Priority Existing Chemical



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o.2Hazard communication

o.2.1Labels


Labels for six aftermarket MMT products containing up to 10% w/w MMT, one MMT concentrate imported in bulk in isotainers and one MMT concentrate imported in drums both containing approximately 60% w/w MMT were available for assessment. A label for an additional imported drummed MMT concentrate was not available. Labelling for this product consisted of an attached MSDS.

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:



  • Substance identification;

  • Hazard category/Signal word;

  • ADG Code classification/packaging group;

  • Details of manufacturer or supplier;

  • Risk Information (or phrase);

  • Safety Information (or phrase);

  • Information on spills/leaks or fires; and

  • Reference to MSDS.

In accordance with the hazard classification of MMT against the current version of the NOHSC Approved Criteria for Classifying Hazardous Substances (NOHSC 1999a) (Section 13), MMT is classified as a Hazardous Substance. Depending on the concentration of MMT, labels for products containing MMT should contain the following hazard classification, risk and safety phrases:

Classification of mixtures containing MMT

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

The most appropriate safety phrases are:

  • S36: Wear Suitable Protective Clothing;

  • S38: In Case of Insufficient Ventilation Wear Suitable Respiratory Equipment.

Additional risk and safety phrases may also be applicable in products depending on the presence of other hazardous ingredients.

MMT concentrates

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:



  • Signal words and/or dangerous goods class;

  • Product name; and

  • Details of manufacturer or importer.

All labels for the present aftermarket products of 350 or 500 mL capacity contained local supplier contact details and the product name. However, despite MMT being above the cut-off of 0.1% in all products for classification as a hazardous ingredient, only two labels disclosed the presence of MMT and none contained information on the concentration of MMT present, either as an exact concentration or as a range.

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


Material Safety Data Sheets (MSDS) are the primary source of information for workers involved in the handling of chemicals. Under the NOHSC National Model Regulations for the Control of Workplace Hazardous Substances (NOHSC 1994c) and the corresponding State and Territory legislation, suppliers of a hazardous chemical for use at work are obliged to provide a current MSDS to their customers and employers must ensure that an MSDS is readily accessible to employees with potential for exposure to the chemical.

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


Guidelines for the induction and training of workers exposed to hazardous substances are provided in the NOHSC National Model Regulations for the Control of Workplace Hazardous Substances (NOHSC 1994c). Under these regulations, employers are obliged to provide training and education to workers handling hazardous substances. These regulations stipulate that training and induction should be appropriate for the workers concerned.

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.




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