Does your workplace need a manifest of hazardous chemicals?

Dec 26, 2018 Posted by Walter Ingles

A Manifest of Hazardous Chemicals is a legal document identified in Australian WHS Regulations. This blog will help you determine if you need one, (and if you do) how to prepare, and install the Manifest so you fulfil your WHS legal obligations. The Manifest of Hazardous Chemicals is also a key document in your worksite’s Emergency Plan.

IMPORTANT: Heavy penalties of up to $30,000 could be enforced for not having an up-to-date and correct Manifest of Hazardous Chemicals in place.

What is a Manifest of Hazardous Chemicals?

A Manifest of Hazardous Chemicals is a legal document, required if your worksite exceeds threshold quantities of certain hazardous chemicals and Dangerous Goods. The purpose of the Manifest is to provide important information for emergency crews responding to fires, explosions, or chemical emergencies. The Manifest identifies significant chemical hazards and the quantities of Dangerous Goods they are likely to encounter.

IMPORTANT: Don’t confuse a Manifest of Hazardous Chemicals with a Register of Hazardous Chemicals. The Register is required at all worksites that hold Hazardous Chemicals (regardless of the quantities) and must include a copy of the current Safety Data Sheet (SDS) for each of the chemicals.

How to determine if your workplace needs a Manifest of Hazardous Chemicals

You will need a Manifest of Hazardous Chemicals if your worksite exceeds the threshold quantities defined in the WHS Regulation (Schedule 11). The Regulation displays threshold quantities for at least 43 different classes of chemicals including:

  • Flammable gases

  • Self-reactive substances

  • Unstable explosives

  • Substances with acute toxicity

  • Organic peroxides

If you exceed the threshold of any of the hazard classes you only need to notify the quantities of that chemical on your Manifest. For example: your workplace holds 3,000 litres of Flammable Gases (below threshold), 60 kg of organic peroxides (above threshold) and 400 litres of Flammable Liquids (below threshold) — your manifest will only indicate the organic peroxides.

The threshold quantities include chemicals being used, handled, stored, or manufactured at the worksite. Goods in transit are included in certain circumstances but you should check the ADG Code for the full details.

NOTE: If your site has more than 10,000 litres of any type hazardous chemicals you will also need to notify the Regulator in your state or Territory (eg, Work Safe QLD, SafeWork NSW).

Preparing a Manifest of Hazardous Chemicals

Your Manifest of Hazardous Chemicals must be prepared carefully so it is an accurate indication of the chemicals held at the worksite — it must also be updated as quantities change. The Manifest must include:

1. Business Information

  • Name of the PCUB (person conducting the business or undertaking).

  • Address of the workplace where the chemicals are stored.

  • Date the manifest was prepared (or the last time it was updated).

  • Contact details of 2 people at the worksite if there is a notifiable incident (business hours AND after hours numbers).

2. Bulk and Container Storage

  • Name of the chemical and the quantities stored.

  • Information about the tanks/containers including identifying numbers or codes, container types, capacity, diameter (in some cases).

3. Chemical Information

  • Chemical name (proper shipping name and UN code) and quantity held onsite.

  • Hazard Class (including sub-classes of certain chemicals eg, flammable liquids).

  • Product Identifier (for flammable liquids) next to the words ‘combustible liquid

  • Name of the chemical (for unstable chemicals like explosives) next to the words ‘goods too dangerous to be transported

4. Packaged and Manufacture Chemicals

  • Indicate the largest quantities likely to be held onsite

5. Hazardous Chemicals in transit 

6. Site Plan

  • A plan of the workplace drawn to scale with a legend for each item (and an indicator of true North).

  • Location of chemicals (bulk, packaged containers and IBCs, chemicals being manufactured, chemicals in transit).

  • Main entrance, exits, and access points; all drains; essential services (electrical mains, hydrants) the nature of adjoining sites.

  • The location of the Manifest itself.

  • Additional information: street names, environmental features (waterways, canals), fencing and site topography, satellite images with annotations.

Installing the Manifest

One you have prepared your Manifest you’ll need to decide on the best place to keep it. You will want to consider things like:

  • Having a sturdy document box in a definitive colour (like red) and labeling it in a way that Emergency Crews will quickly know what it is.

  • Laminating key documents (eg, the site map).

  • NOT including non-essential items (like SDSs) that can cause confusion and delay emergency responses and fire fighting efforts.

  • Consulting with your official Emergency Services Organisation (eg, Queensland Fire and Emergency Services) and agreeing to the best location for the Manifest.

  • Notifying staff of the nature of the Manifest and their responsibility to keep it secure and never open/remove the documents.

  • Ensuring the manifest is repaired or replaced during/after weather damage to the site, renovations or construction, theft or vandalism.

IMPORTANT: The Manifest must be updated if threshold quantities change, bulk or packaged containers stores are moved/transferred, or the overall layout of the worksite changes and an emergency response could be affected.

Next Steps

Having a Manifest of Hazardous Chemicals in place is only one small step in complying with WHS legislation. Download our free eBook How to manage the risk of Hazardous Chemicals in the workplace to gain a full understanding of how to control the chemical hazards at your workplace and getting your site 100% compliant. Download and read it today by clicking on the image below:

How to manage the risk of hazardous chemicals in the workplace

Walter Ingles

Walter Ingles Compliance Specialist

Walter is STOREMASTA’s Dangerous Goods Adviser. He loves helping businesses reduce the risk that Dangerous Goods pose upon their employees, property and the environment through safe and compliant dangerous goods storage solutions.

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