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GHS and CLASS

As enforcement agency, DOSH in collaboration with other government agencies and NGO such as CICM, NIOSH, FMM and MITI have started to conduct training activities and promotion related to GHS and CLASS Regulations since 2004. After the enactment of CLASS Regulations, DOSH and FMM have been conducting promotion activities around the country. In principles, activities related to OSH training including chemicals classification is under NIOSH’s job scope. As for now, DOSH welcomes other NGO/ training provider who are willing to collaborate with the Department to conduct training regarding CLASS including classification.

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It is allowed, as long as the meaning does not deviate from the original documents. It is the duty of the suppliers to ensure appropriate translation of SDS from English to the National Language. CLASS Regulations does not require translations to be made by certified translators. DOSH is not providing any translation services. However, common terms and phrases such as hazard classification, hazard statement, precautionary statements and SDS headings are available in both languages in the Regulations and ICOP CHC. This can facilitate translation process by the suppliers.

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No, DOSH is only responsible for enforcing the CLASS Regulations 2013 involving supplied for use at place of work only. For consumer’s sector it is under the responsibility of Ministry of Trade, Cooperative and Consumerism. However, consumer products used in workplaces shall comply with CLASS Regulations.

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The main difference regarding the responsibility of the chemical supplier between CPL Regulations 1997 and CLASS Regulations 2013 is the duty of preparing chemicals inventory by the suppliers categorised as importer and/or manufacturer.

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All products supplied or manufactured to the Malaysian customer would need to be CLASS compliant by 16th April 2015. We have given one year thorough preparation period to the industry to comply with CLASS Regulations and no further extension has been given by the higher management.

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CLASS Regulations apply to raw materials and additives in manufacturing of food product if they are not exempted from CLASS Regulations

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Forwarding company is not categorized as a supplier; therefore responsibility under CLASS Regulations is not applicable. However, responsibility under USECHH Regulations is applicable since the chemicals in transit warehouse are under the responsibility of the company.

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Yes

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Classification record must follow given format in Part 2, Industrial Code of Practice.

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For imported products, the responsibility lies to the importer. The importer is responsible to provide the label complying with CLASS Regulations when the product entering the place of work. Only a period of thorough preparation is given to suppliers.

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To get more information about the chemicals classification method, you can refer to:

i. Industry Codes of Practice on Chemical Classification and Hazard Communication (ICOP CHC);

ii. The Globally Harmonized System of Classification and Labelling of Chemicals 3rd Revised Edition (GHS Purple Book)

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Storage tank – need label according to CLASS Regulations
Pipe line and tanker – no labeling needed according to CLASS Regulations

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Maximum allowable precautionary statements on the label are 6 unless necessary to reflect the nature and severity of hazard.

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Yes, but additional information is not considered in calculation of label size.

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Each of the pictogram must be 1/15 of the surface of the label but must not be less than 100mm2. Surface of the label considered is the surface containing information as specified in subregulation 8 (1) & (2)

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There is no standard format that have been fixed but all the information as specified in subregulation 8 (1) & (2) must be included.

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Based on the provision CLASS Regulations 2013, label is not restricted to be use bright color, but the pictograms must have white background.

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After discussing with the committee and going through the reports from UNECE, the Department has decided that the empty pictogram is not acceptable for usage in Malaysia. We would like to avoid any confusion regarding the meaning of the blank/blacked out/No GHS Symbol pictogram among the user of the hazardous chemicals.

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Yes, that would be acceptable. Just ensure that the size of the pictograms are as per stated in the regulations.

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Precautionary statements that shall be used must be as stated in ICOP CHC (Appendix 3.2).

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