Safe storage and handling of hand sanitiser - particularly alcohol-based hand sanitiser - have become increasingly important in the face of the coronavirus (COVID-19) pandemic.
A rise in demand for hand sanitiser products in response to COVID-19 has driven the need for more awareness around its manufacture, storage and handling.
Alcohol-based hand sanitisers are classified as flammable liquids according to:
- The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) when stored and used in workplaces
- The Australian Dangerous Goods code (ADG code) when transported
This guide will step you through the key considerations for managing the health and safety risks associated with these hazardous chemicals, as outlined in the national Model Code of Practice: Managing risks of hazardous chemicals in the workplace.
The Three Classes of Hand Sanitisers During COVID-19
The Therapeutic Goods Association (TGA) developed three classes of hand sanitisers to assist manufacturers, suppliers and advertisers of hand sanitisers to comply with their regulatory obligations under therapeutic goods legislation.
The three classes of hand sanitisers are:
- General consumer products – these are classified as cosmetics, which include hand sanitisers or antibacterial skin preparations and are not regulated by the TGA
- Therapeutic Goods – these are classified as antibacterial hand hygiene products that must be evaluated by the TGA and included in the Australian Register of Therapeutic Goods (ARTG)
- Sanitisers with one of two specific formulations – these types of hand sanitisers are excluded from TGA regulations for the duration of the COVID-19 pandemic but they must be manufactured according to a strict formula as advised by the World Health Organization (WHO)
What is in Alcohol-Based Hand Sanitiser Formulations?
Alcohol-based hand sanitisers manufactured in accordance with WHO’s specified formulations contain very high proportions of either ethanol or isopropyl alcohol, both of which are considered dangerous goods.
Despite their classification as hazardous chemicals, Hand Hygiene Australia (HHA) recommends the use of alcohol-based handrub products because they are more effective against most bacteria and many viruses than either medicated or non-medicated soaps.
According to the WHO, alcohol-based hand sanitisers have excellent antimicrobial activity against gram-positive and gram-negative vegetative bacteria, and good antimicrobial activity against enveloped viruses, such as COVID-19.
Alcohol-based solutions containing 60 to 80 per cent alcohol are considered to be the most effective hand sanitisers.
“It has been well established that alcohols effectively reduce the bacterial counts on hands better than soap and water.”Effectiveness of different hand hygiene products in reducing bacterial counts after 30 seconds’ use
World Health Organization
What are the Hazards Associated With Manufacturing and Storing Alcohol-Based Hand Sanitiser?
Both ethyl alcohol (ethanol) and isopropyl alcohol (isopropanol) are classified as hazardous chemicals because they are flammable liquids.
As alcohol-based hand sanitiser products contain one of these ingredients, they present a fire hazard and have the potential to harm people and damage property. Ethanol and isopropanol can also cause severe eye irritation.
Alcohol-based hand sanitisers can also contain other ingredients that are classified as dangerous goods, such as hydrogen peroxide, an oxidiser that is corrosive to the skin and eyes.
GHS and ADG Classifications: Isopropanol and Ethanol Solution Sanitiser
|Sanitiser Formulation||Isopropanol (isopropyl alcohol)||Ethanol solution (95% ethyl alcohol|
|Flash Point||14 degrees Celsius||13 degrees Celsius|
|GHS Signal Word||Danger||Danger|
|GHS Hazard Statements||Highly flammable liquid and vapour||Highly flammable liquid and vapour|
|ADG Class & Packing Group (PG)||Class 3 PG II||Class 3 PG II|
|ADG Class Label|
An employee’s hand showing burns caused by hand sanitiser gel that ignited due to static electricity (Source: IOGP)
The IOGP alert went on to highlight the importance of ensuring that the hand sanitiser product has sufficient time to completely dry or evaporate before your hands come into proximity with a potential source of ignition such as light switches or cigarette lighters - or, as in this case - a seemingly harmless dry metal surface. Alcohol vapours from hand sanitiser products may be invisible, but they are also highly flammable, as any flambé chef will confirm.
In May 2020, an American fire department issued a warning that alcohol-based hand sanitiser left in a hot car had the potential to ignite and cause a fire inside the vehicle (assuming the product was in clear packaging and exposed to direct sunlight).
What are the Most Common Ignition Sources?
Due to the flammable nature of the vapours emitted by alcohol-based sanitisers, anyone who manufactures or stores alcohol-based sanitisers or their raw ingredients is obligated to control the risks of fire and explosion associated with the generation of flammable vapours.
Potential ignition sources are diverse, including:
- Naked flame (including pilot lights and cigarette lighters)
- Static electricity (especially in very low humidity environments)
- Any form of sparks (such as welding activity)
- Hot surfaces of vehicles or plant equipment
- Portable electrical equipment (such as tools, radios, and fans)
- Fixed electrical equipment (including power sockets and wiring)
Manufacturers, importers and suppliers of alcohol-based sanitiser products are often involved in the transfer of flammable liquids from one container to another. Even a relatively small amount of flammable liquid being transferred can generate a static electrical discharge. If flammable vapours are present, a fire or explosion is an all too possible consequence.
This is why storing flammable liquids such as alcohol-based sanitiser and its raw ingredients is such a crucial part of risk management in the workplace.
What are Our Legal Obligations When Storing Sanitiser?
Under the model Work Health and Safety (WHS) laws developed by Safe Work Australia (SWA), businesses involved in the manufacture, importation, storage or supply of hazardous chemicals, such as alcohol-based sanitiser, must comply with a specific set of requirements as set out in the model WHS Regulations.
The model WHS Regulations, along with the model WHS Act and model Codes of Practice, constitute the model WHS laws. As a national policy body, SWA leaves the implementation, regulation and enforcement of the WHS laws in each jurisdiction across Australia to the Commonwealth, states and territories.
This means that if you need help or advice regarding the WHS laws in your jurisdiction, you need to contact your local WHS regulator, such as:
Under the WHS laws, if you are a business that manufactures or imports hand sanitiser, you must:
- ensure, so far as is reasonably practicable, the product is without risks to health and safety, and
- correctly classify the product, and based on that classification, prepare correct labels and a safety data sheet (SDS) for the product.
You must also manage the risks to health and safety when handling and storing hand sanitiser.
How to Handle and Store Sanitiser
Any business involved in the storage of alcohol-based hand sanitiser product must consider the risks of fire and explosion.
Undertaking a dangerous goods assessment and putting the appropriate risk controls in place before preparing storage areas is the most effective way of:
- Identifying and managing those risks
- Ensuring compliance with WHS laws in your jurisdiction
- Implementing the most cost-effective storage options
SWA maintains guidance material for Managing risks of storing chemicals in the workplace, including a storage checklist that sets out the standard precautions a business should take and a detailed segregation chart showing which types of chemicals to keep separate and how far apart they should be.
The simple 12-step checklist is designed to help you develop an inspection program for your storage area.
Example workplace floorplan showing indoor and outdoor chemical storage areas used to separate incompatible chemicals Source: SWA Guidance material
The above workplace floorplan example demonstrates the importance of locating the internal storage area well away from exits and passage ways, ensuring escape routes are clear in the event of fire or other dangerous incident.
How to Store Flammable Liquids
SWA also developed guidance material specific to the Storage of flammable liquids, such as hand sanitiser, in the workplaces of small to medium businesses.
This guide is designed to be used in conjunction with the Managing risks of storing chemicals in the workplace guidance material and covers the risks posed by flammable liquids in particular.
It clearly demonstrates the process of identifying, assessing and managing those risks.
The guide will help you and your team to begin the risk management process by identifying any hazards present in your workplace storage area that could potentially harm your people.
You will learn how to recognise the three key elements associated with fire and explosions in the workplace - commonly referred to as the fire triangle.
Fire and explosions occur when the three elements of this fire triangle come together, namely:
- a fuel source - a flammable or combustible substance such as sanitiser
- a source of oxygen - typically air
- an ignition source - a source of energy sufficient to cause ignition, such as a pilot light, light bulb or static electricit
The Fire Triangle helps you identify hazards Source: SWA Guidance material
How to Comply With AS 1940:2017 The storage and handling of flammable and combustible liquids
Standards Australia developed AS 1940:2017 The storage and handling of flammable and combustible liquids which provides the minimum acceptable safety requirements for storage facilities, operating procedures, emergency planning and fire protection.
This Standard is designed to provide technical guidance related to the storage and handling of flammable and combustible liquids, such as alcohol-based sanitiser, in accordance with the risk management requirements of SWA’s Model Code of Practice and the underpinning legislation.
The general requirements and recommendations applicable to the storage of flammable and combustible liquids (in larger quantities than what is classified as minor storage) cover the following key considerations:
- Design safety and suitability
- Emergency provisions
- Minimisation of vapour hazards
- Ignition sources
- Separation distances, including:
- Separation to property boundary
- Separation to protected places on adjoining properties
- Adjacent occupancies storing flammable and combustible liquids
- On-site storage of other dangerous goods
Install AS 1940:2017-Compliant Sanitiser Storage Cabinets
Ensure the safe and secure storage of your stocks of alcohol-based sanitiser and other flammable liquids by using only sanitiser storage cabinets designed and manufactured to comply with AS 1940:2017 The storage and handling of flammable and combustible liquids.
STOREMASTA’s range of sanitiser storage cabinets are fully compliant with AS 1940:2017 and will help reduce your financial liability due to non-compliance.
Maintain a Hazardous Chemicals Spill Kit
Storing Class 3 Flammable Liquids within the workplace requires an Australian Standard-compliant Spill Containment System in Australian-made spill kits in a variety of sizes designed to fit into vehicle boots, equipment cabins and other workplace scenarios.
Provide PPE Storage Cabinets
AS 1940:2017 mandates the provision of Personal Protective Equipment (PPE) in areas where flammable liquids are used. Well-stocked PPE storage cabinets placed in strategic locations will ensure your staff can access the appropriate PPE when handling hazardous substances such as flammable liquids.
STOREMASTA’s range of PPE cupboards is manufactured in our Australian-based facility using high-quality sheet steel.
Install Adequate Dangerous Goods Signage
Ensure your people and any visitors are aware of the location and nature of any flammable liquids being stored on site. Installing the appropriate Dangerous Goods Labels and Hazard Signs is a crucial element of the overall strategy of managing the risks associated with storing hazardous chemicals such as sanitiser in the workplace.
How to Store Large Quantities of Sanitiser
Under WHS Regulations, once the quantity of a hazardous chemical such as sanitiser exceeds a specified threshold amount, you are required to placard the workplace, prepare a manifest and notify the regulator.
Placards are specific signs required at some workplaces under WHS laws. You need to display placards when storing hazardous chemicals above the placard quantities listed in the Placard and manifest requirements under the model WHS Regulations, or when storing hazardous chemical in bulk (inside containers holding more than 500L/Kg).
For GHS Category 2 / ADG Class 3 PG II Flammable Liquids such as ethanol and isopropanol, the placard threshold quantity is 250L.
A manifest is a written summary of hazardous chemicals with physical and acute toxicity hazards that are used, handled or stored at the workplace.
Manifests are only required where hazardous chemicals such as flammable liquids present at a workplace exceed the specified manifest threshold quantities. A manifest is mainly for emergency services when they respond to a workplace emergency such as a fire or chemical spill involving flammable liquids.
For GHS Category 2 / ADG Class 3 PG II Flammable Liquids such as ethanol and isopropanol, the manifest threshold quantity is 2,500L.
Placarding requirements are set out in Schedule 13 to the model WHS Regulations.
How to Store Manifests and SDS
Manifests and the relevant Safety Data Sheets (SDS) required to satisfy SWA’s chemical storage checklist should be safely and securely stored in a waterproof red Hazmat Box and SDS storage box, respectively.
Get a clear, step-by-step guide to the Hierarchy of Control Measures and learn how to minimise chemical hazards in your workplace, especially if you are storing or handling flammable liquids such as alcohol-based sanitisers on site.
Download this free eBook, Controlling Risks Associated With Hazardous Chemicals, to help identify the most effective risk control measures for your workplace and ensure you’ve implemented all the mandatory controls required under WHS legislation.