You’ve carried out a full risk assessment and implemented HAZCHEM control measures to minimise the risk to the health and safety of your workers. But your responsibilities don’t end there. According to the WHS Regulations you also need to ensure that any ‘risk control measure is maintained so it remains effective’. This blog takes a look at Section 37 of the Regulations — 'maintenance of control measures' and exactly what that means for your business.
1. Ensuring controls are fit for the purpose
Your first responsibility is to ensure that the chemical control measures you have implemented are (and remain) fit for the purpose. In terms of chemical hazards, a control measure that is fit for purpose is compatible with the hazard class of the chemical and aligns with the chemical’s Safety Data Sheet (SDS) (as well as the relevant Australian Standards). Examples include:
- Engineering controls required by Australian Safety Standards. Eg, flammable liquids cabinet made from double-walled sheet steel.
- PPE controls recommended by a Safety Data Sheet (SDS). Eg, impervious gloves made from polyvinyl alcohol or teflon when handling a flammable, corrosive solvent.
- Isolation controls recommended by an SDS. Eg, keeping a highly flammable liquid in a tightly closed container and under 30°C.
At the time of implementation these chemical controls may be fit for the purpose, but if an SDS or Australian Standard is updated, quantities of the chemicals increase, or even the way the chemical is used changes — the controls you have in place may no longer be suitable.
One of the most common issues we find at the worksites of our clients, is chemical stores and safety cabinets that were purchased many years ago (and still in use) but no longer meet the requirements of Australian Safety Standards.
EXAMPLE 1: You’ve been storing paints and jerrycans of petrol in an old flammable liquids cabinet that was purchased 15 years ago. Even though the cabinet was purpose-built and has the correct signage it does not have doors that automatically close. It is a requirement of AS1940:2017 –-The storage and handling of flammable and combustible liquids that ‘cabinet doors shall be self-closing, close-fitting and held shut automatically by catches at two or more points.’ This cabinet is no longer ‘fit for the purpose’ and would not comply with the WHS Regulations.
EXAMPLE 2: You’ve been storing 200 litres of paints in a dedicated flammable liquids cabinet, purpose built with self-closing doors. It is 2.2 metres tall. You increase your stocks to 260 litres. According to AS1940:2017 a cabinet holding more than 250 litres of flammable liquids cannot be more than 2 metres high. This cabinet is no longer ‘fit for the purpose’.
2. Suitable for the nature and duration of the work
Your next responsibility is to ensure that the controls remain suited to the nature and duration of the work. A hazard control measure like PPE might be suitable for a quick task that lasts only 2 minutes but the same item of PPE may not be able to withstand 3 hours of continuous use. Here are some examples:
EXAMPLE 1: You transfer several drums of chemicals to an outdoor area. You have been using a drum dolly to hold and transport the chemicals around the warehouse. An inspection reveals sun damage to the dolly after only a few months of outdoor use. After checking the original specs you realised the dolly was never designed for outdoor use and has no UV protection. The dolly is not suited to the nature of the work.
EXAMPLE 2: Your cleaning staff use a new corrosive floor stripper to clean the floors of the warehouse, despatch dock, and factory every day. You issue chemical resistant gloves and aprons from your usual supplier but discover that the gloves and aprons are failing after only 1-2 hours of use. While they are suited to the chemical under light use, they cannot withstand a heavy workload. The gloves and aprons are not fit for the duration of the work.
3. Installed, setup and used correctly
Finally you will need to have systematic review procedures in place to ensure that each chemical control measure has been installed, setup and being used correctly. Sometimes problems don’t emerge until after a piece of equipment, machine, or safety device is actually in use. Consider these examples.
EXAMPLE 1: You have purchased a gas bottle cage and have your maintenance crew install it outside. But a site inspection indicates the cage is located within the turning circle of delivery vehicles and has no protection from vehicular impact. It is a requirement of AS4332:2004 — The storage and handling of gases in cylinders that cylinder stores have bollards, crash barriers or other protective devices when there is a risk of damage from vehicles. The gas bottle cage has not been installed correctly.
EXAMPLE 2: You create a Register of Hazardous Chemicals and purchase a waterproof document box to attach it to the chemical stores. But the box only contains a list of the chemicals in the store and does not include any of the Safety Data Sheets (SDS). The Register of Hazardous Chemicals has not been setup correctly.
EXAMPLE 3: You have purchased a gas bottle trolley for transferring cylinders around the job site. The trolley is manufactured to Australian Standards and is complete with straps to restrain the cylinders while on the trolley. After a safety audit you notice that some workers are transporting cylinders without properly securing the cylinders with the straps. The gas bottle trolley is not being used correctly and is likely to fail as a control measure.
The best way of ensuring that your chemical risk control measures are installed, used, and maintained correctly is to implement a 4-STEP risk management methodology. Such a methodology has review mechanisms to ensure each of your control measures are working properly and remain fit for the purpose.
We encourage you to download our free eBook How to manage the risk of Hazardous Chemicals in the workplace which explains STOREMASTA’s own in-house methodology IDENTIFY - ASSESS - CONTROL - SUSTAIN. Our eBook demonstrates how to use the methodology and includes practical tools and templates so you can get started right away. Download and read it today by clicking on the image below: