Priority Existing Chemical

o.2Hazard communication

o.2.1Labels

Labels submitted for assessment were assessed for requirements under the NOHSC National Code of Practice for the Labelling of Workplace Substances (NOHSC, 1994). The assessment took the form of a qualitative appraisal of the following categories of information:

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  Substance identification;
  
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  Hazard category/Signal word;
  
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  ADG Code classification/packaging group;
  
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  Details of manufacturer or supplier;
  
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  Risk Information (or phrase);
  
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  Safety Information (or phrase);
  
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  Information on spills/leaks or fires; and
  
• 
  Reference to MSDS.
  

MMT Concentration	Risk Phrases	Classification of Mixture
 0.1% - < 1%	R20, R22	Harmful
 1% - < 3%	R23, R25, R48/20	Toxic
 3% - < 7%	R21, R23, R25, R48/20	Toxic
 7% - < 10%	R21, R26, R28, R48/20	Very Toxic
 10% - < 25%	R21, R26, R28, R48/23	Very Toxic
 25%	R24, R26, R28, R48/23	Very Toxic

• 
  S36: Wear Suitable Protective Clothing;
  
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  S38: In Case of Insufficient Ventilation Wear Suitable Respiratory Equipment.
  

Both labels available for assessment contained overseas but not local supplier contact details, the product name and disclosed the presence of MMT. However, neither contained information on ingredient proportions, either as an exact concentration or as a range.

Signal words (“Warning” and “Danger: Poison”) were found on both labels. As these products are to be used in the workplace, the signal word should be “Hazardous”. Only one label contained information on an ADG code classification/packaging group.

Neither label contained the risk phrases recommended above. One label contained a risk phrase of equivalent hazard warning for acute effects (“May be fatal if swallowed, inhaled or absorbed through skin”). However, on this label there was no risk phrase covering effects of repeated exposure. The second label contained an appropriate risk phrase for repeated exposure (“May cause CNS, blood, liver and kidney damage after prolonged or repeated exposure”), although this warning was in relation to another ingredient in the mixture.

Neither label recommended the wearing of suitable protective clothing (S36) or the wearing of suitable respiratory equipment in cases of insufficient ventilation (S38). However, both contained adequate safety phrases regarding hazards of acute contact. Both labels contained adequate first aid instructions but one label only contained advice on spills/leaks.

Aftermarket products

In the case of labelling of hazardous substances of 500 mL capacity or less and where space on the containers is especially limited, the NOHSC Labelling Code describes the required minimum information as:

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  Signal words and/or dangerous goods class;
  
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  Product name; and
  
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  Details of manufacturer or importer.
  

Signal words were obvious only on 3 labels and no labels contained the risk or safety phrases recommended above. Alternative safety phrases were present to varying extents, pertaining to avoidance of dermal and ocular exposure, aspiration hazards or prevention of child exposures. All labels included some first aid instructions varying from advice regarding ingestion to additional advice regarding dermal exposure.

o.2.2MSDS

A total of 8 MSDS, 5 for aftermarket products and 3 for imported MMT concentrates were available for assessment against the NOHSC National Code of Practice for the Preparation of Material Safety Data Sheets (NOHSC 1994b). The results of the MSDS assessment are presented in Appendix 2.

On 6 MSDS, either no statement was found as to the hazardous nature of the product or statements incorrectly claimed that the product was not hazardous (one MSDS). On 5 MSDS, an emergency telephone number was missing. Local company details were missing on one MSDS.

Key health effects of MMT were included in the MSDS, although only 3 MSDS mentioned the possibility of kidney damage. Also, the First Aid section of some MSDS advised vomiting following ingestion whereas others advised (correctly) against vomiting. On 6 MSDS, exposure standards drawn from overseas sources rather than Australian sources (in this case they are the same) and there were no plain English explanation as to what the skin notation on the exposure standard meant.

One MSDS for an MMT concentrate incorporated ingredient details for 3 different possible formulations for the product targeted at the 3 different markets of USA, Canada and Europe whilst not indicating the formulation applicable for Australia.

A sample MSDS prepared in accordance with the findings of this assessment and the NOHSC National Code of Practice for the Preparation of Material Safety Data Sheets (NOHSC 1994b) is provided in Appendix 3.

o.2.3Education and training

Refinery companies use the Ethyl Corporation HiTEC 3062 Product Handling Manual specifying storage requirements, blending procedures, handling precautions, maintenance procedures and decontamination and disposal procedures for refinery blending.