Hazardous Chemicals & the GHS: Chemical Storage
Most organisations understand, that at the very least, controls are needed when using hazardous chemicals, but forget that chemicals in storage can be just, if not more dangerous.
Whilst handling related hazards are typically more likely to occur, due to chemicals being handled, decanted, used, mixed or diluted, in most cases the quantities involved are generally smaller that the amounts being stored, helping minimise how widespread the impacts can be.
Whilst storing hazardous chemicals probably has a relatively lower likelihood of hazards occurring, due to the absence of handling activities within storage areas (eg mixing, decanting), the quantities are higher providing the potential for more serious or widespread damage.
But it’s not uncommon for both handling and storage to occur in the same area (it generally shouldn’t), particularly where there isn’t enough space to separate the two activities. Recent industrial disasters have demonstrated how major chemical disasters can occur when poor handling practices combine, in close proximity, with large hazardous chemical stores that aren’t fit for purpose.
But understanding exactly how to store hazardous chemicals can be complex, requiring an understanding of the instruction and guidance available in Regulations and various Codes, product specific information in SDSs as well as specific instruction provided in Australian Standards covering the various dangerous good classes. Getting storage arrangements right also requires an understanding of the limitations of each of these information sources.
With a single product type, in relatively low quantities, getting storage arrangements right can be achieved using Regulations/Codes and the specific guidance and instruction outlined in product SDSs. WHS / DG Regulations and Codes outline your general obligations, including the requirements for safety signs, identifying risks of physical or chemical reaction, fire and explosion measures, keeping products stable, providing for spill control and protecting hazardous chemicals from impact or damage. Information from SDSs will enable you to understand what to do in most circumstances to achieve the right outcomes.
However, these information sources aren’t always comprehensive, particularly when there are stores with mixed product or significant quantities. Both of these circumstances increase the complexity of hazard identification and how comprehensive or advanced control measures should be. In these circumstances, a more detailed analysis of hazards needs to occur and control measures should have regard for one or more Australian Standards.
Lets consider the storage of compressed gas cylinders, where leaks from cylinders can result in hazards such as explosion, exposure to airborne contaminants as well as asphyxiation. While WHS and DG Regulations outline that such hazards need to be controlled, they are silent on specifics that might prevent such hazards. Seeking further guidance from SDSs would highlight that the product should be stored in a “well ventilated area” with little guidance of what this entails or how to achieve it. Similarly, Codes highlight the requirement for adequate ventilation in storage areas, be it natural or mechanical, but importantly, don’t go into specifics of how to achieve ‘adequate’ ventilation. Only consulting an Australian Standard like AS 4332 is going to instruct you on how to achieve suitable natural or mechanical ventilation through storage area design or design of ventilation systems.
This is because Australian Standards go beyond the generic chemical properties of a product to identify hazards and the necessary controls that address how and where a product is typically used and stored.
Whilst interrogating and interpreting information from Australian Standards isn't always cheap or easy (the endless cross and circular referencing in Standards is particularly annoying), major and complex hazardous chemical storage arrangements are only going to be safe by understanding the full extent of requirements, guidance and instruction outlined in Regulations, Codes, SDSs and relevant Australian Standards.
Having now improved our understanding of hazardous chemicals guidance, how to properly use Safety Data Sheets and now storage hazards, its now time to meet the accompanying compliance obligations. In our next Blog Entry we will look at how to satisfy requirements for hazardous chemical notification, manifests and placards. Hit the subscribe button to be notified about this and all future upcoming blogs.
If you still aren’t sure how to safely store hazardous chemicals and need assistance, contact Verus today. Verus has chemical management specialists that can advise and support you on how to meet your obligations.