Frequently Asked Questions (FAQ) on the Globally Harmonised System of Classification and Labelling of Chemicals (GHS) - 2014

No.

1*

CATEGORY

QUESTION

Compliance

The main objective of

GHS is to have a single
harmonised system
worldwide. However the
implementation timeframe and standards
differs for some
countries.

Compliance

Final Draft_11 Sep 2014

Page 1

Is GHS classification &

labelling of chemicals
mandatory in
Singapore?

ANSWER

The Globally Harmonized System of Classification and Labelling of Chemicals or GHS is an

internationally agreed-upon system created by the United Nations. It is designed to replace
the various classification and labelling standards used in different countries by using
consistent criteria for classification and labelling on a global level.
The adoption of the GHS is expected to facilitate international trade by increasing consistency
between the laws in different countries that currently have different hazard communication
requirements. There is no set international implementation schedule for the GHS. Different
countries will require different time frames to update current regulations or implement new
ones.

GHS hazard communication is developed by the United Nations which encourages member
states to adopt for safeguarding persons against hazardous chemicals. Singapore has
adopted the GHS and under the WSH (General Provisions) Regulations which are
administered by MOM, chemical suppliers must provide SDS for their hazardous chemical
products, and any occupier of a workplace must label the containers of hazardous
substances. The law has recently been amended by making reference to SS 586 on GHS. SS
586 has also been gazetted as an Approved Code of Practice under the WSH Act.

The GHS implementation timeline in Singapore is as follows:

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Compliance

What is the GHS

implementation timeline
in Singapore?

Manufacturers/Suppliers

Timeline

Single Substances
All hazardous substances except ozone depleting
substances, chemically unstable gases, aerosols,
sensitisers
(based on GHS purple book Rev 2)

Feb 2012

Ozone depleting substances, chemically unstable

gases, aerosols, sensitisers (based on GHS purple
book Rev 4)

1 Jul 2015

Mixtures

1 Jul 2015

Users

Timeline

Single Substances

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All hazardous substances except ozone depleting

substances, chemically unstable gases, aerosols, sensitisers
(based on GHS purple book Rev 2)

End 2012

Ozone depleting substances, chemically unstable gases,

aerosols, sensitisers (based on GHS purple book Rev 4)

1 Jul 2015

Mixtures

1 Jul 2016

Compliance

Compliance

Compliance

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Why is the GHS

transition period for
single substances
different from that for
mixtures?

Who is responsible for

complying with GHS
when a chemical is
imported into, exported
out or traded in
Singapore ?

GHS has been

implemented in many
countries but at different
timelines. If I import
chemicals from countries
which have yet to
implement GHS, I will
not be able to comply
with the GHS
requirements in respect
of labelling and SDS for
the chemicals imported.
What should I do in
order to meet the local

Single substances are easier to classify compared to mixtures. Furthermore, data and
information on hazard classification, labelling and SDS for most single substances are readily
available in the public domain. Therefore, a shorter timeline is given for GHS implementation.
Mixtures are composed of different substances. They are often complex and therefore a
longer time timeline is needed for hazard classification and SDS preparation.

Anyone (including importer, exporter, trader or company) responsible for or involved in the
importation, trading or marketing of chemicals in Singapore is expected to comply with the
local requirements of GHS.
The same applies when exporting chemicals to a country which has implemented the GHS.
Further to the above, Users of chemicals must also comply with the relevant requirements of
the GHS under their respective countrys local regulations.

Importers of hazardous chemicals must ascertain that the chemicals imported are provided
with GHS labels and SDS. Any local importer importing hazardous chemicals without GHS
labels and SDS has to re-label the product package and prepare the SDS in accordance with
the GHS format if the chemicals are to be sold or marketed in Singapore. It would therefore
be more cost-effective and less troublesome for local importers to import chemicals from
overseas suppliers who are able to provide GHS labels and SDS for their products.

GHS implementation
timeline?

Compliance

Compliance

Compliance

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Does Singapore adopt

High or Low thresholds
for GHS classification
purpose?
We had delivered some
chemicals to our
customers a few years
ago and some of these
chemicals (single
substances) did not have
a GHS label at that time.
Will it be the companys
responsibility when our
customers who
requested GHS labels
from us for those bottles,
pasted them onto the
wrong chemical bottles?
Is there anything we
need to ask our
customer to take care of
when using these GHS
labels?

My company imports
products from other

Generally Singapore has adopted the higher (i.e. less stringent) generic concentration limit,
consistent with key trading partner countries adoptions. However, there is this Hazard Class
whereby if a STOT Category 1, is present at 1-10%, the mixture will be classified as Category
2. The UN allows countries to decide if it will be a CAT 2, or NOT. Singapore has decided on
CAT 2 (i.e. more stringent in this case).

The labels provided to the customers should be the correct labels for the chemicals which
they have requested. The customers who are the users of the chemicals will have to check
that the labels which they are replacing should tally with the labels affixed to the original
containers.

In this scenario, there is no requirement to affix Singapore GHS-compliant label to each

container given that the companies have to ensure that the DG (Dangerous Goods) labels

countries to Singapore
for re-export purpose.
They will be stored in the
warehouse until the time
for re-export to a
destination country.
There are DG labels
and/or GHS labels of the
origin countries on the
products. Does my
company need to apply
Singapore GHScompliant label on the
products when stored in
the Singapore
warehouse?

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Compliance

My company
manufactures chemical
products in our own
plant, which are stored in
the warehouse until the
time for export to a
destination country.
Does my company need
to apply Singapore GHScompliant label on the
products when stored in
the warehouse?

Compliance

How do we comply with

GHS requirements if
SS586 is going to be
revised once every 2

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and/or origin countries GHS compliant label is affixed to the drum and consignments.
Companies, whether subscribing to third party warehouses and/or using own warehouses,
must ensure they have the necessary licences from relevant government agencies (i.e.
Hazardous Substances under NEA; Petroleum & Flammable Materials under SCDF and
explosives & explosive precursors under SPF) before storing the chemicals in the warehouse.
(Please also refer to Q10.)

Yes, for chemicals manufactured in Singapore for export purpose, company may use reduced
workplace GHS label (which indicates chemical name and GHS pictograms) at the storage
area or on the pallet. The reduced workplace label should be visible to the workers at storage
warehouses. All export and re-export chemical packages should be labelled in accordance
with export countrys regulatory requirement.

It is a usual practice for the UN documentation (standards or codes) to be revised from time to
time so as to remain relevant. However, the amendments are usually refinements or additions
in nature rather than making fundamental changes to the original GHS document (Purple
Book). Therefore, the amendments or changes will not be expected to affect most of the

years or at the same

frequency as the UN
GHS revision?

existing chemicals that have already been classified. The national GHS Task Force (which
coordinates the implementation of GHS in Singapore) takes into consideration the local
context and consults relevant stakeholders when reviewing or updating the SS 586 to align
with the UN GHS Purple Book.
.

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Compliance

Different countries will

have their own
requirements on the
building blocks adopted,
how then is GHS
harmonised?

The GHS document provides countries with the flexibility to adopt building blocks which meet
their respective domestic requirements. Although there may be differences in categories
adopted by different countries, the overall key information such as labelling elements;
pictograms, signal words, hazard and precautionary statements are harmonized.

GHS does not exempt any chemical substances/mixtures, except for the following:

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Compliance

Is any chemical
exempted from GHS
labelling and SDS?

those classified as non-hazardous by GHS hazard classification

those which do not contain any hazardous ingredients above the SDS cut-off limits as
guided by SS586 Part 3 Table 1
traces of food additives or pesticides in food *
pharmaceutical products (at the point of human intake or ingestion) *
cosmetics (at the point of intentional application) *
veterinary products intended for application to animals *

Note:- (*) These products will not be covered in terms of labelling at the point of intentional
intake but will be covered where workers are exposed in the workplace and in transport.

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Compliance

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Is there any official

language specified for
GHS label? Are multilanguages labels
permissible?

There is no official language stipulated in the GHS requirements for labelling. When exporting
to any country, you would have to comply with the local requirements (which may cover
language) as set by that particular country.
In Singapore, English is a business language used for SDS and labels. Under the WSH
(General Provisions) Regulations, it is mandatory to have warning labels in languages

understood by all persons at work, depending on the demographic of the workforce.

Pictograms serve as a tool to guide and train workers. Translation of GHS pictograms in
several languages can be obtained from the following website:
http://great.cla.gov.tw/ENG/download.aspx?classifyId=3

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Definition

Is there any difference

between the physical
hazards as determined
by GHS and UNTDG?

There is generally no difference as part of harmonisation, the GHS and UNTDG testing
requirements / rules on physical hazards and the end points have been aligned. In the 14th
edition of the UN Recommendation on the Transport of Dangerous Goods (UNTDG, the
Orange Book), the classification and labelling of DG have been harmonized with GHS to a
large extent.
Different regulators have different definitions. See summary table below.

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Definition

Definition

SS586

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What is Singapores
definition of bulk versus
packaged tanks?

What is the difference

between a single
substance and a
mixture?

When will the SS 586 be

an Approved Code of

Competent
Authority

tank

SCDF

Bulk >250 L

NEA

Bulk >450 L

SCDF

Package <250 L

NEA

Package <450 L

DG

GHS SEIP

TEIP

A single substance is a chemical element or its compound in the natural state or obtained by
any production process, including any additive necessary to preserve the stability of the
product and any impurities deriving from the process used, but excluding any solvent which
may be separated without affecting the stability of the substance or changing its composition.
A mixture means a mixture or a solution composed of two or more substances in which they
do not react.
SS 586 has already been gazetted as an Approved Code of Practice (ACOP) under the
Workplace Safety and Health (Approved Codes of Practice) Notification 2011, effective on 15

Practices (ACOP)?

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SS 586

SS 586

Safety Data
Sheet

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There are some

similarities in the
requirements for
labelling in SS 532 on
storage of flammable
liquids and SS 586 Part
1. What should be the
requirements for storage
of chemicals?

I have a warehouse of
chemicals and at the
entrance I have
displayed all the warning
notices complying to SS
508 and with this new
SS 586 part 1 on SEIP
my entrance will be
flooded with warning
signs.

Feb 2011.
SS 532 for the storage of flammable liquids provides technical requirements for safe storage
of flammable liquids in fixed bulk installations and in packages. The definition of flammable
liquids is according to the GHS flammable liquids; and in additional liquids with flash point
more than 93 degree C and up to including 150 degree C are to comply with the requirements
of category 4. It recommends the use of hazard labelling such as symbol, pictogram, signal
word, hazard and precautionary statements of GHS flammable liquids.
SS 586 Part 1 for hazard communication for hazardous chemicals and dangerous goods
provides guidelines on labelling requirements for transport and storage of dangerous goods. It
is based on the UN Recommendations for transportation of dangerous goods, and it provides
comprehensive information for the emergency responders, workers and public on the
associated physical risks of the chemicals being transported or stored.

SS 508 is the requirement for factories on warning notices to warn or remind the target
audience (workers at work) of possible dangers such as high voltage, wear protective
clothing, certain nature of hazard etc.
SS 586 Part 1 targets emergency responders and people who may not aware of the presence
of physical hazards arising from the hazardous chemicals stored inside the premises.
Thus, there is minimum repetition between SS 508 and SS 586.

How I can manage the

signs to comply with
both SS such that
people are not
confused?

For chemical warehouse where diverse range of hazardous chemicals are kept, only UNTDG
label is required at the entrance, not SEIP. SEIP is more for out-door storage such as bulk
tank farm or drums store, where single hazardous chemicals are kept at one place.

What is the difference

between SDS (Safety

There is no difference. The use of this title varies from country to country. For the purpose of
harmonisation internationally, the UN Sub-Committee of Expert on the GHS Classification and

Data Sheet) and MSDS Labelling has standardised it to Safety Data Sheet (SDS). Singapore has adopted this.
(Material Safety Data
Sheet)?

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Safety Data
Sheet

Do traders need to
prepare and create their
own SDS or can they
use the copy from the
company?

Safety Data
Sheet

Whenever there are

changes in the contents
of the SDS, is it
necessary to highlight
these changes in the
new / revised SDS?

Safety Data
Sheet

Must a new SDS be

issued when a chemical
is diluted (e.g. a 99%
concentrated alcohol is
diluted to 70%
concentration) ?

Labelling

Storage of chemicals in
drums, do we need a
GHS label for each
drum?

Labelling

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Is there a size
requirement for the

This would depend on whether the trader is selling on behalf of the company which could use
the trademark / logo, etc. In this case, they could use the supplier SDS. If the trader is to sell
and market the product under its own brand name and company, the trader would need to
create its own version of the SDS including contact details and emergency response contact
number.

No, there is no legal requirement for the changes to be highlighted. It should be the
responsibility of the manufacturer to issue a new or revised SDS whenever there are changes
in properties or contents of the chemical.

No. The SDS of the original/pure chemical can be used if there are no other chemicals
present. In addition to the SDS, additional information related to the revised diluted
concentration should also be provided.

In general, all hazardous chemical storage drums need to be labelled in accordance with SS
586 i.e. the drums must be affixed with a GHS label. If the drums are to be transported by an
open vehicle to another location, additional UNTDG label is required on the drums.
Please refer to SS 586: Part 1 and SS 586:Part 2 - Section 6.3 (Reduced Workplace
labelling) for details.
Currently there is no size requirement for the pictogram but there is a minimum size

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pictogram to be used on
the label under GHS
standards?

dimension for GHS labels which can be found in the Singapore Standard SS 586 Part 2.

Labelling

Can we combine the

transport and workplace
product label to just one
label?

Yes, they can be combined under GHS labelling. Please refer to SS 586 Part 1 for the size
requirement on transport label and Part 2 for the label elements to be stated.

Labelling

Can a GHS label be

printed on a coloured
paper/background?

Under GHS, pictograms prescribed should have a black symbol on a white background with a
red frame sufficiently wide to be clearly visible (black border is acceptable if the product is not
for export) regardless of the colour or background of the paper used.
Please refer to SS 586 Part 2 for details.

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Labelling

If the label could not fit

all hazards/pictograms,
is it possible to leave out
some?

Labelling

The use of a blank diamond space pictogram with a red (or black border) or any other related
Can a blank diamond
combinations on a printed label is currently being reviewed by the United Nations GHS Subspace pictogram with red committee. In view of this pending decision on the issue by the UN Sub-committee, for the
(or black) border be
interim, the use of existing pictograms as currently practised by the industries is acceptable in
printed on the label?
Singapore. However, exporters must check on the local requirements of the other countries if
the product is to be exported or for use in that respective country.

Labelling

Is there a requirement
for vacuum pumps or
POU abatement that
may deliver or contain
hazardous chemicals be
labelled with GHS
chemical labels?

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There can be a maximum of four pictograms on the label and all hazard statements are to
be included.

GHS label is only required for a chemical that is classified as hazardous under the GHS
classification criteria. It also applies to packed-in containers (e.g. drums, pals and bottles or
small containers).
This is not for equipment or tanks. Refer to the GHS guideline (SS 586) for more details.

There are numerous databases listing substances and their classifications and resulting label
elements in the internet. Some of these are country specific and offered by the competent
authority e.g. Korea and Japan.
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Miscellaneous

Are there available

databases to assist in
classification and
labelling?

Miscellaneous

Is GHS labeling required

for consumer products
which contain hazardous
substances?

Miscellaneous

What is the relation

between HS Code in
Trade Net and GHS?

Miscellaneous

If I do the classification
for the chemicals, would
my classification be
challenged?

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Miscellaneous

Is there a course for

mixtures classification?

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Miscellaneous

Where can a copy of the

Singapore Standard SS

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Notwithstanding the availability of these databases, a company will need to review and carry
out its own assessment based on the chemical and component details to determine the
hazard classification of the chemical substance. It is also recommended that the company
maintains proper house-keeping records of the classification process for future references,
particularly so when the classification process has to be reviewed due to changes in the GHS
criteria.
Generally in most countries, consumer packages (purchased off the retail shelf in
supermarkets and stores) which contain hazardous substances do not have to be GHS
labelled.
However, in some countries e.g. Japan, they do provide GHS labels on consumer
packages/products such as soap and detergent. This practice is however voluntary.
HS Code is used for the identification of products (including chemicals) in Singapores Trade
Net for custom clearance. It is for Import/Tariff Tax which in principle has no relation to GHS.

Regulatory authorities or agencies have the right to know or challenge the classification
especially if there is any query or complaint from an end-user. Hence, it is advisable to keep
and make available all the records and data on how the hazardous chemicals are classified.
Please contact the Singapore Chemical Industry Council (SCIC) by Tel. 6267 8891, email
secretariat@scic.sg or visit SCIC website at www.scic.sg for more information.

To purchase Singapore Standards, please go to www.singaporestandardseshop.sg. The full

collection of Singapore Standards may be viewed at SPRINGs reception area (1
Fusionopolis Walk, #01-02 South Tower, Solaris, Singapore 138628), as well as the Lee

586 be obtained?

Kong Chian Reference Library (National Library Building, 100 Victoria Street, #07-01,
Singapore 188064).

Notes
SS 508: 2004 Part 3 Graphical symbols Safety colours and safety signs use at workplace and public areas
SS 532: 2007 Code of practice for the storage of flammable liquids (formerly CP 40: 1987)
SS 586: 2014 Specification for hazard communication for hazardous chemicals and dangerous goods
Part 1: Transport and storage of dangerous goods
Part 2: Globally harmonised system of classification and labelling of chemicals - Singapore's adaptations
SS 586: 2008 Specification for hazard communication for hazardous chemicals and dangerous goods
Part 3: Preparation of safety data sheets (SDS)

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