Gas cylinders are used for a multitude of tasks, but they are dangerous goods that must be stored and handled in a way that reduces risk. When working with gas cylinders, it’s important that safety and compliance are considered, including how to properly document the chemicals that you have onsite so that staff or emergency services can quickly access information. In this post, we’re looking at gas cylinders in the workplace – and answering the question ‘Do you need a manifest for gas cylinders?’
In Australia it’s essential for any workplace that uses, handles or stores hazardous chemicals to have a hazardous chemical register. This hazardous chemicals list must include up-to-date copies of safety data sheets (SDS) and be located somewhere your staff can easily grab the information in an emergency. The hazardous chemical register is primarily for onsite staff.
But when quantities of hazardous chemicals exceed threshold limits set by WHS Regulations, your workplace is required to also have a hazardous chemicals manifest in place. The manifest is primarily for emergency services and their crews responding to an emergency.
The chemical manifest contains essential information about the chemicals at your site and includes:
Your chemical manifest must be in a highly visible and accessible location, which is determined in conjunction with local emergency services. Remember to mark the location of your manifest on your site plan, so that the information can be found promptly in an emergency.
REMEMBER: The model WHS Regulations states that a manifest is required if the workplace exceeds manifest quantity for the Schedule 11 hazardous chemical or group of Schedule 11 hazardous chemicals. Refer to your local WHS regulations for further details.
Compressed gases in cylinders are classed as hazardous chemicals. Therefore, if you’re keeping manifest quantities at your workplace, you require a hazardous chemicals manifest for your gas cylinders and other substances.
You can find out more about the manifest quantities from Safe Work Australia or your local regulator.
Any hazardous chemical that are kept in quantities exceeding threshold limits must have an up-to-date Hazardous Chemicals Manifest.
In relation to gas cylinders, you will require a hazardous chemicals manifest if your worksite has more than:
REMEMBER: There are threshold limits for all hazard classes, this article is general guide and relates mainly to gas cylinders. Always check the relevant WHS Regulation in your state or territory plus applicable Australian Standards before making WHS decisions.
Your hazardous chemicals manifest is a written summary of hazardous chemicals used, handled or stored at your workplace that are above manifest quantities.
The manifest will include references to the acute and toxic properties of the chemicals (including Class 2.3 toxic gases) and other physical hazards (like Class 2.1 Flammable gases), plus the quantities kept onsite.
IMPORTANT: To learn more about manifests, see Schedule 12 of the model WHS Regulations. Please note that South Australia has a separate dangerous substances licencing scheme, so refer to SafeWork SA if you operate in that state.
The manifest for gas cylinders and other hazardous chemicals must include:
You must include the proper shipping name, maximum quantities ever held onsite, and the location of each chemical. For gas cylinders you also need to include the UN number plus the dangerous goods class, division and packing group.
To calculate quantities, use the maximum capacity of the gas cylinder or container housing the substance. For gas cylinders, you will specify how many individual cylinders are onsite as well as the total amount of gas held in litres.
Empty cylinders must also be included as they must always be treated as full cylinders according to AS 4332 - The storage and handling of gases in cylinders. Use the maximum capacity of the cylinders in your calculations.
Your gas cylinder manifest must be updated as soon as possible if the amount and types of chemicals at the worksite changes. You’ll also need to notify your emergency service provider.
REMEMBER: Safety at your site includes a range of measures from elimination and substitution controls, through to engineering solutions to contain and isolate chemicals. Administrative controls and personal protective equipment are also part of the Hierarchy of Controls, which must all be considered when creating a safe, healthy workplace.
Your site plan is a critical document that should be drawn to scale so emergency responders can clearly identify location points, site facilities, and features of the surrounding area. It’s essential that the document is easy to understand, so provide a clear legend system that supports the written information provided.
When creating your site map, you’ll need to develop a visual reference to all the hazardous chemicals onsite, including the cylinder stores. When drawing in your cylinder stores make sure you identify hazard classes the way they are segregated within the store. Empty cylinders will also need to be identified. Make sure you show true north on your map so emergency services can quickly locate your stores and other important sites.
IMPORTANT: A site plan of the worksite clearly identifying the location points of the hazardous chemicals and cylinder stores.
When you’re storing gas cylinders or other hazardous chemicals in the workplace, your site map should also indicate a range of locations.
These site map locations should include:
IMPORTANT: The location of Class 2.3 Toxic Gases (as well as other acute toxic substances) should highlighted on the site map, we suggest using the skull and crossbones pictogram which is instantly recognisable.
Your manifest of hazardous chemicals is best stored as close as possible to the main entrance in a robust document holder.
If you have submitted the manifest to emergency services, it should be in the mutually agreed location. Make sure your document holder can withstand an industrial environment: we suggest something made of polyethylene that is corrosive-resistant and hardwearing.
Because the manifest is primarily for use by emergency responders, don’t overload the document storage box with all the safety data sheets (SDSs). These should be stored separately in your register of hazardous chemicals, which should be stored in a safety data sheet holder which is freely accessible to staff. We recommend attaching your safety data sheet holder to your gas cage or storage area.
IMPORTANT: In certain Australian States and Territories, you must submit your hazardous chemicals manifest to the primary emergency service organisation. Check the WHS Regulation current in your state or territory for specific guidelines.
If you need more information about the legal requirements for handling and storing gas cylinders at your workplace, we recommend downloading our free eBook Gas Cylinder Storage: Compliance and safety requirements. We outline the control measures required by AS 4332 - The storage and handling of gases in cylinders. Get your copy today to learn more.