Information about chemicals classification method can be referred to:

1. Industry Code of Practice on Chemicals Classification and Hazard Communication, (ICOP CHC);
2. The Globally Harmonized System of Classification and Labelling of Chemicals (GHS Purple Book)

If the chemical has already gone through the classification process and found to be not classified according to CLASS Regulations, the requirements of packaging, labelling, SDS and inventory of hazardous chemicals is not applicable to the particular chemical. However, the requirement of SDS is still applicable to the chemical mixture containing hazardous substance exceeding concentration specified in the Fifth Schedule of the CLASS Regulations. Please retain all classification record as proof of classification.

The format of classification record is given in paragraph 2.7 of Part 2 in the ICOP CHC. Classification record must contain all the information as per stated in the format. However, any form of documentation, for example electronic database or tools, which contains all of the specified information (as specified in the format) will be regarded as a classification record. Please be informed that an SDS is not a classification record.

Classification records are meant to prove that the chemicals are classified according to the CLASS Regulations with justifications and/or data to support the classification. These justifications and/or data are then ensured reliable through proper citations and are traceable when needed.

For chemicals not listed in Part 1, ICOP CHC, the principal supplier will have to carry out self-classification using methodology as detailed out in Part 2 of ICOP CHC. If the chemical has gone through the process of classification and the result for classification is “not classified” for all hazard classes, the requirements of packaging, labelling, SDS and inventory of hazardous chemicals is not applicable for that particular chemical. Please be informed that the list of chemicals in Part 1 only consist of substances and is not finite.

If the chemical is listed in Part 1 ICOP CHC, it is sufficient to mention that the chemical is listed in Part 1 ICOP CHC in the justification column (refer to Appendix 2.3 Classification Record).

Importer can obtain data on the classification from the overseas manufacturer. If the data could not be obtained, the importer will have to search data on the chemical from literatures, journals, established articles or internationally recognised chemical database in order to perform self-classification as per Part 2 of ICOP CHC. It is the duty of the importer to make classification record available for inspection.

The classification should be done based on the form of the product that it is supplied. Therefore, in this case, the classification should be done in solid form. If there is any known hazard that can affect health when handling/using the product, these should be detailed out and stated in the SDS (Section 2, as explained in the paragraph 3.7.2.3, ICOP and section 7).

The supplier should comply with the classification given in Part 1 ICOP CHC. If there is strong evidence or data available to support on the differences in classification, the supplier may submit evidence or data to the Department to highlight the inconsistency. The Director General will determine the final classification of the particular chemical.

Yes and this chemical is still classified as hazardous under CLASS Regulations.