need to ask our customer to take care of when using these GHS labels? My company imports products from other countries to Singapore for re-export The timeline for mixtures will remain as 1 Jul The packages/containers are to be re-labelled before supplying to customers. For packages which cannot be re-labelled due to the conditions required for re-labelling, please ensure that the changes in SDS and label content are communicated to the downstream users. Generally Singapore has adopted the higher (i.e. less stringent) generic concentration limit, consistent with key trading partner countries adoptions. However, there is this Hazard Class whereby if a STOT Category 1, is present at 1-10%, the mixture will be classified as Category 2. The UN allows countries to decide if it will be a CAT 2, or NOT. Singapore has decided on CAT 2 (i.e. more stringent in this case). The labels provided to the customers should be the correct labels for the chemicals which they have requested. The customers who are the users of the chemicals will have to check that the labels which they are replacing should tally with the labels affixed to the original containers. In this scenario, there is no requirement to affix Singapore GHS-compliant label to each container given that the companies have to ensure that the DG (Dangerous Goods) labels and/or origin countries GHS compliant label is affixed to the drum and consignments.

5 11 Compliance 12 Compliance purpose. They will be stored in the warehouse until the time for re-export to a destination country. There are DG labels and/or GHS labels of the origin countries on the products. Does my company need to apply Singapore GHS-compliant label on the products when stored in the Singapore warehouse? My company manufactures chemical products in our own plant, which are stored in the warehouse until the time for export to a destination country. Does my company need to apply Singapore GHS-compliant label on the products when stored in the warehouse? How do we comply with GHS requirements if SS586 is going to be revised once every 2 years or at the same frequency as the UN GHS revision? Companies, whether subscribing to third party warehouses and/or using own warehouses, must ensure they have the necessary licences from relevant government agencies (i.e. Hazardous Substances under NEA; Petroleum & Flammable Materials under SCDF and explosives & explosive precursors under SPF) before storing the chemicals in the warehouse. (Please also refer to Q10.) Yes, for chemicals manufactured in Singapore for export purpose, company may use reduced workplace GHS label (which indicates chemical name and GHS pictograms) at the storage area or on the pallet. The reduced workplace label should be visible to the workers at storage warehouses. All export and re-export chemical packages should be labelled in accordance with export country s regulatory requirement. It is a usual practice for the UN documentation (standards or codes) to be revised from time to time so as to remain relevant. However, the amendments are usually refinements or additions in nature rather than making fundamental changes to the original GHS document (Purple Book). Therefore, the amendments or changes will not be expected to affect most of the existing chemicals that have already been classified. The national GHS Task Force (which coordinates the implementation of GHS in Singapore) takes into consideration the local context and consults relevant stakeholders when reviewing or updating the SS 586 to align with the UN GHS Purple Book. Page 5

6 13 Compliance 14 Compliance 15 Compliance 16 Definition Page 6 Different countries will have their own requirements on the building blocks adopted, how then is GHS harmonised? Is any chemical exempted from GHS labelling and SDS? Is there any official language specified for GHS label? Are multi-languages labels permissible? Is there any difference between the physical hazards as determined by GHS and UNTDG? The GHS document provides countries with the flexibility to adopt building blocks which meet their respective domestic requirements. Although there may be differences in categories adopted by different countries, the overall key information such as labelling elements; pictograms, signal words, hazard and precautionary statements are harmonized. GHS does not exempt any chemical substances/mixtures, except for the following:- those classified as non-hazardous by GHS hazard classification those which do not contain any hazardous ingredients above the SDS cut-off limits as guided by SS586 Part 3 Table 1 traces of food additives or pesticides in food * pharmaceutical products (at the point of human intake or ingestion) * cosmetics (at the point of intentional application) * veterinary products intended for application to animals * Note:- (*) These products will not be covered in terms of labelling at the point of intentional intake but will be covered where workers are exposed in the workplace and in transport. There is no official language stipulated in the GHS requirements for labelling. When exporting to any country, you would have to comply with the local requirements (which may cover language) as set by that particular country. In Singapore, English is a business language used for SDS and labels. Under the WSH (General Provisions) Regulations, it is mandatory to have warning labels in languages understood by all persons at work, depending on the demographic of the workforce. Pictograms serve as a tool to guide and train workers. Translation of GHS pictograms in several languages can be obtained from the following website: There is generally no difference as part of harmonisation, the GHS and UNTDG testing requirements / rules on physical hazards and the end points have been aligned. In the 14th edition of the UN Recommendation on the Transport of Dangerous Goods (UNTDG, the Orange Book), the classification and labelling of DG have been harmonized with GHS to a

7 17 Definition What is Singapore s definition of bulk versus packaged tanks? large extent. Different regulators have different definitions. See summary table below. Competent Authority tank DG GHS SEIP TEIP SCDF Bulk >250 L NEA Bulk >450 L SCDF Package <250 L NEA Package <450 L 18 Definition What is the difference between a single substance and a mixture? A single substance is a chemical element or its compound in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurities deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition. A mixture means a mixture or a solution composed of two or more substances in which they do not react. 19 SS SS 586 Page 7 When will the SS 586 be an Approved Code of Practices (ACOP)? There are some similarities in the requirements for labelling in SS 532 on storage of flammable liquids and SS 586 Part 1. What should be SS 586 has already been gazetted as an Approved Code of Practice (ACOP) under the Workplace Safety and Health (Approved Codes of Practice) Notification 2011, effective on 15 Feb SS 532 for the storage of flammable liquids provides technical requirements for safe storage of flammable liquids in fixed bulk installations and in packages. The definition of flammable liquids is according to the GHS flammable liquids; and in additional liquids with flash point more than 93 degree C and up to including 150 degree C are to comply with the requirements of category 4. It recommends the use of hazard labelling such as symbol, pictogram, signal word, hazard

8 the requirements for storage of chemicals? and precautionary statements of GHS flammable liquids. SS 586 Part 1 for hazard communication for hazardous chemicals and dangerous goods provides guidelines on labelling requirements for transport and storage of dangerous goods. It is based on the UN Recommendations for transportation of dangerous goods, and it provides comprehensive information for the emergency responders, workers and public on the associated physical risks of the chemicals being transported or stored. 21 SS 586 I have a warehouse of chemicals and at the entrance I have displayed all the warning notices complying to SS 508 and with this new SS 586 part 1 on SEIP my entrance will be flooded with warning signs. How I can manage the signs to comply with both SS such that people are not confused? SS 508 is the requirement for factories on warning notices to warn or remind the target audience (workers at work) of possible dangers such as high voltage, wear protective clothing, certain nature of hazard etc. SS 586 Part 1 targets emergency responders and people who may not aware of the presence of physical hazards arising from the hazardous chemicals stored inside the premises. Thus, there is minimum repetition between SS 508 and SS 586. For chemical warehouse where diverse range of hazardous chemicals are kept, only UNTDG label is required at the entrance, not SEIP. SEIP is more for out-door storage such as bulk tank farm or drums store, where single hazardous chemicals are kept at one place. 22 Safety Data Sheet What is the difference between SDS (Safety Data Sheet) and MSDS (Material Safety Data Sheet)? There is no difference. The use of this title varies from country to country. For the purpose of harmonisation internationally, the UN Sub-Committee of Expert on the GHS Classification and Labelling has standardised it to Safety Data Sheet (SDS). Singapore has adopted this. 23 Safety Data Sheet Do traders need to prepare and create their own SDS or can they use the copy from the company? This would depend on whether the trader is selling on behalf of the company which could use the trademark / logo, etc. In this case, they could use the supplier SDS. If the trader is to sell and market the product under its own brand name and company, the trader would need to create its own version of the SDS including contact details and emergency response contact number. Page 8

9 24 Safety Data Sheet Whenever there are changes in the contents of the SDS, is it necessary to highlight these changes in the new / revised SDS? No, there is no legal requirement for the changes to be highlighted. It should be the responsibility of the manufacturer to issue a new or revised SDS whenever there are changes in properties or contents of the chemical. 25 Safety Data Sheet Must a new SDS be issued when a chemical is diluted (e.g. a 99% concentrated alcohol is diluted to 70% concentration)? No. The SDS of the original/pure chemical can be used if there are no other chemicals present. In addition to the SDS, additional information related to the revised diluted concentration should also be provided. 26 Labelling Storage of chemicals in drums, do we need a GHS label for each drum? In general, all hazardous chemical storage drums need to be labelled in accordance with SS 586 i.e. the drums must be affixed with a GHS label. If the drums are to be transported by an open vehicle to another location, additional UNTDG label is required on the drums. Please refer to SS 586: Part 1 and SS 586:Part 2 - Section 6.3 (Reduced Workplace labelling) for details. 27 Labelling Is there a size requirement for the pictogram to be used on the label under GHS standards? Currently there is no size requirement for the pictogram but there is a minimum size dimension for GHS labels which can be found in the Singapore Standard SS 586 Part Labelling Can we combine the transport and workplace product label to just one label? Yes, they can be combined under GHS labelling. Please refer to SS 586 Part 1 for the size requirement on transport label and Part 2 for the label elements to be stated. Page 9

10 29 Labelling 30 Labelling Can a GHS label be printed on a coloured paper/background? If the label could not fit all hazards/pictograms, is it possible to leave out some? Under GHS, pictograms prescribed should have a black symbol on a white background with a red frame sufficiently wide to be clearly visible (black border is acceptable if the product is not for export) regardless of the colour or background of the paper used. Please refer to SS 586 Part 2 for details. There can be a maximum of four pictograms on the label and all hazard statements are to be included. 31 Labelling 32 Labelling 33** Miscellaneous Can a blank diamond space pictogram with red (or black) border be printed on the label? Is there a requirement for vacuum pumps or POU abatement that may deliver or contain hazardous chemicals be labelled with GHS chemical labels? Are there available databases to assist in classification and labelling? The use of a blank diamond space pictogram with a red (or black border) or any other related combinations on a printed label is currently being reviewed by the United Nations GHS Subcommittee. In view of this pending decision on the issue by the UN Sub-committee, for the interim, the use of existing pictograms as currently practised by the industries is acceptable in Singapore. However, exporters must check on the local requirements of the other countries if the product is to be exported or for use in that respective country. GHS label is only required for a chemical that is classified as hazardous under the GHS classification criteria. It also applies to packed-in containers (e.g. drums, pals and bottles or small containers). This is not for equipment or tanks. Refer to the GHS guideline (SS 586) for more details. There are numerous databases listing substances and their classifications and resulting label elements in the internet. Some of these are country specific and offered by the competent authority e.g. Korea and Japan. Notwithstanding the availability of these databases, a company will need to review and carry out its own assessment based on the chemical and component details to determine the hazard classification of the chemical substance. It is also recommended that the company maintains Page 10

11 34 *** Miscellaneous 35 Miscellaneous Is GHS labeling required for consumer products which contain hazardous substances? What is the relation between HS Code in Trade Net and GHS? proper house-keeping records of the classification process for future references, particularly so when the classification process has to be reviewed due to changes in the GHS criteria. Generally in most countries, consumer packages (purchased off the retail shelf in supermarkets and stores) which contain hazardous substances do not have to be GHS labelled. However, in some countries e.g. Japan, they do provide GHS labels on consumer packages/products such as soap and detergent. This practice is however voluntary. HS Code is used for the identification of products (including chemicals) in Singapore s Trade Net for custom clearance. It is for Import/Tariff Tax which in principle has no relation to GHS. 36 Miscellaneous 37 Miscellaneous If I do the classification for the chemicals, would my classification be challenged? Is there a course for mixtures classification? Regulatory authorities or agencies have the right to know or challenge the classification especially if there is any query or complaint from an end-user. Hence, it is advisable to keep and make available all the records and data on how the hazardous chemicals are classified. Please contact the Singapore Chemical Industry Council (SCIC) by Tel , secretariat@scic.sg or visit SCIC website at for more information. 38 Miscellaneous Where can a copy of the Singapore Standard SS 586 be obtained? To purchase Singapore Standards, please go to The full collection of Singapore Standards may be viewed at SPRING s reception area (1 Fusionopolis Walk, #01-02 South Tower, Solaris, Singapore ), as well as the Lee Kong Chian Reference Library (National Library Building, 100 Victoria Street, #07-01, Singapore ). Notes SS 508: 2004 Part 3 Graphical symbols Safety colours and safety signs use at workplace and public areas SS 532: 2007 Code of practice for the storage of flammable liquids (formerly CP 40: 1987) SS 586: 2014 Specification for hazard communication for hazardous chemicals and dangerous goods Part 1: Transport and storage of dangerous goods Part 2: Globally harmonised system of classification and labelling of chemicals - Singapore's adaptations Page 11

12 SS 586: 2008 Specification for hazard communication for hazardous chemicals and dangerous goods Part 3: Preparation of safety data sheets (SDS) Page 12

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