If you’ve implemented any type of substitution control in your Class 3 Flammable Liquids storage and handling areas we recommend carrying out a follow-up risk assessment and review within a few weeks of the changes. Substitution controls can be very effective ways of improving chemical safety, but they still require regular monitoring because the hazard still exists. In many cases the hazard has merely been exchanged or transferred to another area of the business.
REMEMBER: All business owners and duty holders have a responsibility under Australian WHS Regulations to monitor and review hazard control measures to ensure they are actually working.
1. Substitution controls for flammable liquids
Substitution controls are risk control measures that find safer alternatives to the original hazard. Here are some HAZCHEM examples:
- Less flammable - switching to chemicals that are less flammable ie, using a combustible liquid (diesel) instead of a highly flammable liquid (petrol).
- Minimal hazard classes - changing to a chemical that does not have multiple hazard classes. Eg, changing to a chemical that is non-toxic and non-corrosive.
- Different form - changing to a chemical form that is less flammable and emits less vapours. Eg, using chemical solids, pastes, and pellets instead of liquids where possible.
- Different processes - changing the way a chemical is used or handled. Eg, applying paint with a roller or brush instead of spray painting.
- Diluted concentrations - diluting chemicals and reducing their concentration levels.
2. The problem with substitution controls
Substitution controls do have inherent problems and we’ve listed below some things to consider when carrying out a follow-up risk assessment.
Substitute chemical may be less effective
If the substitute chemical is not as effective as the original chemical this may create new hazards.
- Paints that take longer to dry — extended inhalation to paint fumes.
- Cleaning chemicals that require more effort — extended immersion in liquid chemicals.
- Solvents that take longer to dilute — extended inhalation of chemical vapours, greater risk of spillage.
When chemicals are less effective your workers might begin to take shortcuts or avoid using the new chemicals altogether.
The new chemicals may have compatibility issues with other substances onsite or have environmental hazards.
Working conditions may have changed
The substitute chemicals may require changes to machinery, tools and PPE. This could create additional exposure, tripping, falling and noise hazards.
The substitute chemical or product may create additional waste that is beyond your current handling and storage capabilities.
Staff training and awareness
When chemicals are changed, operating procedures and other administrative controls need to be updated. You may need to re-induct every worker and contractor onsite and provide extra supervision during the initial changeover.
3. Reviewing controls
When reviewing any type of hazard control you’ll want to first review the original hazard as well as looking for new hazards that may have emerged. The most effective risk assessment reviews involve a thorough inspection of work and storage areas and consult with the workers who are using the chemicals on a daily basis.
Begin your review by referring to your original risk assessment — the one that identified a chemical hazard and recommended a new substance to be introduced to replace a chemical. Let’s imagine you decided to use diesel fuel instead of petrol in all your vehicles and processes (because it’s less flammable and not classed as Dangerous Goods). Your review might consider:
- If petrol is still being used (or stored) anywhere onsite.
- If existing decanting, storage and handling systems been cleaned (or disposed of) and now suited to diesel fuel?
- If chemical signage, placards and labelling have been updated.
- If workers changed their PPE?
- If there’s been a reduction in fires, spills and exposure incidents?
Now look for new hazards. Consulting with your workers and talking to line supervisors is an important step in this process. Consider your:
- Supply chain — are new suppliers breaching site rules? are delivery times different? do you have to keep larger quantities of the new chemical onsite?
- Storage areas — are the new chemical containers flimsy or low quality? are the new chemicals stored in containers that don’t fit in your safety cabinets?
- Emissions — is diesel exhaust (which has different emission characteristics to petrol) causing issues in the workplace?
4. Continuous improvement
Chemical safety compliance involves constantly looking for safer ways of doing business and is not a job that is ever considered ‘done’. When you use and store Class 3 Flammable Liquids there is an expectation that your business will always be:
- Looking for chemical alternatives that are less flammable, less toxic and less corrosive.
- Analysing your supply chain and looking for ways to keep less chemicals onsite.
- Reviewing work methods and eliminating processes that are unsafe or inefficient
- Updating flammable liquids storage equipment as it begins to age, or as safer models are released to the market.
Chemical substitution is not always possible, so if you want accurate, up-to-date information about minimising flammable liquids storage risk, please download our free eBook Essential Considerations When Storing Flammable Liquids Indoors. Our detailed eBook walks you through the steps required to assess your compliance risk, choose a suitable indoor safety cabinet, and ensure it is installed and being used correctly. Download and read it today by clicking on the image below: