National Industrial Chemicals Notification and Assessment Scheme

Summary

The majority of labels contained safety phrases S23 and S37, the signal word POISON, ingredient disclosure and statement of strength, UN Number, and ADG goods class label. One of the labels had the wrong ADG class label, 6.1(a), and two had no class label. No labels contained risk phrase R36 or R38, and most did not contain risk phrase R40, safety phrase S36, emergency procedures, or reference to the MSDS. Two labels did not have any first aid instructions.

The majority of labels contained safety phrase S23 and disclosed the presence of trichloroethylene in the mixture, but did not disclose the proportion of trichloroethylene present. Few contained risk phrases R36, R38 or R40, safety phrase S36/37, emergency procedure instructions, or reference to the MSDS. Less than half contained the signal word POISON. In addition, only 16 gave an Australian supplier’s name. First aid instructions relating to ingestion (phrases ‘c’, ‘d’ and ‘e’) were present on less than half of the labels. Five labels, however, contained the SUSDP first aid statement ‘b’ “If swallowed and if more than 15 minutes from a hospital induce vomiting, preferably using Ipecac Syrup APF”. This phrase is contrary to that recommended by the SUSDP for trichloroethylene, and an analysis of the other ingredients in these four mixtures against SUSDP requirements did not appear to justify the over-ruling of phrase ‘a’.

Three of the labels provided were for products available to the public and should be labelled according to SUSDP requirements. The SUSDP requires that where the concentration of trichloroethylene in a product is 71.5 g/L or 71.5g/kg or more, the product should display the following safety directions and warning statement:

SD1 Avoid contact with eyes

SD4 Avoid contact with skin

SD5 Wear protective gloves when mixing or using

SD8 Avoid breathing dust (or) vapour (or) spray mist

SD9 Use only in well ventilated area

WS12 Vapour is harmful to health on prolonged exposure

Some other elements required to be present on labels for all products containing trichloroethylene (regardless of strength) are: the approved name ‘trichloroethylene’ and a statement of the quantity or strength; the signal words and phrases POISON; NOT TO BE TAKEN; KEEP OUT OF REACH OF CHILDREN; the name of the manufacture or distributor or the brand name or trade name used exclusively by the manufacturer or distributor. The three labels were checked for compliance with these requirements. Labels were also checked for the presence of first aid instructions recommended by the SUSDP for substances containing trichloroethylene. The results are presented in Table 35.

Requirements prior to this assessment	Label 1	Label 2	Label 3
SD1	No	No	No
SD4	No	No	No
SD5	No	Equivalent	Equivalent
SD8	No	Equivalent	Equivalent
SD9	No	No	No
WS12	No	No	No
Approved name	No	Yes	Yes
Statement of strength	No	No	No
POISON	No	No	No
NOT TO BE TAKEN	No	No	No
KEEP OUT OF REACH OF CHILDREN	Yes	No	No
Name of manufacturer/distributor or brand/trade name	Yes	No	No
First Aid Instructions a. If poisoning occurs, contact a doctor or Poisons Information Centre. c. If swallowed, do NOT induce vomiting. Give a glass of water. d. Avoid giving milk or oils. e. Avoid giving alcohol. f. If skin contact occurs, remove contaminated clothing and wash skin thoroughly. g. Remove from contaminated area. Apply artificial respiration if not breathing. s. If in eyes, hold eyes open, flood with water for at least 15 minutes and see a doctor.	Yes No No No No No No No	Equivalent No No No No No No No	Equivalent No No No No No No No