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Hazardous Chemicals & the GHS: Compliance Requirements

Large chemcial refinery

Hazardous Chemicals & the GHS: Compliance Requirements

Hazardous Chemicals

Hazardous Chemicals & the GHS: Compliance Requirements

Whilst WHS and OHS/DG jurisdictions typically outline similar requirements when it comes to managing hazardous chemicals, there are a number of key differences that organisations need to be aware of to ensure they comply with specific legal obligations.

The introduction of the model WHS laws provided a framework across the majority of Australia. Whilst the consistency across most jurisdictions has reduced the effort required to meet requirements, the near universal nature of WHS has meant that some of the specific obligations for the management of Dangerous Goods in Victoria and WA have been forgotten or have been incorrectly ‘met’ under the false assumption that legislative requirements for dangerous goods are exactly the same as those under WHS law.  

Certainly, a range of obligations are the same, including requirements for registers, availability and access to Safety Data Sheets, as well as protecting chemicals from ignition, impact or damage and ensuring that spills are contained and managed. 

Additionally, there are similar requirements relating to placards, notification, emergency plans and manifests, however there are key differences in how to meet these obligations.

Placards, Notification and Manifest Quantities

Both WHS and DG/OHS jurisdictions include requirements for placards, notification and manifests when quantities exceed certain limits. Importantly, the quantities that trigger requirements for placards are different for some of the gas classes. 

Product WHS Placarding Quantities Victorian Placarding Quantities
Flammable Gases 200L 500L
Compressed Gases (non-flammable) 1000L 5000L
Compressed Gases (sub-risk 5.1) 1000L 2000L

It’s also important that quantities of compressed gases are calculated correctly. Many organisations incorrectly calculate the quantity of compressed gas, using the mass (kg) of compressed gas within the cylinder, or the volume that the gas would expand to at normal temperature and pressure. But each of these methods are flawed. 

One of the problems using either the mass within a particular cylinder or the volume at normal temperatures and pressures, is that calculated quantities would change depending on the specific gas stored in a same sized cylinder. To provide a consistent measure, cylinder water capacity is used to calculate quantities of compressed gases. If you’re unsure of the water capacity of a specific cylinder, look for the “WC” often stamped or imprinted on the cylinder near the valve or on the protective valve collar. If you’re still unsure or can’t find the “WC” contact your gas supplier. 

Having correctly calculated the quantities of hazardous chemicals onsite, you can now install placarding, prepare a compliant manifest and notify the regulator, but when doing so, be aware of the following: 

  1. HAZCHEM Signs need to be displayed at more than the main entrance. In Victoria each road and rail entrance must display HAZCHEM signs, whilst in WHS jurisdictions a HAZCHEM placard needs to be displayed at each entrance that emergency services may use to enter the workplace. 
  2. Contrary to popular understanding, individual class placards are not required to be displayed at site entrances. Rather they are required at entrances to, and within, buildings were placard quantities are contained or adjacent outdoor storage areas. 
  3. Whilst WHS jurisdictions have adopted GHS and the pictograms for inclusion on packages, they haven’t adopted GHS pictograms for storage area placards. Stick with the dangerous goods placards for storage areas as outlined in the ADG code. 
  4. Notification of hazardous chemicals in quantities that exceed manifest quantities is required in Victoria and WHS jurisdictions, but in Victoria the notification to the regulator is required every 5 years even if quantities haven’t changed. 

Hazchem Combined

Fire & Emergency Management

Both WHS and Victorian jurisdictions mandate requirements for emergency plans to be developed that address the emergency risks from hazardous chemicals/dangerous goods. However, there are some important compliance requirements that are often overlooked.

  1. In both Victorian and WHS Jurisdictions, if you have notified the regulator due to exceeding manifest quantities, there are requirements to consult with the emergency services authority about the contents of your emergency plan. If the Authority provides a written recommendation, you must revise the emergency plan in accordance with the recommendation. 
  2. In Victoria, this Emergency Plan must be reviewed every five years, and with each review, you must again seek advice from the emergency services.
  3. The Emergency Plan must reference the location of the site Manifest in Victoria. 
  4. Also, within Victoria, if you have exceeded the Fire Protection Quantities (an additional quantity trigger in Victoria that is above Placard and Manifest Quantities), then you must seek the written advice from the Emergency Services for your fire protection system, including when any changes to the fire protection system occurs. 

If I have managed to keep you interested in hazardous chemicals over the past few weeks you now have an improved understanding of the GHS and other chemical guidance, how to identify handling as well as storage hazards and how to meet the accompanying compliance obligations.  

If you still aren’t sure how to safely manage 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.