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Appendix 14


appendix 14

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appendix 15 page 5


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Appendix 15





Introduction

Label Assessment

Under the National Code of Practice for the Labelling of Workplace Substances (NOHSC, 1994a), hazardous substances in containers of greater than 500 mL(g) capacity require the presence of a list of items. Smaller containers require less detail, but need to draw the attention of persons handling or using the substance to the significant hazards involved.


This assessment examined the following core elements:


    • Signal word(s);




    • Product name;




    • The recognised chemical name of the hazardous ingredient and details of the amount present in the product;




    • Risk and safety phrases (refer to the Hazardous Substances Information System (DEWR, 2004));




    • First aid procedures;




    • Emergency procedures;







  • A reference to the MSDS.

Formaldehyde is defined as a dangerous good within the ADG Code and is scheduled (Schedule 6) by the SUSDP. The appropriate signal word for formaldehyde is “POISON” for products containing > 5% formaldehyde.


The appropriate risk and safety phrases for labelling mixtures containing formaldehyde are determined by the concentration cut-off levels of the hazardous substance (DEWR, 2004). In some cases labels gave a range for the concentration of formaldehyde, for example 1% to 5%. It was assumed that the concentration of formaldehyde was the highest in the range specified.
As for MSDS, information supplied on a label for mixtures should be relevant to the mixture as a whole, not its individual constituents, and the information may differ depending on what ingredients are present and in what proportions. A full assessment of labels for mixtures cannot be carried out because an assessment of each ingredient has not been made. If any items of the core elements could not be assessed, its presence or absence was simply noted.
As for MSDS, labels were randomly selected for assessment. However, due to smaller number of labels available, more than one label from the same company were selected. Therefore, the label assessment was not as representative as it could have been as companies tended to repeat the same errors in all their labels.
Table A15-1 shows the number of labels provided to NICNAS in the course of this assessment, and the number selected and assessed against the Labelling Code.


Table A15-1: Number and type of labels received and assessed


Label Type

Number Received

Number Assessed

Formalin

21

8

Formaldehyde products


68

10

Formaldehyde containing resins


76

10

Paraformaldehyde


10

Not assessed

Paraformaldehyde products


nil

Not assessed

Assessment of labels for paraformaldehyde and paraformaldehyde products were not undertaken as the chemical is not listed in the Hazardous Substances Information System (DEWR, 2004).


Results of assessment of labels for formalin
All labels (8) examined were for containers of greater than 500 ml.
One label contained no signal word. All included chemical identification, proportion of formaldehyde, UN Number and company contact details. Five labels included all risk phrases. One label had R10 which was not necessary and another omitted R40 and R43.
Five labels provided all relevant safety phrases. One label only gave safety phrases S1/2 and another provided the wrong safety phrases apart from S1/2.
First aid statements were completely addressed in three and partially in four labels. One label did not include any information on first aid. Emergency procedures were not addressed in two labels and another two labels advised to dial 000. A reference to MSDS was not given in two labels.

Results of assessment of labels for formaldehyde products

Pack size was provided on six out of ten labels assessed. Two were for approximately 20 litres and the remainder were for packs in excess of 25 kg.


The signal word “POISON” was given in only three labels. The Labelling Code requires that where a hazardous substance is not defined as a dangerous good and is not scheduled by the SUSDP, the word “HAZARDOUS” should be used. Of the labels giving “POISON”, only one had a potential concentration of formaldehyde of greater than 5%. The other two gave concentrations of formaldehyde of less than 0.8% and less than 0.25%. These would require the signal word “HAZARDOUS”. The labels which did not give a signal word had formaldehyde concentrations ranging from less than 1% to up to 48%, hence, would have required a signal word, either “HAZARDOUS” or “POISON”.
The UN Number was not required on nine labels and was not provided on the one which required it. Most labels gave full company contact details.
Safety phrases were provided on nine labels, but only six addressed all risk phrases. Three gave no risk phrases and one omitted irritation to the respiratory system.
First aid procedures for swallowing were provided in only two labels, but most addressed first aid following inhalation, skin and eye contact. A reference to an MSDS was not given in three labels. Two labels covered emergency procedures, with the remainder giving no information.

Results of assessment of labels for formaldehyde containing resins

Pack size was in excess of 25 kg in seven labels and not provided in other three of the ten labels examined.


The correct signal word “HAZARDOUS” was given on eight of the labels examined.
All labels either provided a statement that no UN Number was allocated or gave a UN Number which may have applied to entities other than formaldehyde or been a generic UN Number.
Product name and proportion of chemicals were provided on all labels. All labels gave full company contact details.
Safety phrases were provided on nine labels, and all labels fully addressed the required risk phrases.
First aid procedures were not well covered. Four labels gave advice on procedures following inhalation, three following swallowing, seven after eye contact and six after skin contact. Two labels advised that vomiting be induced after oral ingestion. A reference to an MSDS was given in all labels. Emergency procedures were detailed on six labels, with the remainder giving no information.



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