You’ve carried out a full risk assessment and implemented HAZCHEM risk controls to reduce health and safety risks. But your responsibilities don’t end there. According to the WHS Regulations, you must ensure that any ‘risk control measure is maintained so it remains effective’. This post looks at Section 37 of the WHS Regulations and unpacks what 'maintenance of control measures' means for your business through ensuring controls are:
Chemical risk controls can be any type of control that reduces the risks associated with your dangerous goods and hazardous chemicals.
This could be safety cabinets, outdoor chemical stores, bunding, gas cages, gas cylinder trolleys, bunded drum dollies or any other solution that can help you manage the hazards of your onsite chemicals.
Your control measures, such as this outdoor IBC chemical store, must be maintained for compliance and safety.
The selection, installation and use of your chemical risk controls is only the beginning of your compliance journey. Remember to pay attention to the inspection and maintenance of your controls to ensure they effectively reduce risk for your operations.
We’ll now look at the 3 key points involved with maintaining HAZCHEM risk controls to meet your WHS compliance obligations.
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 fit for purpose control measure is one that is compatible with the hazard class of the chemical. This control should align with the recommendations in the chemical’s safety data sheet, as well as the requirements of the relevant Australian Standard/s.
To illustrate how chemical controls can be fit for purpose, we’ve included some general examples below.
Examples of fit for purpose controls that can assist with compliance with WHS laws include:
At the time of implementation, these chemical controls may be fit for the purpose, but if things change (and they always do) the controls you have in place may no longer be suitable. Such changes may include the updating of a safety data sheet or Australian Standard. It may also include a change in the quantity of chemicals that you have onsite or even the way the chemical is used during your work processes. Therefore, remember that controls must remain fit for purpose by continually inspecting and reviewing your HAZCHEM risk controls to ensure safety compliance.
Storage requirements for dangerous goods, such as flammable liquids or paints, may change over time. It's important to keep up with any legislative changes or Australian Standard updates to ensure continued compliance.
REMEMBER: 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 the current Australian Standards.
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:
Your personal protective equipment is a risk control that must be suitable for the nature of the work.
Finally, you will need to have systematic review procedures in place to ensure that each chemical control measure has been installed, set up and used correctly.
Sometimes problems don’t emerge with chemical risk control measures until after the equipment, machine or safety device is in use.
Consider these examples of how the improper installation, set up or use of risk controls can impact the safety of your workplace:
The best way of ensuring that your chemical risk control measures are installed, used, and maintained correctly is to implement Storemasta’s 4-step risk management methodology. To learn more about it, simply access your free copy of our eBook to ensure workplace health and safety. This eBook can guide health and safety representatives in your workplace to control chemical risks with practical tools and templates. Access your copy to control safety risks straight away.