Malaysia consults on amendments to the Industry Code of Practices

On 6 September 2023, the Malaysian Department of Occupational Safety and Health (DOSH) published its proposed amendments to the Industry Code of Practices of Chemicals Classification and Hazard Communication (ICOP), Parts 2 and 3. The consultation on the proposed amendments is open until 10 November 2023. The eighth revised edition of the UN’s Globally Harmonized System (GHS) for Classification and Labelling of chemicals served as a building block for the development of these changes.

ICOP Regulation

In order to comply with the Occupational Safety and Health (Classification, Labelling and Safety Data Sheet of Hazardous Chemicals) Regulations 2013 (CLASS Regulations), the Industry Code of Practices of Chemicals Classification and Hazard Communication, 2014 (ICOP) is a legally binding document that must be followed. Generally speaking, the CLASS Regulations provides guidance on chemical classification and hazard communication, as well as a list of chemical substances that have been officially classified.

The following four Parts along with an Appendix create the ICOP:

Part 1: Classified Chemicals List

Part 2: Chemical classification

Part 3: Hazard Communication, labelling and SDS,

Part 4: Confidential Business Information (CBI)

Amendments to Part 2 (Classification of Chemicals) of ICOP

In Part 2 of the ICOP, the main amendments to the hazard classes in terms of definitions and classification methods are as follows:

• Physical Hazards: Explosives/Flammable gases/Flammable liquids/Flammable solids/Oxidizing gases/Oxidizing solids/Gases under pressure/Self-reactive substances/Substances which in contact with water emit flammable gases/Organic peroxides/Substances corrosive to metal
• Environmental Hazards: Hazardous to the aquatic environment/Hazardous to the ozone layer
• Health Hazards: Acute toxicity/Skin corrosion or irritation/Serious eye damage or eye irritation/Respiratory sensitization/Skin sensitization/Germ cell mutagenicity/Carcinogenicity/Reproductive toxicity/Specific target organ toxicity (single exposure)/Specific target organ toxicity (repeat exposure)/Aspiration toxicity

Amendments to Part 3 (Hazard communication) of ICOP

In addition to amendments related to labelling, the guidance for the creation of Safety Data Sheets (SDS) has been amended. Some of the changes are as follows:

• Section 1: The following paragraph was added: The product identifier used for the chemical shall match with the product identifier used on the label (3.7.1.1.4)
• Section 4:  Guidance on first-aid measures was added.
• Section 6: Advice related to suitable fabric for personal protective clothing was added (3.7.6.1.2).
• Section 8:  Guidance on air monitoring procedures was added (3.7.8.1.1). ‘Exposure monitoring’ has been modified to ‘air monitoring’.
• Section 9:  Advice on the properties that should be included and the appropriate units of measure and/or reference conditions was added.
• Section 11:  Guidance on hazard information to be provided was corrected
• Section 14: Guidance on bulk transport was added

Amendments to the ICOP Appendix

In addition, with regard to Parts 2 and 3, the Appendix was also amended as follows:

• Appendix 2.2 Guidance on classification of carcinogenicity.
• Appendix 2.3 Example of Classification Record
• H315 + H320 (causes skin and eye irritation) were removed from Appendix 3.1 (List of hazards).
• Appendix 3.2 (List of Precautionary statements) several entries were deleted, replaced or amended, and new entries were added.
• Appendix 3.3 has been replaced by instructions for choosing precautionary statements for labelling.
• Appendix 3.4: Label elements for each hazard class
• Appendix 3.5: Examples of label element arrangements