When you own a business or control a workplace that uses, handles, generates, or stores hazardous chemicals you have duties and legal obligations specified by the WHS Act and Regulations in your state or territory. This blog lists your duties relating to hazardous chemicals — so you can use it as the basis of your own risk assessment and control measures. To make things easy we’ve grouped the responsibilities into logical areas and built you a generic checklist — but remember to always apply legislation, Standards and Codes of Practice to the chemical hazards specific to your own workplace.
IMPORTANT: The WHS responsibilities outlined in this blog apply to the PCBU (Person Conducting a Business or Undertaking) who has a primary duty of care to eliminate (or minimise) all risks from hazardous chemicals in their workplaces and job sites.
The PCBU has a number of administrative responsibilities if they intend to have hazardous chemicals at the worksite. These duties include:
Risk Assessment - identify the chemicals introduced to the worksite and determine their physical hazards (hazard class) ie, are they flammable, oxidisers, or explosive? You also need to identify if there is any risk of chemical reactions and how you will ensure the stability of all the hazardous chemicals present at the site.
Safety Data Sheets - you need to obtain safety data sheets (SDSs) for every hazardous chemical held onsite. And they need to come from the actual manufacturer, importer, or supplier of the chemicals — a generic SDS is NOT acceptable. SDSs must be easily accessible to workers who have been trained in how to read and use them.
Register and Manifest of hazardous chemicals - all of your SDSs need to be collated into a Register of Hazardous Substances which lists the names of all the hazardous chemicals onsite. It needs to be updated as chemicals are introduced, changed, or discontinued. When chemical quantities exceed a threshold limit (specified in the WHS Regulations) you will need to prepare a Manifest of Hazardous chemicals in addition to the Register. The Manifest is a more detailed version of the Register and must be lodged with your local emergency response authority.
TIP: learn how to implement a chemical risk management methodology into your own workplace by downloading our free eBook Gas Cylinder Storage: compliance and safety requirements.
As PCBU you’ll also need to introduce operational procedures and work methods that minimise exposure to chemical hazards. Your workers will require training, instruction and supervision to ensure the procedures are implemented correctly. These will include:
Labels and Placards - correctly label all chemical containers and pipework. Then erect compliant warning placards and safety signage according to the hazard class of the chemicals and the type of work being carried out onsite.
Chemical Exposure Standards − make sure no person at the workplace is exposed to a hazardous chemical or substance that exceeds the relevant exposure Standards. Exposure standards define the safe airborne concentration of any substance.
Health Monitoring - actively monitor the health of your workers. If you are using chemicals that have severe health effects (eg, carcinogenic) you might need to implement a formal health monitoring program which includes doctors’ visits, testing and analysis of the blood, urine and other samples.
Ignition Sources − minimise stocks of flammable and combustible substances. You also need to identify and control possible ignition sources.
Spill containment − implement a spill containment system. This could include having compatible spills kits in stock, using bunding products, and installing chemical storage cabinets that have an inbuilt spill sumps.
Staff Training and Supervision − ensure your staff understand the hazard class and health hazards of the chemicals they use; implement an effective induction and training program; and provide adequate supervision
TIP: The WHS Regulation in your state/territory has strict requirements for installing HAZCHEM warning placards and safety signage. This extends to more than just the type of placard or pictogram being displayed, there are also requirements for the location, the height, visibility, and manner of installation.
Preparing for chemical emergencies including fires, explosions, and dangerous chemical reactions is essential if you are carrying out a business or undertaking. This will include:
Fire Protection − based on the hazards at the worksite provide sufficient fire protection, including emergency and safety equipment. This equipment especially includes firefighting equipment like fire hose reels, extinguishers, and sprinkler systems.
Emergency Planning − you must have an up-to-date emergency plan based on the chemical hazards at the worksite and the size of operation. It should be prepared in consultation with local emergency services who will require a copy as well as the Manifest of Hazardous chemicals outlined above.
TIP: Your staff need thorough training in chemical emergency procedures including regular drills and simulation activities where they are actually using emergency equipment.
Depending on the type of chemicals you are using, you may also need to modify your workplace (or notify the authorities) to ensure that bulk storage facilities for fuels and other hazardous chemicals are compliant and safe. This will include:
Stabilising bulk containers − ensuring that bulk containers and hazardous chemical stores (including chemical pipework and attachments) are completely stable with sufficient structural support.
Underground storage and handling − when decommissioning underground storage and handling systems make sure that associated risks continue to be managed and controlled while the tank is waiting to be decommissioned.
Abandoned tanks - notify the regulator in your state or territory if a tank that once held flammable liquids or flammable gases is being abandoned
REMEMBER: Work carried out on abandoned underground tanks and associated pipework is potentially dangerous because residual levels of flammable gases, liquids and vapours will remain.
Being in charge of a workplace that holds or handles hazardous chemicals is a big responsibility and this blog has only summarised your key responsibilities under the WHS Act and Regulations (current in your state or territory). If you would like more information on how to manage the risks associated with hazardous chemicals, feel free to download our free eBook by clicking on the image below: