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Chemical
Management in
Malaysia
SCOPE
• Life cycle of chemical
• Legal framework
• Chemical management in the workplace
• Future of chemical management in Malaysia
• Potential career development in OSH
Management of Chemicals: From Cradle to Grave
Storage
Transport
Distribution
Use
Recycle
Production
Imports Exports
Disposal
Legal Framework
Chemical Legislation & Enforcement Agencies
Stages Agencies Relevant Legislation
IMPORT
Pesticide Pesticide Board Pesticide Act 1974
Industrial Chemicals Royal Malaysia Customs
Customs Act 1967
Drugs Ministry of Health Poison Act 1952
Food Ministry of Health Food Act 1983
PRODUCTION
Emission to air and water
Department of Environment
Environmental Quality Act 1974
Workers health and safety
Department of Occupational Safety and Health
Occupational Safety and Health Act 1994
Food Industry Ministry of Health Food Act 1983
Stages Agencies Relevant Legislation
TRANSPORT OF HAZARDOUS GOODS
By air, road, marine and rail Ministry of Transport Civil Aviation Act 1969;
Transport Act 1987
USE/HANDLING
Pesticide Pesticide Board Pesticide Act 1974
Cosmetics Ministry of Health Control of Drugs and
Cosmetics Regulation 1984
Workers health and safety Department of Occupational
Safety and Health
Occupational Safety and
Health 1994
Consumer chemicals Ministry of Domestic Trade
and Consumer Affairs
Consumer Protection Act 1999
DISPOSAL
Schedule Wastes Department of Environment Environmental Quality Act
1974;
Environmental Quality
(Schedule Wastes) Regulations 2005
CHEMICAL LEGISLATIONS AND
ENFORCEMENT AGENCIES IN MALAYSIA
CRADLE TO GRAVE – Enterprise Level
Receiving Storage Transfer
Use & Handling Disposal
• Only looks at chemicals as it enters the
place of work until it exits the place of work
Maintenance and Repair
Chemical Management at the Enterprise Level – Regulatory
Requirements
CURRENT LEGISLATION
ENFORCED BY DOSH
Law Currently Enforced
Factories and Machinery Act 1967
& 14 Regulations
Petroleum (Safety Measures) Act, 1984
Occupational Safety and Health
Act, 1994. &
7 Regulations
OCCUPATIONAL SAFETY AND HEALTH ACT, OSHA 1994
• Seven regulations and two orders
• Philosophy and guiding principal
• Responsibilities to ensure safety and health at the workplace lies to those who create the risk and on those who work with the risk
• Key features : self-regulation, consultative approach, employees participation and broad range of working population
OSH LEGISLATION APPROACH
Type of Standards Description Examples
1.Prescription Tell the duty holders precisely what preventive
measures to take and how to make a goal
FMA, 1967
2. Principle Based Tell the duties holder general duties to ensure
health and safety at work so far as is reasonably
practicable
General duties
under OSHA 1994
3. Performance Based Specify the outcome of the OSH improvements
of the desire level of the performance but leave
the concrete measures to achieve this open for
the duty holder to adapt to local circumstances
Exposure standards
of chemicals under
USECHH, 2000
4. Process Based Identify a particular process, or series of steps
to be followed in the pursuit of managing a
specific hazards, or OSH in general .
Often used when the regulator has difficulty
specifying a goal or outcome but has
confidence the risk of injury/diseases will be
reduced if particular steps are followed
CHRA
HIRARC
OSHMS
1. OSH (Control of Industrial Major Accident Hazards) Regulations 1996
2. OSH (Prohibition of Use of Substances) Order 1999
3. OSH (Use & Standard of Exposure of Chemicals Hazardous to Health) Regulations 2000
4. OSH (Classification, Labelling and Safety Data Sheet of Hazardous Chemicals) Regulations 2013
5/10/2017
CIMAH REGULATIONS,1996:
MAJOR HAZARD INSTALLATIONS
• Where large quantities
(exceeding the threshold
ua tity of desig ated che icals a e manufactured, processed,
stored or handled
5/10/2017
NON MAJOR
HAZARD
INSTALLATION
MAJOR
HAZARD
INSTALLATION
EXCLUDED
INDUSTRIAL
ACTIVITIES
TQ 10% OF TQ
QUANTITY OF HAZARDOUS
SUBSTANCE
[QHS<10% TQ] [10% TQ<QHS <TQ ] [QHS >TQ ]
REFER TO SCHEDULE 1 AND 2 FOR TYPE AND THRESHOLD
QUANTITY (TQ) OF HAZARDOUS SUBSTANCE
1 2 3
CLASSIFICATION OF INDUSTRIAL
ACTIVITIES
GENERAL REQUIREMENT
PART I - Application
PART II - Identification & Notification
PART V - Notification of Accident
PART VI - Penalty
PART IV
Safety report
On/off-site ERP
Information to
public
PART III
Demonstration
of safe operation
MHI NMHI
INDUSTRIAL ACTIVITY
CIMAH REGULATIONS 1996: SCOPE
•Nuclear
Installation
•Armed Forces
Inst.
•Transportation
•Installation with
Q<10 % TQ
EXCLUDED
1. OSH (Control of Industrial Major Accident Hazards) Regulations 1996
2. OSH (Prohibition of Use of Substances) Order 1999
3. OSH (Use & Standard of Exposure of Chemicals Hazardous to Health) Regulations 2000
4. OSH (Classification, Labelling and Safety Data Sheet of Hazardous Chemicals) Regulations 2013
5/10/2017
OSH (PROHIBITION OF USE OF
SUBSTANCE) ORDER 1999
• Order Made By The Director General Of Occupational Safety & Health – Under Section 35(1) Of The Osh Act 1994
• 10 Types Of Chemical Substances Prohibited From Certain Uses
• Prohibited due to their hazardous effects to health, such as proven carcinogens.
5/10/2017
PROHIBITED SUBSTANCES
• 4-Aminodiphenyl
• Benzidine
• 2-Napthylamine
• 4-Nitrodiphenyl and their salts & any substance containing them exceeding 0.1%
• Benzene
• Carbon disulphide
• Carbon tetrachloride
• n-Hexane
• White Phosphorus
• Crocidolite
Mercury Not Included In List Of
Prohibited Substances
1. OSH (Control of Industrial Major Accident Hazards) Regulations 1996
2. OSH (Prohibition of Use of Substances) Order 1999
3. OSH (Use & Standard of Exposure of Chemicals Hazardous to Health) Regulations 2000)
4. OSH (Classification, Labelling and Safety Data Sheet of Hazardous Chemicals) Regulations 2013
5/10/2017
INTRODUCTION TO USECHH REGULATIONS
• Made under Section 66 of OSHA 1994
• To protect safety and health of employee and
other person from being affected by chemical
hazardous to health use at the place of work
• Gazetted on 4th April 2000
• Come into force on 4th April 2001
5/10/2017
RATIONALE OF USECHH REGULATIONS
• to provide legal framework for the employer to control use of chemical hazardous to health
• to set workplace exposure standard in order to protect the health of the employees and others at the place of work
• to promote excellence in management chemicals hazardous to health
5/10/2017
USECHH: APPLICATION
• All places of work within the purview of the Occupational Safety and Health Act 1994 where chemicals hazardous to health are used
5/10/2017
USECHH: CHEMICAL HAZARDOUS TO HEALTH
• Chemicals with Permissible Exposure Limits listed in Schedule 1 – about 600 chemicals
• Define under CPL Regulations as – Very toxic, Toxic, Corrosive, Harmful,
Irritant including carcinogens,
teratogens & mutagens
• Pesticides under Pesticides Act 1974
• Scheduled wastes under Scheduled Waste Regulations 1989
Schedule 1 : USECHH, 2000
5/10/2017
USECHH: EXCLUSION FROM COMPLIANCE
Certain places of work are excluded if the chemical substances used are
• radioactive materials,
• foodstuff,
• pharmaceutical products, or
• they are hazardous to health solely by virtue of their explosive or flammable properties,
• or solely because they are at a high temperature or pressure.
5/10/2017
SALIENT PROVISIONS OF USECHH
• Identification of chemicals hazardous to health ;
• Permissible exposure limits;
• Assessment of risk to health;
• Action to control exposure;
• Labelling & Relabelling
• Information, instruction and training
Sample of chemical register
Permissible Exposure Limit
Ceiling Limit TWA 8hrs Maximum Exposure
Limit
Exposure to CHH listed in
Schedule I not exceed at
any time
Eight-hour time-weighted
average airborne
concentration
3 x TWA8hrs
Potential Risk
Method & procedure
Nature of hazard
Exposure control
procedure
Assessment Shall be reviewed if • significant change in work • more than 5 years •Directed by DG DOSH
Degree of exposure
Health risk
Accidental exposure
control procedure
Monitoring programme
Health surveillance
Training & retraining
1. Contain 2. Must be carried out by Assessor (Registered with DOSH)
3. Assessor must furnish the employer the report of assessment within one(1) month of completion of assessment
4. If result of assessment indicate likely cause immediate danger- assessor must inform employer immediately
10 STEPS CHRA
Source Path Receiver
i. Elimination
ii. Isolation
iii. Total enclosure
iv. Modification v. Substitution
i. Engineering Control i. Safety operating procedure
ii. PPE
Method of Control
Elimination
Substitution
Total Enclosure
Isolation
Modification
Engineering control
SOP
PPE
Hierarchy of Control
Most useful
Least useful
Sample of chemical exposure control Substitution
Sample of chemical exposure control Engineering Control
Fume cardboard
Local Exhaust
Ventilation
Sample of chemical exposure control Total Enclosure
Spraying booth
Sand blasting
Sample of chemical exposure control Personal Protective Equipment
5/10/2017
USECHH: SALIENT PROVISIONS (cont)
•Monitoring of the exposure at the workplace
• Health surveillance;
•Medical Removal Protection
•Warning Sign
• Record keeping
Also !
a. As per mention by the assessment of risk to health
b. If workers expose/likely to expose to CHH listed in Schedule II, monitoring interval shall be repeated in not more than 6 month
Section. 26 USECHH Reg. 2000
Airborne contains of
Dusts/Fibers
Mists
Fume
Aerosols Smoke
Vapors
Gas
Basic sampling method/principles
Collection media
Sampling pump
Cassette/ Filter
Impinger bottle
Sorbent tube
Sampling approach
Personal Sampling
Area Sampling
Health Surveillance
1. Where an assessment indicates that health surveillance is necessary for the protection of the health of employees exposed or likely to be exposed to chemicals hazardous to health
2. Consist of medical surveillance component which shall be carried out by occupational health doctor.
3. If an employee is exposed or likely to be exposed to chemicals hazardous to health listed in Schedule II, the health surveillance shall include medical surveillance conducted at intervals of not more than twelve months or at such shorter intervals as determined by the occupational health doctor or an occupational safety and health officer who is also a medical practitioner.
Medical Removal Protection
Medical Removal
Protection
OHD OSH Officer cum Medical
Practitioner
Pregnant / breastfeeding
employee
Employee is no longer has
detected medical condition
Not pregnant / breastfeeding
anymore
When exposed to CHH – increase risk of material
impairment to health
PROPOSE
Record Keeping
1. Whenever an employer ceases to carry on business and another person succeeds him, the employer ceasing business shall hand over, and the successor employer shall retain, all records to be maintained.
2. Whenever an employer ceases to carry on business and no person succeeds him, the employer shall transmit the records required to be maintained
3. At the expiration of the retention period for the records required to be maintained, the employer shall give the Director General at least three months notice in writing that he intends to dispose of such records, and he shall transmit those records to the Director General, if requested to do so within that period
5/10/2017
GUIDELINES UNDER USECHH
1. Guide on Chemical Register 2. Guidelines for the Registration of Assessor,
Hygiene Technician and Occupational Health Doctor
3. Manual on the Assessment of Health Risk Arising from the use of Chemicals Hazardous to Health (CHRA)
4. Guidelines on the Control of Chemical Hazardous to Health
5. Guidelines on Health Surveillance 6. Guidelines on the Storage of Chemical Hazardous
to Health
1. OSH (Control of Industrial Major Accident Hazards) Regulations 1996
2. OSH (Prohibition of Use of Substances) Order 1999
3. OSH (Use & Standard of Exposure of Chemicals Hazardous to Health) Regulations 2000
4. OSH (Classification, Labelling and Safety Data Sheet of Hazardous Chemicals) Regulations 2013
INTRODUCTION TO CLASS REGULATIONS
• Made under Section 66 of OSHA 1994
• To ensure chemicals hazardous to health used
in the work places have been classified and
labelled correctly, so that workers
acknowledge the hazard and know how to
handle it safely.
• Gazetted on 30 September 2013
52
HARMONISATION FOR CLASSIFICATION & LABELLING
Australia-Harmful
India-Non-toxic
Japan-Toxic
US-Toxic
Malaysia-Harmful
Thailand-Harmful
EU-Harmful
New Zealand-Hazardous
China-Not Dangerous
Korea-Toxic
Acute oral
LD50 = 257 mg/kg
GHS classification: Acute toxic (oral) Category 3 Symbol :
Part l : APPLICATION Chemicals supplied for
use at place of work
-Manufacturer
-Importer
EXEMPTION
• radioactive materials
• scheduled wastes
• drugs & cosmetics
• R & D che icals ≤ 5 kg
• manufactured items
(articles)
• pesticides & chemicals
in transit before export
except SDS
SUBSIDIARY SUPPLIER
PRINCIPAL
SUPPLIER
Formulator
Manufacturer
Importer
Recycler
Reformulator
Repacker
Distributer
Retailer
Part
ll
CLASSIFICATION
Reg.
4
Classify
chemicals:
•Physical Hazard
•Health Hazard
•Environmental
Hazard
Reg.
5
Maintain
classification record
for inspection
Part
lll
PACKAGING
Reg.
6
Safe packaging and
sealed
Reg.
7
Seal is broken &
cannot be repaired
Part
lV
LABELLING
Reg.8
6 elements of label
•product identifier
•Supplier identification
(name, add. & no. tel.)
•signal word
•hazard statement
•hazard pictogram
•precautionary
statement
Reg.
11
Dimension of label –
4th Schedule
Part
V
SAFETY DATA
SHEET (SDS)
Reg.
13
Furnish SDS-
meet cut-off
value of
concentration
(5th Schedule)
Format of SDS:
16 sections
National &
English language
Part
Vl
INVENTORY
Reg.
14
Submit to DG,
if;1 MT &
above/year for
each calendar
year and not later
than 31st March of
the following year
Hazardous
chemical
information
•product identifier
•name of
hazardous
chemical
•composition &
ingredients
•total quantity of
each hazardous
chemical
imported or
supplied
Special labelling
- s all co tai e ≤ 5 ml
product identifier
supplier identification
signal word
hazard pictogram (if applicable)
state e t ead SDS before use
Schedule Regulation Name
1st 3 Hazard Classification, Hazard Pictogram, Signal Word and Hazard Statement
2nd 3 Hazard Pictograms
3rd 8(6) Combined Hazard Statements
4th 11 Dimension of Label
5th 13 Cut-Off Value of Concentration
Part V lll : REVOCATION
CPL Regulations 997 are
revoked
SCHEDULE
Part Vll : CONFIDENTIAL
BUSINESS INFORMATION (CBI)
name
composition & ingredients
OCCUPATIONAL SAFETY AND HEALTH
(CHEMICALS CLASSIFICATION, LABELLING
AND SAFETY DATA SHEETS) REGULATIONS
2013
Responsibility of supplier – principal & subsidiary supplier
Duty to ensure every packaging of hazardous chemicals is labelled legibly and indelibly with:
√Product identifier
√Supplier identification
√Signal word
√Hazard statement
√Hazard pictogram
√Precautionary statement
55 CMD-DOSH 2014
Duty of Supplier
LABELLING
56
A label must consist of this information
a) Product identifier
b) Supplier identification
c) Signal word
d) Hazard statement
e) Hazard pictogram
f) Precautionary statement
Physical Hazard Health Hazard Environmental Hazard
Description
of symbol
Hazard
pictogram
Description
of symbol
Hazard
pictogram
Description
of symbol
Hazard
pictogram
Flame Skull and crossbones Environment
Flame over circle Exclamation mark Exclamation mark
Exploding bomb Health hazard
Gas cylinder Corrosion
Corrosion
Hazard pictograms
57
Example of Label
Formaldehyde Solution
Ingredient & Concentration: Formaldehyde (CAS. No.:50-00-0) 37%
Water 63%
HAZARD STATEMENT
Causes skin irritation
Toxic if swallowed, in contact with or if inhaled
Causes severe skin burns and eye damage
May cause an allergic skin reaction
PRECAUTIONARY STATEMENT
Keep away from heat/sparks/open flames/hot surfaces-
No smoking.
Avoid breathing vapour.
Use only outdoors or in a well-ventilated area.
Wash hands thoroughly after handling.
Obtain special instructions before use.
Do not handle until all safety precautions have been read
and understood.
Manufacturer: XYZ Co. Limited, 515 Touhy Avenue, Des Plaines, IL 60018
(Pengilang) USA. (24 hr Emergency Tel. No: 800 424-9300 )
Supplier: ABCD Kimia Sdn. Bhd., 1126 , Jalan Kg. Attap,
(Pembekal) 50534 Kuala Lumpur (Tel : 03- 273 1234, Fax:03-0000-1234, Emergency: 1-800-1234567 )
DANGER
BAHAYA
Product Identifier
Supplier Identification
Hazard Statement
Precautionary
Statement
PERNYATAAN HAZARD
Menyebabkan kerengsaan kulit
Maut jika tertelan, terkena kulit atau jika tersedut
Menyebabkan lecuran kulit dan kerosakan mata
yang teruk
Boleh menyebabkan tindak balas alahan kulit
PERNYATAAN BERJAGA-JAGA
Jauhkan dari haba/percikan api/nyalaan
terbuka/permukaan panas-Dilarang merokok.
Elakkan daripada menyedut wap.
Gunakan hanya di luar bangunan atau di dalam kawasan
yang dialihudarakan dengan baik.
Basuh tangan bersih-bersih selepas mengendalikan
bahan.
Dapatkan arahan khas sebelum menggunakan bahan.
Jangan kendalikan bahan sehingga semua langkah
berjaga-jaga keselamatan telah dibaca dan difahami.
Signal
Word
Hazard
Pictogram
Safety Data Sheet (SDS) Format Formally known as CSDS/MSDS
Contain information according to the following headings and order:
1. Identification of the hazardous chemical and supplier
2. Hazards identification
3. Composition and information of ingredients of hazardous chemical
4. First aid measures
5. Fire fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls and personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal information
14. Transportation information
15. Regulatory information
16. Other information
FUTURE CHEMICAL MANAGEMENT
IN MALAYSIA
International Obligations
• Basel Convention ( Control of trans boundary movement of hazardous waste) – ratified on 8th October 1993 – DOE Malaysia is designated as the competent authority – Export / import through Customs shall be accompanied by a permit issued by DOE
• Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous
Chemicals and Pesticides in International Trade – ratified on 4th September 2002
• Stockholm Convention on Persistent Organic Pollutants – active involvement in activities under this convention
• Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on their Destruction (Chemical Weapon Convention )
• The Minamata Convention on Mercury -designed to protect human health and the environment from anthropogenic emissions and releases of mercury and mercury compounds
• ILO s Safety in the use of che icals Convention & Recommendations
• SAICM- Emerging issues: Lead in paint, Chemical in product (CIP), Nano particle technology, Endocrine disrupting substances (EDC), E-waste, Perfluorinated chemicals
• Formation of Malaysia Chemical Agency
• Enacted of Chemical Safety Act
• Formation of National Institute of Chemical Management
• Formation of National Chemical Safety Fund
• Enhancement of chemical products security features
• More expertise in chemical management area
• Formation of national chemical registry
• More online chemical management tools
• To give more attention to chemical security
aspects of chemical plants
• Encourage local expertise to work in relevant
international organization
• To develop global chemical safety
management index (GCSI).
Example: New Security Label
Step 1: Visual Checks
• Check the color-cha gi g po tio . The o d Shell should disappea he wet and reappear when dry.
• Make sure the cap is properly sealed. You will hear a cracking sound when
you twist open the cap.
Step 2: Peel & Scratch
• Peel the top layer and scratch the silver film for the 8-character Security
Code
Step 3: SMS** TO 33228
• SMS the 8-character Security Code to 33228 in this format:
Shell<space>Security Code
• To include data on occupation in the
identification card, medical record and death
certificate
• To have national data bank in innovative
ideas and low cost solution methodology in
controlling chemical exposure and release
• To introduce extensive application of
Integrated Pest Control Management System
• Expansion of GHS in all sectors
GHS In Other Sector
CIGARATTES ALCOHIC DRINK
POTENTIAL CAREER DEVELOPMENT IN OSH
Registered OSH Practitioner with DOSH until 2011
No. Type of registration
2008 2009 2010 2011
1 Safety and Health Officer 3,428 3,804 4,148 4087
2 Major Hazard Competent Person 45 45 36 24
3 Lift Competent Person 83 100 118 106
4 Steam Engineer 1605 1766 1924 2054
5 Steam Engine Driver Grade I 2816 2972 10083 10216
6 Steam Engine Driver Grade II 6650 7071
7 Internal Combustion Engine Engineer 184 226 254 282
8 Internal Combustion Engine Driver Grade I 1304 1370 4344 4366
9 Internal Combustion Engine Driver Grade II 3758 3980
10 SIWC Trainers 251 * * *
11 Occupational Health Doctor 709 740 785 838
12 Hygiene Technician I 146 154 160 352
13 Hygiene Technician II 150 157 167
14 Authorized Gas Tester 42 64 124 320
15 Indoor Air Quality Assessor 6 11 15 19
16 Assessor 261 270 281 303
17 Competent Person (Noise Monitoring) 94 106 113 118
18 Tower Crane / Passenger Hoisting Machine / Goods
Hoisting Machine / Gondola 86 68 73 56
19 Scaffold Erector 3682 4699 5716 6109
20 Crane Operator 8274 10589 12626 14866
TOTAL 34 024 38 192 43 010 44 116
Note: * Not monitored by DOSH starting from Year 2010
TERTIARY EDUCATION
Public University Private University Collaboration public/private
Universiti
Kebangsaan
Malaysia
Universiti
Putra
Malaysia
Universiti
Teknologi
Malaysia
Universiti
Malaysia
Pahang
Universiti
Teknologi
Mara
Universiti
Malaya
Masterskills
MAHSA University
College
Kolej Islam Sains &
Teknologi
Universiti Industri
Selangor
University of
Nottingham, Malaysia
Consist College
Victoria International
College
Kolej Dar Al-Hikmah
Ronaco Marine Sdn
Bhd
Open University
Malaysia
KLIAC / UTM
NIOSH / UUM
NIOSH / OUM
OSH Courses in Public & Private Institutions
NEW POTENTIAL AREA
• Train person for SiRAC online
• Chemical classifier for CLASS Regulation,
• SDS translator for CLASS Regulation
CA1- General Ventilation
CA2- Engineering Control
CA3- Containment
CA4- Special
SiRAC 2011
(Simple Risk Assessment Control for Chemicals)
2. APPLICATION
•Does NOT apply to the following types of chemicals:
1. Not listed in chemical register
2. Chemical classified as :
- carcinogenicity category 1;
- mutagenicity category 1 or 2; or
- respiratory sensitization category 1.
3. Process generated dusts and fumes
4. Organic dust
5. Gases
6. Scheduled waste (1st schedule in EQR 2005)
Only covers routes of entry:
-Inhalation
-Skin absorption
3. WHO CAN CONDUCT?
Anyone who has knowledge on :
1. How to interpret SDS
2. Work processes and tasks
3. Basic principles of HIRARC
4. Basic requirement of OSHA,
USECHH and relevant guidelines.
5. Has been trained on SiRAC.
6. Has knowledge on the Simple
Risk Assessment and Control for
Chemicals (SiRAC) manual.
4.
ASSESSMENT
STEPS
1.INTRODUCTION
• To help the employer to carry out a simple
assessment on the use of chemicals
hazardous to health at the workplace
• To meet duties under USECHH.
Solid- level of
dustiness
- Use Table 3.4
5. Selection of control approach- Use Table 3.6
6. Selection of task specific control
guidance sheet - Use Table 3.8
2. Identify chemical
Liquid- to decide
volatility
- Use Table 3.5a or
3.5b or Figure 3.1
6. Select control guidance sheets (CGS) (P100,
P101, P102, P103, P104, P105, P106) - Use
Table 3.9
4. Scale of use - Use Table 3.3
1. Gather Information
Get Hazard Group-Use
Table 3.1 and Table 3.2
3. Get R-Phrase or H-Code
8. Report Writing & Record
Keeping
No Yes Pesticides?
Form SA1
•Chemical register
* SDS- BP,VP, Risk phrase
* Label
*Task and work process
* Existing control measures
Small
Medium
Large
Low
Medium
High
Low
Medium
High
Suitability
Practically
•Content assessment based on Reg. 11(4)
USECHH Reg.
•Document keep in hard or soft copies
•SiRAC record should be maintained at
least 30 years
Hazard group
A
B
C
D
S
R / H 17≥0.1% but <0.5%
Frequency & Duration Adjustments= Threshold
of 15-minute use per day is applied.
Rules for mixtures= volatility should relate to
the major component(s) of the mixture.
Use Table 3.7
Form SA 2i
o
FOR DOSH INTERNAL USE ONLY
7. Develop and implement action plan
BPK 2013
Form SA 2ii
Form SA 3
CONCLUSIONS
• OSHA a d it s Regulatio s ha i g ade uate ge e al provisions for managing chemicals in the workplace.
• ICOP & Guidelines are require to supplement general
provisions stated in the Act and Regulations.
• Malaysia government is in the process of further
strengthening the chemical management system in the
country in order to improve safety, health, environment,
security in this aspect and meet very demanding
international obligations.
74