You are considered as a subcontractor. Under the Occupational Safety & Health Act 1994, a subcontractor is considered as an employer. As an immediate employer you have to comply with the requirement of Occupational Safety and Health (Use and Standards of Exposure of Chemicals Hazardous to Health) Regulation 2000 (USECHH) including carrying out Chemical Hazardous Risk Assessment (CHRA).

Yes, Sulfuric Acid is a corrosive substance under Occupational Safety and Health (Classification, Packaging and Labelling of Hazardous Chemicals) Regulation 1997, (CPL) and listed under schedule 1 of USECHH regulations and therefore it considered as chemical hazardous to health. It's your duty to conduct CHRA even though it is used in small quantities.

Write officially to DOSH office for extension of compliance. It is advisable that the cost for Safety & Health activities (including CHRA) should be budgeted for as part of the business activity.

To be done immediately If
i. There has been a significant change in the work to which the assessment relates or 
ii. Five years from the date as the last assessment or  
iii. As directed by DG, DDG or Director of DOSH.

Chemicals that should be listed in the chemical register are chemicals hazardous to health as defined under USECHH Regulations.

Yes.

No. In the CHRA report, work units assessed using SiRAC should be indicated so (eg ' done using SiRAC ' etc).

Recommendation shall only be made by the assessor. The OHD and assessor should work together to ensure that the assessment is done thoroughly.

Assessor can choose to perform assessment by using CHRA or SiRAC. However, SiRAC is not applicable to chemical classified as Carginogenic, Mutagenic and Respiratory Sensitiser (CMR) and are only applicable for chemical in solid an liquid form. SiRAC can only be used once the amended USECHH Regulation is gazette.

No. However, assessor can submit the report in a CD.

Assessor is recommended to refer the information given in the SDS to prevent error in classification. Reclassification has to be done if no information is provide in SDS.

For silica issue, monitoring can be suggested to determine the existance of silica dust. Para 5.2 CHRA Manual had stated, various sources can be used as a reference to determine hazard rating.

Assessor must reclassify the chemical if the chemical is mixed at the assessed workplace.

For C3, employer will have to implement the suggested improvement made by the assessor and the assement will have to be reviewed afterwards. For C4, assessor would have to provide employer with suitable temperory measures while the employer seek further information on the related chemicals. After the information is obtained, the assessment will have to be reviewed again.

Yes, soft copies are preferred.

Copies of the CEP certification must be certified as true copies by professionals not limited to Commissioner for Oaths.

Currently, online competency renewal is available for SHO, SSS, and AGT. Online renewal of registration for CHRA Assessor is expected to be available soon.