Malaysia Malaysia releases self-assessment checklist to ensure compliance with CLASS Regulations

Malaysia releases self-assessment checklist to ensure compliance with CLASS Regulations

A self-assessment checklist on the various requirements of the “Occupational Safety and Health (Classification, Labelling and Safety Data Sheet of Hazardous Chemicals) Regulations 2013” (commonly referred to as the CLASS Regulations) has been released on the website of the Department of Occupational Safety and Health (DOSH) under the Ministry of Human Resources Malaysia. The checklist is a six-page A4 size format that can be utilized by chemical suppliers including manufacturers and importers to self-evaluate whether they are complying with the requirements of the CLASS Regulations.

 

The check items can be roughly divided into five categories: chemical classification, packaging, labeling, SDS, and inventory. For each check item, questions, supplementary explanations, and documents to be attached are clearly indicated. Questions must be answered by marking “yes”, “no”, or “not applicable”, and documentary evidence to support the answer must be attached (see the figure below for an example). The suggested format for the attached documents is PDF.

For example, there is a question “Do you have any record of classification as prescribed under Regulation 5 of the CLASS Regulations 2013?” in the first category of the checklist, “classification”, followed by supplementary explanations shown below.

For main suppliers =>

    1. Select at least three samples of record of classification among all chemicals.
    2. All chemicals shall be considered as samples in case the total number of chemicals is three or less.
    3. Please confirm the answer based on the CLASS Regulations 2013, ICOP CHC 2014, and ICOP CHC (Amendment) 2019 Part 1.

For subsidiary suppliers => Please mark “Not applicable”.

 

Other questions in the checklist are as follows.

    • Is there a fastener attached to the package?
    • Does the packaging have any mark indicating that it is a chemical product?
    • Is the information on the label clear and undeletable?
    • Is the label provided bilingual (Malay and English)?
    • Does the size of the label comply with fourth schedule of Regulation 11(1) of the CLASS Regulations?
    • Can the label be read horizontally when the container is in its normal position?
    • Does the pictogram meet the requirements?
    • Is SDS available for the hazardous chemicals being supplied?
    • Is the SDS provided bilingual (Malay and English)?
    • Is the SDS reviewed at least every five years?
    • Is the inventory submitted to the Chemical Information Management System (CIMS)?

 

The original text of this checklist can be downloaded from the following URL.
https://www.dosh.gov.my/index.php/list-of-documents/info-kkp/pengurusan-kimia-1/3816-senarai-semak-self-assessment-peraturan-class-2013/file

Author / Responsibility

AOKI Kenji

Senior Consultant, EnviX Ltd.
General Director, E&H Consulting Co., Ltd.

Business Performance

Expertise in EHS (environment, health and safety) consulting in ASEAN region.
- Environmental regulations updating
- Chemical regulations consulting

Background

MSc in Earth Science, The University of Tokyo

AOKI Kenji