Are you running a Victorian business that handles Class 3 Flammable Liquids or any class of dangerous goods? Unlike other states and territories, Victoria has yet to adopt the Model Act and Regulation that was issued by Safe Work Australia. This means that Victorian businesses must comply with their own set of WHS laws, instead of following the harmonised legislation that the rest of Australia follows. Victoria’s WHS laws includes a range of requirements that specifically apply to dangerous goods storage and handling, as well as occupational health and safety. In this blog, we’ll help you meet your flammable liquids compliance obligations by listing key legislative requirements for Victorian businesses and workplaces that carry flammable liquids.
REMEMBER: If your business carries certain quantities of Class 3 Flammable Liquids or any class of dangerous goods (above manifest quantity), you are required to notify WorkSafe Victoria using the proper form.
Work Health and Safety Laws In Victoria
As we’ve mentioned, workplace health and safety in Victoria is regulated by WorkSafe Victoria. Your obligations to provide a workplace and job site that is safe and properly managed is defined in the following legislation:
- Occupational Health and Safety Act 2004
- Occupational Health and Safety Regulations 2017
- Dangerous Goods Act 1985
- Dangerous Goods (Storage and Handling) Regulations 2012
Of course, the legislation requires you to employ specific risk management practices on all the hazards at your workplace, but the state of Victoria also has additional requirements for the storage and handling of all Dangerous Goods including Class 3 Flammable Liquids. These requirements can be found in the essential Codes of Practice.
Workplace health and safety is regulated by WorkSafe Victoria which offers a range of resources for businesses that carry dangerous goods.
Essential Codes of Practice
Victoria’s Dangerous Goods legislation can be best understood and implemented by following the requirements of the following Codes of Practice:
Code of practice: The storage and handling of dangerous goods - this is essential reading because it walks you through the Dangerous Goods Act and Regulations and provides practical guidance about how to comply. Information included in the Code of Practice includes duties of manufacturers and suppliers, duties of occupiers, risk management, risk control duties, fire protection systems, and emergency preparation and response.
ADG Code – Victorian businesses and workplaces that carry dangerous goods must refer to the Australian Dangerous Goods (ADG) Code. This is because the Dangerous Goods Act and Code follow the ADG Code’s chemical classification system. This includes hazard classes, packaging sizes and segregation requirements.
Critical requirements of the Code
In this section of the blog, we’ll introduce you to some of the critical requirements of the Code of practice: The storage and handling of dangerous goods.
Remember, this is just a brief overview of the Code to help get you started.
1. Classification
Using the ADG Code, determine the type (and quantities) of dangerous goods at your worksite. This should be done first, because many of the requirements of the DG Regulations are determined by:
- The classification of the chemicals (eg, Class 3 Flammable Liquids)
- Size of the containers you are using (eg, IBCs)
- Aggregate quantities of other Dangerous Goods held onsite (eg, compressed gases in cylinders).
2. Consult With Your Workers
If you want to create and maintain a compliant workplace, it’s important that you consider the people who will be directly handling and managing your dangerous goods. Consult with the staff, supervisors and contractors who will be in contact with the flammable liquids at your worksite. You should get their input and advice when introducing new chemicals, ordering storage equipment and PPE, or developing safe handling procedures.
3. Induction and Training
Everyone on the job site must be aware of the hazards associated with the flammable liquids — as well as any other dangerous goods they may encounter. Through proper inductions and training, all people who may handle flammable liquids should know how to stay safe, use PPE, and follow emergency procedures. This includes your workers, contractors and visitors to your worksite.
Staff, supervisors, contractors and site visitors should undertake the proper inductions and training.
4. Safety Data Sheets
When bringing a new chemical product into your operations, you must first consider the hazards this chemical will pose to your operations. Therefore, you must obtain a current copy of a substance’s Safety Data Sheet (SDS) on — or before — the hazardous chemical is brought onto the worksite.
The SDS for each chemical product must be kept in a Register (additional to the one required under the OHS Act). It should also be readily accessible to workers in the immediate area.
IMPORTANT: Store your Safety Data Sheets in a sturdy document holder that is attached to your flammable liquids cabinets or outdoor stores. This will prevent your sheets going missing or not being accessible to staff or emergency crews.
5. Safety Signs, Placards and Markings
Any dangerous goods in your organisation must retain their official markings — according to the ADG Code. Your worksite is also required to display certain safety signs and warning placards (depending on the aggregate quantities of your stored chemicals).
6. Risk Management
For any business that carries dangerous goods, risk management is an essential consideration. Make sure you have a clear risk management process and plan in place that includes WHS duty holders, risk assessments, hazard controls and review systems.
7. Isolation and Stability
The isolation and stability of your Class 3 Flammable Liquids is crucial in ensuring a compliant workplace. Using correct segregation distances and barriers, keep your flammable liquids (and other dangerous goods) stable and away from:
- Incompatible and reactive substances
- Ignition sources
- Traffic and impact hazards
- People and property
8. Spill Containment
Have spill containment equipment, systems and procedures in place. This includes compliant bunding for the volume of chemicals that you’re storing, housekeeping procedures for handling and storage areas, and planned emergency responses and clean-up of uncontrolled releases or dangerous spill incidents.
Having an effective spill containment system is integral for the safe handling and storage of flammable liquids in the workplace.
9. Decanting and Transfer
As flammable liquids can easily ignite and emit hazardous vapours, the decanting and transfer of these chemicals must be carried out in a safe and compliant manner. Only use the proper equipment and safety procedures when filling, loading, pumping, or pouring Class 3 Flammable Liquids (and other dangerous goods).
10. Ignition sources
Flammable liquids must never be handled or stored close to workplace ignition sources. Ignition sources can range from the obvious (ie. welding equipment) to other sources which may not immediately raise alarm with untrained workers (ie. power points). To create a safe workplace, it’s important that organisations identify and manage ignition sources in and around dangerous goods storage and handling zones — and other hazardous areas.
Isolate ignition sources from any workplace areas which carry or store flammable liquids.
11. Ventilation
You must ensure that your workplace has provided sufficient mechanical or natural ventilation to prevent flammable, explosive and asphyxiant atmospheres. Your workplace should also monitor and maintain chemical concentration levels to meet the required standards.
12. Site Security
When dealing with any type of dangerous goods, it’s important that only trained and authorised staff have access to chemicals. Make sure that your organisation has the proper equipment and systems in place to prevent unauthorised people from accessing the dangerous goods onsite. Failure to do so could result in the flammable chemicals being stolen, misplaced or misused — which will increase risk for your workplace.
Security measures, such as ISO locking bars, are required for flammable liquids stores to ensure that unauthorised entry does not occur.
13. Fire Protection Systems
You must ensure that your fire protection system is designed and constructed to suit the chemical quantities as well as the conditions in which they’re stored. Any firefighting equipment must also be compatible with the flammable liquids (and dangerous goods) that you’re carrying in your organisation. Your fire protection system must be properly installed, as well as regularly test and maintained.
14. Emergency Plan
Every Victorian (and Australian) business must have an up-to-date emergency plan in place. This plan must also be regularly reviewed and tested to ensure that all potential hazards are adequately covered by your emergency response.
15. Manifest of Dangerous Goods
If your quantities of Class 3 Flammable Liquids (and other dangerous goods) exceed the Manifest Quantity (outlined in Schedule 2 of the DG Regulations), you must prepare a Manifest of Dangerous Goods. The Manifest must be kept on your premises in a place where it’s readily accessible to emergency services who may attend your site.
16. Notification of Storage and Handling
You should also notify WorkSafe Victoria (using the correct online form) if you exceed manifest quantities of flammable liquids and dangerous goods. While notification was previously required every five years, it’s now required by WorkSafe Victoria at least every two years.
REMEMBER: Your duties and responsibilities are directly linked to the class of dangerous goods, packaging sizes and aggregate quantities held onsite. You may require the services of a Dangerous Good Consultant to assist you in this classification process.
Maintaining Chemical Compliance In Victoria
Of course, we could never hope to condense your flammable liquids compliance obligations down to a single blog post. Instead, we hope we’ve given you a broad overview of the ways in which you can meet your compliance obligations in Victoria. To help you store your flammable liquids in a safe and compliant manner, we encourage you to download and read our free eBook Essential Considerations When Storing Flammable Liquids Indoors. No matter what state or territory your business operates from, our eBook will help you to minimise your Dangerous Goods storage risks. Why not use our guide as the basis of your next risk assessment and compliance audit?
