Chemical manufacturers and importers making the notification and registration of EHS are encouraged to follow the steps given below:

A.      PRE-NOTIFICATION

1

Compile an inventory (list) of all individual chemical substances manufactured and/or imported by the company during the year of notification. The substances to be listed, together with their identification number (e.g. CAS No or EC No), may be in pure form or as part of mixtures or in finished products.

2

Check whether each of the listed chemical substances is hazardous or not. There are two ways to achieve this:

Log into the Department of Environment's on-line EHS Notification and Registration System. In the EHS Reference List box, type the identification number (CAS No or EC No) of the substance and click on the Search button. A result of the search function will be displayed to the user. If the substance is on the EHS Reference List and already has an agreed GHS hazard classification, as shown by the displayed chemical name, classification code and other properties, a basic notification of the substance is required from the company. The basic notification is however not required if the annual tonnage of the substance is below the tonnage trigger point currently enforced by the Department of Environment Malaysia (see Implementation ). The information can be notified by completing the form under the sub-menu "Basic Notification of EHS". (Note: A chemical company needs to register with the EHS system first before a notification is permitted - See Step 4).

Next, type the identification number (CAS No or EC No) of the substance in the CMR Reference List and click on the Search button. If the substance is on the CMR Reference List and already has an agreed GHS hazard classification, as shown by the displayed chemical name, classification code and other properties, a basic notification of the said substance is also required from the company; irrespective of the annual tonnage produced or imported by the company.

3

If the substance is not on the EHS and CMR Reference Lists or which do not have an agreed GHS classification, as indicated by the message "Record Not Found", the manufacturer or importer will then be required to assess that substance against the GHS classification criteria. If the substance is assigned a GHS classification, the manufacturer or importer will then be required to supply the information that they have used to carry out the classification, the classification itself and the data on tonnage per annum (as defined in the basic notification of EHS). The manufacturer or importer can also refer to the Safety Data Sheet (SDS) of the given substance or mixture/product, where in Section 2 on "Composition/Information on Ingredients", a listing of the hazardous substances in the mixture/products is documented. Note: There is a need to differentiate between the SDS of a substance and a SDS of a mixture or product. The EHS NOTIFICATION AND REGISTRATION SCHEME is for environmentally hazardous substances only. If in doubt about the properties given in the SDS, please contact the supplier or manufacturer of the substance or mixture/product. If through any of the above ways the substance is determine to be hazardous, a detail notification of the substance is required from the company. The information can be notified by completing the form under the sub-menu on "Detail Notification of EHS".  

4

For those substances which are not assigned a GHS classification in Step 3, the manufacturer or importer shall however be required to retain the data used to make their GHS assessment for a minimum of 5 years, after the assessment has been made. The data must be made available for inspection on request by the Department of Environment Malaysia.

For some substances, it is recognized that the producer and/or importer may be unable to carry out a GHS classification (e.g. because of insufficient data or uncertainty in the structure of the substance). In this case, the producer or importer should submit all of the available data, including tonnage, and submit them to the DOE with an explanation of why it was not possible to assign a GHS classification.

5

Finalize the list of all hazardous substances manufactured and/or imported by your company. The list shall have, at least, all the information required for basic notification of EHS, i.e. name of chemical, ID no, annual tonnage, occurrence, source, uses, etc. 

Full details and guidance on the Notification and Registration Process are available in the Guidance Document which can be downloaded from this website.

B.      NOTIFICATION

4

Register your company with the Department of Environment Malaysia to participate in the EHS NOTIFICATION AND REGISTRATION SCHEME. This can be done by logging into the DOE website (http://www.doe.gov.my) and activating the menu on EHS Notification and Registration. Select the option on Company Registration in the resultant output to register your company. A letter of approval, sent by e-mail, will be communicated to you once the registration is verified and approved by the Department.

5

A two stage approach is recommended to chemical industries for the Notification and Registration of EHS. Once access to your company private domain or window is obtained, i.e. after entering the User ID and Password, follow the procedures listed below:

Activate the menu on Basic Notification of EHS to undertake a basic notification for each hazardous substance which you have finalized in Step 5. On completion of data entry, check for correctness of your data before submitting the information to DOE, since information once submitted will not be subject to any changes. Repeat the basic notification for all substances in your list. A display listing all substances entered into the system and notified by your company is available for your viewing and printing, if required. Explanatory texts to assist you in entering the data as well as how to proceed with the notification process are given the system.

Once the basic notification has been completed, a detail notification can then be undertaken. In this case, the substances which require detail notification will be listed when the menu Detail Notification of EHS is activated. Select a particular substance to begin the detail notification process. (Note: All six sets of data, i.e. EHS Identification, Physical Chemical Properties, Physical Hazards, Hazards to Human Health, Hazards to Aquatic Environment and Overall GHS Classification must be completed before submitting the data to the Department of Environment Malaysia).     

If a substance had been previously notified in detail (e.g. in the previous year), a detail notification of the said substance is not required anymore. However a new detail notification of the substance should be made if new data are available to the company. In this case, detail data previously notified can be accessed and edited to reflect the changes.