Purpose
The purpose of this policy is to summarise labelling, safety data sheets (SDS), risk assessment requirements, storage and disposal.
This procedure relates to all PEER Construction workplaces and work processes using hazardous substances that any employee, contractor, or visitor may undertake.
Safety Data Sheets (SDS)
SDS are required for all chemicals that are deemed hazardous by the NOHSC. SDS must be obtained for all chemicals in use or storage.
The SDS must:
- be readily available to personnel using the substances with information on chemicals in a form that is easily understood by the user
- identify if the substance is a designated hazardous substance
- meet the needs of those workers with language or literacy difficulties.
The manufacturer’s SDS must be obtained from the supplier and updated every 5 years. Contracts for the supply of hazardous substances must include provision for the supplier to supply the appropriate SDS and that the supplier must notify any changes in formulation.
Process
The process has the following components.
Hazardous substance register
Hazardous substances used at all workplaces must be identified and listed on a register. Non hazardous chemicals should also be included on manifests. A collection of SDS shall be readily available to workers and constitutes part of the register. This register should also state the dangerous goods status/class of any of these substances as well as maximum quantities and location. The register should always be current and should be updated when new substances are introduced.
The register should also include notation of simple and obvious risk assessments which have been conducted on hazardous substances. No further report or record is required.
Register and site plan of the premises
A register of hazardous chemicals is part of a mandatory Emergency Plan and is used to assist emergency service organisations and responders understand the chemical hazards and quantities of dangerous goods present at the workplace. The main purpose of the manifest is to provide the emergency services authority with information about the quantity, type and location of dangerous goods stored and handled on the premises to enable them to respond appropriately if called to an emergency. Workers should be aware of the location and purpose of the manifest.
The register should be located within ready access of emergency personnel, it should not be in an area which may become inaccessible due to the associated risk. The hazardous substance register may be used as the emergency manifest.
Risk assessment
A risk assessment should be performed and recorded for any process using hazardous substances. For a substance to be used, the hazardous substance risk assessment form must be completed in consultation with relevant employees or contractors.
The process shall include:
- Performing a simple and obvious risk assessment on all substances to be used.
- Completing a risk assessment for all processes to be undertaken, taking into consideration all hazardous substances, unless a prior risk assessment has been completed.
- Implementing all controls prior to the process commencing.
- Including all risk assessments in the hazardous substance registry.
- Undertaking generic risk assessments for processes performed on a regular basis and utilising the same processes. These are to be stored in a section of the hazardous substance registry in a designated area.
Risk assessments need to be reviewed in the event of a change of process, plant or substance, new information on hazards, inadequate exposure control being identified and new or improved controls becoming reasonably practicable. All risk assessments must be reviewed every 5 years at a minimum.
Simple and obvious assessments
Simple and obvious risk assessments are performed by consulting the SDS. This is used to provide information on the handling and use of the substance and to identify whether it is classed as a hazardous substance. If the inspection of the work shows that any risk can be, or is already, controlled in accordance with the SDS (or the equivalent information about precautions for use and safe handling), then the assessment is complete and no further assessment is needed. This can be noted in the register.
Detailed assessments
A more detailed assessment may be required for some work. These situations include:
- There is uncertainty about the degree of risk.
- There is a significant risk to health, for example, exposure to a hazardous substance may be high and/or the nature of the health hazard is serious.
- More complex chemical processes and/or exposures are involved.
A more detailed assessment might involve obtaining additional information about health hazards, a thorough evaluation of the work to determine exposures (including monitoring where appropriate), and examination or testing of existing control measures.
Labelling
SDS provides the information required for labelling.
All containers must be clearly labelled with the substance contained and include any risks or significant hazards posed by the substance. Other details should include;
- directions for use
- first aid and emergency requirements
- expiry date
- manufacturer’s details.
Identification information must be noted including, product name, chemical name, UN number and ingredients and formulation details (where relevant). Texta, pencil, pen or any other label other than the original with its label is not accepted.
Barricades
Barricades should be erected or placed to restrict the entry of persons to an area and/or prevent personnel being exposed to dangerous chemicals or goods.
All barricades shall be accompanied by an appropriate sign, which is to be placed on all access points.
Placarding
Legislative requirements for placarding of premises are dependent on volumes and packaging groups of hazardous substances.
The following are recommended as a minimum requirement to minimise risk to emergency services, contractors and employees.
Placarding:
- on any entrance roads to the premises
- at the entrance to the buildings
- on entrance doors to storage facilities
- for class 3, 6 and 8
- where there is storage greater than 25Lt of hazardous substance (except for class 6.1 packaging group 1. where it is 10Lt).
Placarding involves erecting hazardous substance diamonds indicating class and Hazchem placards at entrances.
More information is available from the Guidance Note for Placarding Stores for Dangerous Goods and Specified Hazardous Substances. Refer to this document to determine if placarding is required under legislation. Placarding should also be dependent on risk assessment of the areas.
Emergency response
Risk assessments will cover spills and their consequences and document procedures. The location of the spill should be considered when assessing potential environmental or safety concerns.
Spill kits should be available for use in the event of a spill and their use documented on the risk assessment. All personal protective equipment should be available and used in the event of spills.
Spill or leakage procedure
In the event of a spill or leakage:
- ensure there is no danger to anyone in the area.
- attempt to contain the spill using appropriate PPE.
- absorb any liquids with sand/kitty litter etc.
- inform the senior manager of the spill.
- dispose of waste as per disposal instructions on SDS.
- inform any regulatory bodies as required such as EPA / SafeWork SA.
Spill kits
Spill kits should be available for use where it is assessed they are required. The contents of the spill kit should be relevant to the area and the potential spill. This may include;
- heavy duty plastic bags or plastic drums (with a lid) to contain hazardous material prior to disposal (this can be used to store all items).
- a couple of bags of kitty litter, saw dust or sand to absorb spilt liquids.
- brooms, dustpans and a square mouth shovel to sweep up the absorbent material.
- absorbent pillows or booms to contain larger liquid spills and prevent spills entering drains.
- appropriate personal protective clothing such as chemical resistant gloves, safety glasses.
Ensure that the spill kit is clearly labelled and located in a position easily accessed by all workers. Spill kits should be restocked following use and the contents should be checked monthly.
All spillages must be reported immediately to your supervisor. Appropriate clean up action is mandatory.
Storage, transport and disposal
All hazardous substances must be kept in secured storage facilities. The doors must be locked except when there is an employee present who has responsibility for accessing this area.
General requirements for the storage of dangerous goods
The area where dangerous goods are stored should be:
- well ventilated and well lit
- separated from ignition sources
- secured from the public
- protected from temperature fluctuations and direct sunlight.
All chemicals are to be:
- clearly labelled with manufacturer’s label or appropriate hazardous substance label. Labels are to be in good condition and easy to read.
- segregated by class into the appropriate bays.
- stored according to their compatibilities.
Copies of SDS are to be held on site and located in the safety bay for use as appropriate and all SDS must be current.
Liquid waste storage
Liquid waste such as solvents or acids are to be stored in containers approved by the statutory authority.
The container should be:
- resistant to the chemical contents
- able to be sealed
- suitable for transport.
Segregation of chemicals
In general, each class of dangerous goods should be segregated by a physical barrier. More detailed information is available from the SDS.
The risks involved in the interaction of incompatible substances can include;
- uncontrolled release of heat
- emission of noxious fumes
- explosion.
It is important that a hazardous substance risk assessment form is completed prior to mixing chemicals.
Shelf storage
Where chemicals are kept on shelves or racks;
- shelving must be compatible with the goods stored.
- the shelves should be constructed of chemically resistant materials.
- shelving systems must be designed to hold the maximum holding capacity of the chemical containers.
- incompatible chemicals should not be stored together on shelves.
- solid chemicals should preferably be stored on upper shelves above liquid chemicals.
- secondary containment (bunding) is essential for large containers. As a priority all dangerous goods of this size should be bunded.
- shelves should have raised edges to reduce the likelihood of dislodging containers.
- the most dangerous chemicals should be stored at easily accessible heights (e.g. 1.5 metres from the floor)
- chemicals should not be stored in direct sunlight.
Storage in refrigerators
Storage in cabinets
Where chemicals are stored in cabinets it must be ensured that;
- the cabinet is marked with the appropriate hazardous class diamonds
- they are constructed of chemically resistant material
- flammable liquid storage cupboards are self closing with two points of contact
- incompatible substances are not stored together.
Transportation of dangerous goods
- Supervisor / managers must be notified when chemicals are delivered to the site, so the chemical can be transported in accordance with the SDS.
- Consideration shall be given to handling and storage requirements on the SDS when transporting hazardous substances.
- Personnel shall ensure spill and emergency response equipment is readily available during transit.
- Transportation of dangerous goods shall be done in accordance with the Australian Code for the Transport of Dangerous Goods by Road & Rail.
- Never transport hazardous chemicals in the cab of a vehicle.
Disposal
SDS should be viewed to determine the most appropriate means of disposal. All substances no longer required are to be removed from the site by a licensed operator for disposal as per Environment Protection Authority guidelines.
Roles and responsibilities
The following roles and responsibilities apply.
Managers and supervisors
- Maintain the register and SDS and ensuring they are up to date.
- Identify hazardous substances and dangerous goods and completing risk assessments.
- Provide appropriate information to workers in relation to hazardous substances and dangerous goods.
- Implement appropriate risk control measures in consultation with workers in keeping with the hierarchy of control.
- Conduct investigations of incidents involving hazardous substances or dangerous goods.
- Report any notifiable incidents involving hazardous substances to SafeWork SA.
Workers
- Use control measures and any other actions designed to protect health and safety.
- Participate in the development of appropriate risk control measures for hazardous substances and dangerous goods in keeping with the hierarchy of control.
- Report any incident involving a hazardous substance or a dangerous good.
Work Health and Safety Act 2012 (SA)
Work Health and Safety Regulations 2012 (SA)
Environment Protection Act 1993
Guidance Note for Placarding Stores for Dangerous Goods and Specified Hazardous Substances
WHS Policy
Class label
The label illustrating the class allocated to a substance under the Australian Code for the Transport of Dangerous Goods by Road & Rail (ADG Code) (ADG Code 1)
Dangerous goods
A hazardous substance defined by the Dangerous Goods Act, (as amended), to be dangerous. They are classified on the basis of immediate physical or chemical effects that may impact on people, property or the environment – explosive, flammable, corrosive, chemically reactive, highly combustible, acutely toxic, radioactive or infectious.
Dangerous goods class
The class allocated to a substance under the ADG Code 1.
Designated hazardous substance
A hazardous substance that is:
- listed on Safe work Australia Hazardous Chemical Information System (HCIS)
- above its lowest cut-off concentration
- determined to be a hazardous substance by the manufacturer or importer of the substance on the basis of NOHSC’s Approved Criteria for Classifying Hazardous Substances.
Hazardous substance
A substance that contains ingredients that may be harmful to health in the medium or long term.
Label
Information on a container which identifies the substance in the container, whether the substance is hazardous and provides basic information about the safe use and handling of the substance.
Safety Data Sheet (SDS)
Information sheets that provide technical information in relation to substances. These sheets are obtained directly from the manufacturer. Be aware of the possible differences between the manufacturer’s and generic SDS.
Risk
The probability (likelihood) of harm or damage occurring from exposure to a hazard, and the likely consequences of that harm or damage.
Version 1.0 – Last updated 22/6/2022