Flammable Liquids Compliance (Part 3) Navigating the WHS Regulations 

Aug 8, 2019 Posted by Walter Ingles

This blog is part 3 in our series of blogs on flammable liquids compliance. In today’s blog we take a closer look at the WHS Regulations and provide examples of how they could apply to the Class 3 Flammable Liquids (and other Dangerous Goods) at your worksite. STOREMASTA always recommending undertaking a full risk assessment and regular chemical safety audits to support your compliance efforts. 

 

IMPORTANT:  You must comply with all areas of the WHS Regulations that apply to your business. Ignorance or lack of understanding is not considered a valid reason for non-compliance. 

Understanding the WHS Regulations 

The WHS Regulations help you fulfil your obligations to provide a safe workplace by outlining specific actions, hazard controls, administration and licences that your business must either undertake or obtain. It provides actual ways of minimising the risks associated with specific hazards. 

PLEASE NOTE: This blog summarises the key requirements of the WHS Regulations but it is not a complete list. Always carry out your own risk assessment and if you are having difficulties, engage the services of a qualified Dangerous Goods specialist. 

Risk Management 

Sections 32-38 of the WHS Regulations make the concept of risk management a legal requirement in Australia. All businesses are required to identify hazards and (if they exist) take steps to eliminate or control them. More specifically if your business carries flammable liquids you must: 

  1. Identify chemical hazards. Take steps to fully identify reasonably foreseeable hazards that could risk the health and safety of your people, the workplace generally and the natural environment. Eg, you use petrol at your workplace and identify that it is highly flammable, carcinogenic, irritating to the skin and eyes, as well as an aspiration hazard. It is dangerous to aquatic life. 
  2. Eliminate and control hazards. If hazards exist at the workplace you must do all you can to eliminate them. If this cannot be achieved, measures must be put in place to minimise the hazard. Eg, you use diesel fuel at your workplace to fuel the forklifts. You eliminate the need for carrying diesel fuel onsite by switching to electric powered forklifts. 
  3. Hierarchy of Controls. If you are unable to completely eliminate a hazard, you must look for suitable hazard control measures using the Hierarchy of Controls (substitution, engineering, isolation, administrative, PPE controls). Eg, you use highly flammable liquids for testing processes in the lab. Containers are regularly left on bench tops. You install a dual skinned flammable liquids cabinet to store the chemicals when not in use. You also issue compatible gloves, goggles and aprons. 
  4. Review and maintain hazard controls. After a hazard control measure is implemented it must be reviewed and maintained to ensure it remains effective, fit-for-purpose and used correctly. Eg, you carry out a workplace inspection and notice an indoor flammable liquids cabinet has been moved outside. The cabinet is not able to be secured from strong winds, rain and the hot sun. You take corrective action and return the cabinet indoors. 

 

General workplace management 

There are a number items in Sections 39-55 of the WHS Regulations that could apply to Class 3 Flammable Liquids including: 

  1. Staff training. Your workers must know how to carry out their jobs safely and understand the hazards they are likely to face each day. Eg, you provide one-on-one training with workers who unpack and distribute chemical orders containing flammable liquids.  
  2. Workplace facilities. Ensure the workplace is maintained so that workers and contractors can safely undertake their duties. Eg, you install a flammable liquids cabinet to stop workers from leaving containers of fuel lying on the ground. 
  3. First Aid. You must provide suitable first aid equipment in the workplace and make sure that each worker and contractor has access to the equipment. Eg, based on a risk assessment you install an emergency decontamination station next to the flammable liquids store. The station has a drench hose, eyewash and shower unit. 
  4. Personal Protective Equipment (PPE). If you require your workers to use and wear PPE when handling flammable liquids, the equipment must be suited to the chemicals, fitted correctly and stored and maintained in proper working order. Workers must also be properly trained to use the PPE correctly. Eg, you issue safety goggles and gloves to workers who decant flammable liquids into portable containers. You install a dedicated storage cabinet to keep the PPE clean and always available for use.  
  5. Airborne Contaminants. You must keep chemical concentration levels in the breathing zones of workers within workplace exposure standards. Eg, you use a number of flammable liquids which have a workplace exposure standard. You calculate the likely airborne concentrations and these appear in a high risk range. You undertake air quality testing. 
  6. Flammables and ignition sources. You must isolate ignition sources from flammable substances and minimise the quantities of flammables and combustibles kept onsite. Eg, you change your ordering system so you can make daily purchases of flammable liquids — this reduces chemical stocks kept onsite. 

 

Hazardous Chemicals 

Sections 328-418 directly relate to Hazardous Chemicals including flammable liquids. Requirements include: 

  1. Labelling. You must ensure that all chemical containers are properly labelled, including portable containers. Eg, you use portable containers that are already labelled and used exclusively for holding decanted diesel fuel. 
  2. Register of Hazardous Chemicals. You must keep a list of all hazardous chemicals carried onsite and include a copy of each Safety Data Sheet (SDS) in the Register. Eg, you put your Register of Hazardous Chemicals in a document box and attach to your flammable liquids cabinet. 
  3. Manifest of Hazardous Chemicals. When chemicals reach certain quantities you are required to prepare a Manifest of Hazardous Chemicals to assist emergency responders in the event of an emergency. Eg, you carry 2,500 litres of petrol onsite and prepare a Manifest. 
  4. Safety signs. If you carry certain quantities of chemicals, you must display the HAZCHEM placard at the entrance to your worksite. All chemicals must also have warning signs displayed near the hazards. Egyou carry more than 250 litres of unleaded petrol onsite, so you display the HAZCHEM placard.
  5. Fires, explosions, reactive and unstable chemicals. You must have measures in place to ensure an ignition source (or other incompatible substance) is not brought near flammable, explosive or reactive chemicals. You must take measures to keep chemicals stable. Eg, you use dedicated safety cabinets to store incompatible hazard classes and keep them apart.
  6. Chemical spills. You must have measures in place to prevent, contain, or manage chemical spills. Eg, you store your flammable liquids in a compliant flammable liquids cabinet that has a liquid tight spill containment sump.
  7. Storage and handling. You must ensure that chemical storage equipment and systems are installed correctly and only used for the purpose in which they were intended. Eg, a safety audit identifies a flammable liquids cabinet that is now being used to store acids in the lab. Someone has covered the original Class 3 Flammable Liquids Diamond and written ACID over the top. This cabinet is now noncompliant and is a safety risk. 

Next steps 

Are your Class 3 Flammable Liquids stored legally and safely? If you are not 100% sure, why not download our free eBook Essential Considerations When Storing Flammable Liquids Indoors? It’s the definitive guide to choosing a compliant flammable liquids cabinet. It also provides advice on how to install it in a way that complies with the Australian Safety Standards and the WHS Regulations. Download it now by clicking on the image below: 

 

Essential Considerations when Storing Flammable Liquids Indoors download Free eBook

Read the whole series 

Part 1 - Flammable Liquids Compliance (Part 1) legislative framework in Australia 

Part 2 - Flammable Liquids Compliance (Part 2) applying the WHS Act 

Part 4 - Flammable Liquids Compliance (Part 4) using Codes of Practice 

Part 5 - Flammable Liquids Compliance (Part 5) meeting Australian Safety Standards 

Part 6 - Flammable Liquids Compliance (Part 6) other guidance materials 

 

Walter Ingles

Walter Ingles Compliance Specialist

Walter is STOREMASTA’s Dangerous Goods Adviser. He loves helping businesses reduce the risk that Dangerous Goods pose upon their employees, property and the environment through safe and compliant dangerous goods storage solutions.

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