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Brunei's Safety, Health and Environment National Authority (SHENA) has issued guidance on managing hazardous substances throughout their lifecycle in the workplace, including labelling, safety data sheets (SDSs) and exposure control.
Issued on 30 September, the non-statutory guidance uses the seventh revised edition of the UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS Rev 7) as the baseline for hazard classification and communication. It does not create or replace obligations under Brunei's Workplace Safety and Health Act (WSHA) or subsidiary regulations.
The note, Managing General Hazardous Substances in a Workplace, combines existing legal duties with SHENA's recommended measures. It uses "shall" to indicate a legal requirement and "should" for a recommendation. Workplaces may adopt alternative measures, provided they comply with legal requirements and provide an equivalent level of protection.
The guidance covers the selection, transport, storage, handling, use and disposal of hazardous substances, as well as registers, emergency preparedness, exposure monitoring and health surveillance.
It applies primarily to the 17 classes of "general hazardous substances" listed in Schedule 5 of the WSHA as:
- corrosive, flammable, oxidising, pyrophoric, self-heating and self-reactive substances;
- explosives, gases under pressure and organic peroxides;
- substances that emit flammable gases on contact with water; and
- toxic substances, mutagens, carcinogens, teratogens (reproductive toxicity), sensitisers, irritants and substances hazardous to the aquatic environment.
It also covers "specific hazardous substances" listed separately under the WHSA if their SDSs show that they fall within one or more of the 17 classes. Where specific hazardous substances exceed the quantity thresholds set by the Workplace Safety and Health (Facilities) (Control of Major Accident Hazard) Regulations, those regulations also apply.
GHS warning labels
Regulation 42 of the Workplace Safety and Health (General Provisions) Regulations requires occupiers to ensure that containers of hazardous substances bear appropriate warning labels that reflect their hazards.
The note says GHS labels should typically include six elements: a product identifier, supplier identification, hazard pictograms, a signal word ("danger" or "warning"), hazard statements and precautionary statements. Labels should be clearly visible and legible, in a language workers understand, and replaced if damaged or outdated.
Decanted substances should be clearly identified and their hazards communicated. A reduced label may be used on containers for immediate or temporary use, such as beakers or buckets kept under a worker's direct control, provided the substance is readily identifiable and the user knows its hazards. Appropriate warning labels should be applied if decanted substances are stored, moved around the workplace or left unattended.
Five-year SDS reviews
Under Regulation 43(1), occupiers must obtain an SDS for any hazardous substance used, handled or stored. They must assess its information it contains, take appropriate precautions and make the SDS readily available to workers who may be exposed.
The note adds that SDSs should be reviewed at least every five years and sooner if new information on hazards, controls or safe handling becomes available. They should be revised where necessary.
Suppliers selling hazardous substances for workplace use must provide buyers with an SDS containing accurate and adequate information. The SDS must conform to Brunei's SDS standard or to other standards, codes of practice or guidance issued or approved by SHENA. The note lists the 16 SDS sections required by the GHS.
Before introducing a substance into the workplace, occupiers should review its SDS and consider whether it can be eliminated. If this is not practicable, they should consider a less hazardous substitute or process.
Hazardous substance registers
SHENA recommends that workplaces storing or handling hazardous substances keep an up-to-date register and inventory with entries covering:
- chemical and common names;
- CAS numbers, where available;
- supplier or manufacturer details;
- quantities stored or used, and storage locations;
- hazard classifications;
- SDS issue dates and references; and
- the date of entry and the person responsible.
Registers should be updated when quantities, locations or hazard classifications change. They should be readily accessible to workers who may be exposed and to staff involved in emergency response or risk management.
Exposure limits and monitoring
Exposure monitoring should be carried out by a competent person when risk assessments indicate that workers may be exposed to toxic substances at levels that could harm their health or safety.
Occupiers must ensure that workers are not exposed to levels above the permissible exposure limits (PELs) set out in Schedule 1 of the General Provisions Regulations. Long-term PELs apply over an eight-hour working day and a 40-hour week, while short-term PELs apply over any 15-minute period in a working day.
To control exposures above PELs, Regulation 39(2) requires work to be carried out in isolated areas, in closed systems or in wet conditions, with adequate ventilation and local exhaust ventilation.
The General Provisions Regulations do not apply to hazardous substances in consumer packages intended for retail sale and use in households or offices.
SHENA has developed a self-assessment checklist, available via a QR code in the note, to help workplaces identify areas for improvement.