On September 1, 2020, the Department of Occupational Safety and Health (DOSH) under the Ministry of Human Resources Malaysia released FAQ on Chemical Information Management System (CIMS), which is a system that enables inventory submissions of hazardous chemicals online. The FAQ consist of 21 items, including basic questions such as CIMS usage, and advanced questions such as inventory submission requirements for chemical mixtures.
The summary of the main questions and their answers is as follows.
Q4. Are there specific quantities of hazardous chemicals for inventory submission in CIMS?
ANSWER: Pursuant to Regulation 14 (1), CLASS Regulations 2013, importers or manufacturers shall submit an inventory of hazardous chemicals for each hazardous chemical imported or supplied in quantities of 1 metric ton and more per year for each calendar year. For example, if supplier A imports ABC chemicals from January to December with a cumulative amount of 950kg and XYZ chemicals from January to December with a cumulative 1200kg, supplier A will need to submit inventory at CIMS for XYZ chemicals only since it exceeds 1 metric ton per year.
Q7. Do local suppliers who supply hazardous chemicals from local importers need to submit inventories?
ANSWER: Local suppliers who obtain a supply of hazardous chemicals from local importers are not included in the interpretation as importers under the CLASS Regulations 2013. Therefore, the requirement to submit an inventory of hazardous chemicals is not applicable. The definition of an importer in the CLASS Regulations 2013 applies only to importers who obtain a direct supply of chemicals from abroad.
Q8. I personally import hazardous chemicals from abroad directly into my factory. The whole chemical is used in the manufacturing process at my factory. I don’t sell those chemicals to anyone. Do I need to apply CIMS?
ANSWER: Any person who obtain the supply of hazardous chemicals directly from abroad including for his own use is an importer under the provisions of CLASS Regulations 2013. Therefore, the inventory of hazardous chemicals needs to be submitted if the annual quantity of imports is 1 metric ton and above.
Q13. For chemical mixtures classified as hazardous, do I need to submit all information related to the compounds and mixtures of the chemicals?
ANSWER: No, only the composition and ingredients of the hazardous chemicals contained in the chemical mixture need to be submitted in CIMS. For example, substance A and substance B form a chemical mixture C, and substance A is classified as hazardous. In this case, the information that needs to be provided is product identifier of mixture C, name of substance A, hazard classification of mixture C and total quantity of mixture C. However, if the substance A is manufactured in the same factory or imported directly by the same manufacturer, the substance A must also be included in the inventory as another hazardous chemical (in the substance category) to be submitted to CIMS.
The original text of the FAQ can be viewed from the following URL.