How long should I wait before reviewing flammable liquids control measures? 

Jan 19, 2021 Posted by Walter Ingles

A lot of people forget that flammable liquids cabinets, chemical decanting equipment, and items of PPE are actually hazard control measures and not an off-the-shelf purchase. This high-tech equipment should only be purchased and installed to address specific hazards that have been identified in a risk assessment. In today’s blog we’ll be explaining the legal requirement to periodically review your flammable liquids cabinets — and other engineering control measures (spill bunding, decanting systems, outdoor chemical stores). We unpack what the law says, and how that looks at an operational job site. 

REMEMBER: Reviewing hazard control measures is an essential requirement under Australian WHS Regulations in every state and territory. 

What the law says 

Any business holder who has introduced a hazard control measure to minimise health and safety risks has responsibilities in three different sections of the Model WHS Regulations. We’ve listed them here in brief, but we’ll unpack them in detail below (using examples). 

  1. Section 37: to ensure hazard control measures are maintained so they remain safe, effective, fit for purpose, installed and working correctly. 
  2. Section 38: to carry out a review if there are indications that a hazard control measure isn’t working, or if new hazards have emerged. 
  3. Section 352: to review chemical hazard control measures at least once every 5 years — or if: 
    • Chemical’s Safety Data Sheet (SDS) is updated 
    • Register of Hazardous Chemicals is updated 
    • There are indications that workers may have developed adverse health conditions.  

 

Carrying out hazard control reviews 

To comply with work health and safety legislation, Australian businesses must review their flammable liquids storage and decanting equipment at least once every 5 years WHS Regulations Section 352 (d). But in daily practice, it is unlikely that you would wait this long. 

1. Post installation checks

A flammable liquids cabinet or decanting system should be reviewed within a few days of installation. We always recommend post installation checks that include: 

  • Installation and setup — is the cabinet on a level surface and not blocking an emergency access point? Are the self-closing doors working? Are warning signs clearly visible? Is there enough lighting in the area? Are there ignition sources or power points within 3 metres of the cabinet? 
  • Correct usage — has the cabinet been loaded past the capacity rating? Are there chemicals being stored in the spill compound? Are incompatible substances also inside the cabinet? 
  • Fit-for-purpose — is the cabinet big enough for the chemical quantities? Is an indoor cabinet being used outside?  

2. Review triggers

Section 38 and 357 of the Regulations outline a range of incidents that must trigger a review of your flammable liquids gear. These include: 

Section 38 Model WHS Regulations 

  • Something isn’t working — is there any evidence that vapours or liquids are leaking from the cabinet? Eg, people working near the cabinets complain of headaches and a fumey smell. 
  • Changes to the workplace — have chemical quantities increased since purchasing the flammable liquids cabinet? Eg, production schedules increase, and more chemicals are being ordered, there are times when chemicals are left outside overnight. 
  • New hazards — has a new (or previously unknown) hazard been identified? Eg, an electrical contractor installs a power point next to the flammable liquid’s cabinet. 
  • Consultation — has consulting with chemical handling staff made you aware of additional safety issues? Eg, workers are having trouble carrying out decanting processes while using their PPE. 
  • Request from HSE Representatives — has an appointed HSE Representative made a formal request for a review? Eg, workers are concerned the chemical decanting equipment has deteriorated and needs replacing. 

Section 352 Model WHS Regulations 

  • Safety Data Sheets (SDSs) — has there been any changes to a Safety Data Sheet (SDS) or the Register of Hazardous Chemicals? Eg, a new chemical is introduced to the job site. 
  • Health Monitoring — is there any evidence that a worker may have contracted a disease, injury, or illness from chemical exposure? Eg, a worker develops chronic asthma and a doctor recommends health testing for chemical metabolites. 
  • 5 years — has it been more than 5 years since you carried out a review? Eg, you must carry out a risk assessment review. 

 

Ongoing compliance checks 

The best way to ensure you are always in full compliance with the WHS Regulations is to carry out regular inspections and safety audits. These can include: 

  • Housekeeping checks — chemicals put away, lids and caps in place, cabinet doors not propped open, decanting containers labelled properly. 
  • Integrity checks — cabinet doors working correctly, no dents or structural damage to cabinet walls and seams, lube stations pumping at correct capacity. 
  • Maintenance — replacing missing or damaged parts. 
  • Compliance checks — ensuring signage is in place, cabinets aren’t overloaded, ignition sources are not in decanting areas. 

 

Next steps 

If you’re about to review your flammable liquids storage areas, we encourage you to download our handy eBook Essential Considerations When Storing Flammable Liquids Indoors. Use it as the base of a compliance review, site inspection, or risk assessment — and best of all it’s completely free. Download it today. 

Essential Considerations when Storing Flammable Liquids Indoors download Free eBook

Walter Ingles

Walter Ingles Compliance Specialist

Walter is STOREMASTA’s Dangerous Goods Storage Specialist. He helps organisations reduce risk and improve efficiencies in the storage and management of dangerous goods and hazardous chemicals.

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