Brunei Issues Guidance on Managing Hazardous Substances at Work Based on GHS Rev. 7

On 30 September 2026, the Safety, Health and Environment National Authority (SHENA) of Brunei Darussalam issued the Industry Guidance Note on Managing General Hazardous Substances in a Workplace (No. 2026/IGN/02). Using the seventh revised edition of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS Rev. 7) as the classification baseline, the Guidance Note covers hazard classification, warning labels, safety data sheets (SDS), registers and inventories, life-cycle management, emergency preparedness, toxic substance exposure monitoring and health surveillance, and is accompanied by a Note to Industry (2026/NTI/02) and a Self-Assessment Checklist for Managing General Hazardous Substances in a Workplace for enterprises to benchmark their management systems.

Positioning and Legal Basis of the Guidance Note

The Guidance Note is a non-statutory document that neither creates nor replaces any legal obligations under the Workplace Safety and Health Act (Chapter 277, “WSHA”) and its subsidiary regulations; it is intended to support compliance therewith and dovetails with Element 5.10, “Management of Hazardous Substances”, of SHENA's Workplace Safety and Health Management System Code of Practice (WSHMS COP). Enacted in 2009 and in force since 1 August 2013, the WSHA, together with subsidiary regulations such as the WSH (Risk Management) Regulations, the WSH (General Provisions) Regulations, the WSH (Incident Reporting) Regulations, the WSH (First-Aid) Regulations and the WSH (Workplace Safety and Health Officers) Regulations, forms the legal framework for hazardous substance management at workplaces, covering risk assessment, warning labels, SDS, incident reporting and first-aid arrangements.

Scope of Application: 17 Classes of General Hazardous Substances

The Guidance Note applies primarily to the 17 classes of “general hazardous substances” listed in Schedule 5, Part 2, Division 1 of the WSHA:

“Specific hazardous substances” listed in Schedule 5, Part 2, Division 2 may likewise be managed in accordance with the Guidance Note where, based on the properties shown in their SDS, they fall within one or more hazard classes of Division 1; where the quantities exceed the thresholds prescribed by the WSH (Facilities) (Control of Major Accident Hazard) Regulations (COMAH Regulations), the applicable COMAH requirements must also be met. Hazardous substances in consumer packages intended for retail sale and use in households or offices are not subject to the relevant requirements of the WSH (General Provisions) Regulations. The Guidance Note does not cover occupational hygiene measurement and sampling, or environmental protection, hazardous waste and other matters administered by other authorities.

Classification Baseline: GHS Rev. 7

SHENA has explicitly adopted the seventh revised edition (2017) of the UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS) as the baseline reference framework for classifying hazardous substances and communicating hazards at workplaces, describing it as the most commonly used revision in the ASEAN region. Under the GHS, hazards are grouped into physical, health and environmental hazards; the Guidance Note sets out the corresponding GHS pictograms for each category and provides classification summary tables. Workplaces typically obtain hazard classification information from the warning labels and SDS provided by suppliers and feed it into the risk assessment process; the Guidance Note also stresses that classification alone does not equate to risk, as actual risk depends on how a substance is used, the extent of exposure and the effectiveness of control measures.

Hazard Communication: Warning Labels and SDS

Under Regulations 42 and 43(1) of the WSH (General Provisions) Regulations, occupiers must ensure that containers of hazardous substances are affixed with warning labels reflecting their hazards, and that for any hazardous substance used, handled or stored at the workplace an SDS is obtained, its information is assessed, and the SDS is readily accessible to workers who may be exposed. A GHS warning label contains six elements: product identifier, supplier identification, pictograms, signal words (“Danger” or “Warning”), hazard statements, and precautionary statements. An SDS should follow the 16-section format prescribed by the GHS and be reviewed at intervals not exceeding five years, with updates where necessary; suppliers selling hazardous substances for use at a workplace must provide the buyer with an SDS.

When hazardous substances are decanted or transferred, the contents should be clearly identified and the corresponding hazard information communicated; containers intended for immediate or temporary use under the direct control of workers may carry reduced labels, while decanted substances that are stored, transported within the workplace or left unattended should bear full warning labels.

Register and Life-Cycle Management

Workplaces storing and/or handling hazardous substances should establish and maintain a hazardous substance register recording elements such as chemical name, CAS number, supplier information, quantities stored, storage locations, hazard classification and SDS information (a template is provided in Appendix A), keep it up to date, and make it readily accessible to workers and personnel involved in emergency response.

The Guidance Note sets out life-cycle management requirements across five stages — selection, transport, storage, handling and use, and disposal — with the SDS serving as the primary reference throughout and higher-level controls such as elimination and substitution prioritised under the hierarchy of controls. The key points for each stage are as follows:

1. Selection: give priority to elimination or substitution with less hazardous substances or processes; review the GHS classification and SDS before introduction, noting that within the same GHS hazard class Category 1 denotes a more severe hazard than Category 2, and evaluate flash point, toxicity, volatility, exposure limits and compatibility with existing control measures;
2. Transport: use suitable, properly labelled and secure containers to prevent damage and leakage in transit; follow recognised standards such as the UN Recommendations on the Transport of Dangerous Goods (Model Regulations) where applicable;
3. Storage: store in accordance with the SDS and manufacturer recommendations, apply first-in first-out stock rotation, maintain ventilation and temperature control, segregate incompatible substances, provide secondary containment such as bunds and drip trays, keep away from ignition sources, and inspect and maintain storage arrangements regularly;
4. Handling and use: complete hazard identification and implement control measures and safe work procedures before handling; provide workers with the necessary information, training and supervision, and use properly fitted personal protective equipment (PPE) as required;
5. Disposal: establish on-site hazardous waste management procedures covering waste classification, interim storage and secondary containment; entrust final disposal to dedicated agencies approved by the Department of Environment, Parks and Recreation (JASTRe) of the Ministry of Development and transport the waste to authorised disposal facilities; waste destined for disposal outside Brunei must comply with JASTRe requirements.

Emergency Preparedness, Exposure Monitoring and Health Surveillance

Workplaces should develop spill response procedures in accordance with the SDS and equip themselves with spill response materials commensurate with the substances involved; where there is a risk of exposure to toxic or corrosive substances, emergency showers and eyewash facilities should be provided in accordance with the WSH (First-Aid) Regulations; emergency procedures should also be developed under Section 12(3)(d) of the WSHA, with regular training and drills. Incidents involving hazardous substances should be reported through SHENA's online portal; where a worker is diagnosed with an occupational disease listed in Schedule 3 of the WSHA, the employer, together with the registered medical practitioner or the Designated Workplace Doctor (DWD), must report the case to SHENA in accordance with the WSH (Incident Reporting) Regulations.

Toxic substance exposure monitoring should be conducted where risk assessments indicate that workers may be exposed to toxic substances at concentrations potentially exceeding the permissible exposure limits (PELs) specified in Schedule 1 of the WSH (General Provisions) Regulations, or where the effectiveness of existing control measures is uncertain. PELs comprise long-term limits (8-hour working day and 40-hour working week time-weighted averages) and short-term limits (15 minutes), and monitoring must be carried out by a competent person (SHENA Notice to Industry 2024/NTI/09 sets out the minimum competency requirements). Where necessary, health surveillance should also be conducted, including pre-employment, periodic and post-employment medical examinations and biological monitoring, by a SHENA-registered DWD; health surveillance cannot replace hazard elimination and control measures.

ChemRadar Insights

Based on the Guidance Note and Brunei's current regulatory framework, CIRS recommends that relevant enterprises focus on the following:

1. Conduct self-assessment to identify gaps: although the Guidance Note is recommendatory in nature, its content directly maps the existing statutory obligations under the WSHA and its subsidiary regulations (GHS warning labels, SDS acquisition and review, risk assessment, etc.). Enterprises with factories, warehouses, laboratories, or oilfield operations in Brunei should use the accompanying Self-Assessment Checklist to review their existing hazardous substance management systems item by item;
2. Mind GHS version differences: Brunei has explicitly based its framework on GHS Rev. 7, whereas the GHS versions adopted across ASEAN countries vary. Labels and SDS for substances supplied to Brunei should align with the Rev. 7 framework; enterprises supplying the same substance to multiple countries should also be alert to label and SDS revisions that version differences may require;
3. Improve records and documentation: the Guidance Note sets out specific requirements on register elements, five-year SDS reviews, exposure monitoring records and emergency drills; such records should be incorporated into local EHS documentation so that they can be readily retrieved during inspections or incident investigations.

CIRS Services

CIRS Group provides chemical compliance support services covering ASEAN and global markets for relevant enterprises:

• SDS and label preparation in compliance with China GHS
• SDS and label preparation in compliance with EU REACH & CLP, UFI assignment and poison centre notification (PCN)
• SDS and label preparation in compliance with Korean GHS, and SDS submission
• SDS and label preparation in compliance with Japan GHS
• SDS and label preparation in compliance with US GHS
• SDS and label preparation in compliance with Canada GHS
• GHS services for other countries and regions (Brazil, Argentina, Southeast Asia, the Middle East, etc.), covering more than 50 languages
• Issuance of SDS and labels bearing the CNAS mark
• 24/7 global emergency telephone consultation service

Further information

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