Chemical management procedure
Intent and objectives
To ensure that arrangements are in place to minimise the risk of adverse health effects to staff, students, contractors and members of the public, due to the exposure to hazardous substances and dangerous goods used as part of RMIT’s operations.
This procedure has been developed to ensure compliance to the Occupational Health and Safety Act (2004), the Dangerous Goods Act (1985), Dangerous Goods regulations (storage and handling) 2000, Occupational Health and Safety Regulations (2007), Drugs, Poisons and Controlled Substances Regulations (2006), and the relevant subordinate legislation and Australian Standards pertaining to the storage, handling and use of Hazardous Substances and Dangerous Goods.
This procedure covers the requirements associated with the safe purchasing, handling, storage and use of hazardous substances and dangerous goods. It includes the use of labels and Material Safety Data Sheets (MSDS's), provision of information and training to personnel, risk assessment and control, precautions for safe handling, storage and use, document control and access to information by interested parties.
Procedure steps and actions:
- Co-ordinating and overseeing the RMIT University Chemical Infosafe Chemical Management Database
- Maintaining the RMIT University Chemical Management Procedure and related Guidelines
- Ensuring Material Safety Data Sheets (MSDS) are obtained for any chemicals used or stored in their area and information is maintained on the University Infosafe chemical management database.
- Ensuring a risk assessment is performed on each chemical for storage and handling and prior to use or used in a process.
- Ensuring that risk assessments are conducted prior to purchasing or obtaining chemicals.
- Ensuring that all staff who use, handle or are likely to be exposed to chemicals are appropriately trained.
- Ensuring that appropriate Personal Protective Equipment & Controls are provided as identified in the risk assessment.
- Ensuring that air quality monitoring is undertaken as indicated in a risk assessment
- Ensuring that work instructions for handling chemicals in the workplace are prepared and developed, and that they are explained to staff and students.
- Ensure that information related to chemicals that are stored/used on site is passed on the emergency services.
All chemicals shall be assessed for risk prior to being purchased or obtained. Manufacturer’s or supplier’s Material Safety Data Sheets shall be obtained for all chemicals prior to assessment. Where possible, proposed new chemicals should be researched, assessed and trialled prior to purchase. The Responsible Manager or their nominated representative/s and the Health and Safety Representative for the area must carry out the assessment.
3. Chemical register
A register of all chemicals used/stored on site shall be generated by the Schools and Work Units.
The RMIT electronic register will be coordinated by RMIT Human Resources Health Safety Team. The ACOHS -InfoSafe electronic chemical management database system contains a register of all chemicals used in each Faculty or Service unit as well as provide access to current manufacturer material safety data sheets, maintain a permanent record of risk assessments, generate substance labels, local hazardous substances registers and provide dangerous goods manifests for emergency services as required.
The InfoSafe Chemical Register contains the following information:
- Unit (e.g. L/ kg)
- Building / Level/Room location
- Manufacturer name
- Area ID (Optional)
- Product code
- The name of the chemical/substance as detailed on the container label
- DG class
- The container type
- Hazardous substance (Y/N)
- Number of containers
- Packing group
- Pack Size
- UN number
- Average Quantity
- Material Safety Data Sheets date
- Maximum quantity
- School – Discipline area
- The quantity of the Chemical. The Average and Maximum Quantity (likely to be held at any one time at that site.)
The Chemical Register must be updated when the following elements occur:
- New chemicals are introduced into the workplace
- Existing chemicals are no longer in use or being stored, must be deleted.
- The details of any revised or updated Material Safety Data Sheet must be entered.
The Responsible Manager or their nominated representative is responsible to maintain the Dangerous Goods and Hazardous Substances Register for their area and to ensure its currency.
4. Chemical hazard identification and risk assessment
It is the duty of the Responsible Manager or their nominated representative to ensure that all hazards associated with chemicals that are used, and stored, within their area, and transported to and from the area, are identified and assessed for risk.
Reference should be made to the following where applicable:
- Material Safety Data Sheets
- Consultants’ reports
- Information supplied from the supplier and/or manufacturer
The chemical risk assessment for Storage and Handling shall be undertaken using the Chemical Risk Assessment Form: Risk assessments should be carried out by someone who is trained in health and safety hazard and risk management.
Risk assessments can be carried out using the Infosafe system and utilising the Manufactures Material Safety Data Sheet (MSDS) .
The Chemical Risk Assessment shall include risk control options that follow the Hierarchy of Control. Where applicable, the risk controls that have been introduced shall be communicated to all staff, students, visitors and contractors who may be exposed to the chemicals.
Chemicals that have not met the requirements of the Risk Assessment must not be stored or used on site.
Where the chemical is used in a process a Risk Assessment must also be undertaken on the process using the relevant Risk Assessment Form i.e. Plant & Equipment / Manual Handling / Noise
Staff and Students must receive training in chemical awareness upon local induction. Additionally, staff and students shall be trained in chemical awareness if, during the course of their work/study they:
- Use or chemical handling,
- Are likely to be exposed to chemicals,
- Mix or conduct experiments using chemicals,
- Synthesise new chemicals.
The responsible manager must ensure that all staff and students using/storing and handling chemicals are trained in chemical awareness.
The course content shall contain the following elements - at a minimum:
- Recognition and understanding of the hazardous nature of chemicals in the workplace.
- Information about chemicals to which the staff are, or may be exposed, this should include physical hazards and health effects, including routes of entry, and potential risks to health from acute or chronic exposure.
- How to locate, identify and obtain relevant information from the Manufacturers Material Safety Data Sheets and chemical labels.
- How to use the Infosafe chemical management system to access relevant information (if relevant).
- How to produce safety labels for decanted substances.
- The conducting of risk assessments for the storage and handling of chemicals including the processes in which the chemical will be used.
- Work practices or Standard Operating Procedures to be followed when handling, processing, storing, cleaning up or disposing of Hazardous Substances/Dangerous Goods. This would include local emergency procedures such as spill containment and first aid.
- Information regarding exposure controls, including information on the correct use of risk controls.
- The proper use and fitting of Personal Protective Clothing and Equipment (PPE).
- Atmospheric monitoring if required.
Note: Atmospheric monitoring is required where there is an exposure standard for the hazardous substance or any of its ingredients and:
- You are not sure whether the exposure standard may be exceeded; or
- Atmospheric monitoring is required to determine if there is a risk to health.
- Health surveillance if required.
Note: health surveillance is required when a substance is listed in Schedule 3 of the NOHSC’s National Model Regulations for the Control of Workplace Hazardous Substances [NOHSC:1005(1994)], and exposure is such that there is a likelihood of an adverse health effect under the particular condition of use.
All designated Chemical Management Database System operators must be trained in the use of the Chemical Management Database System.
6.1 Manufacturer labels
The responsible manager shall ensure that all chemicals purchased are adequately labelled as to provide sufficient information to alert the user of any associated hazards.
The responsible manager should seek additional information from the manufacturer and or supplier if insufficient information is provided.
The label must be firmly secured to the container. All information on labels must be legible and durable.
The manufacturer label must be written in English and must contain the following information as a minimum requirement as detailed in the National Health and Safety Council’s, National Code of Practice for the Labelling of Workplace Substances. NOHSC: 2012 (1994) 2:
- The Product Name *
- The name, address and contact telephone number of the Australian manufacturer or importer of the substance*
- The UN number (If classified as a Dangerous Good)*
- The Dangerous Goods Class *
- The Dangerous Goods Class and Subsidiary Risk Diamond
- The chemical or generic name for all ingredients of the chemical. (A generic name may only be given for ingredients for which commercial confidentiality has been claimed)
- Key Risk and Safety Phrase(s) indicating relevant health and safety information about the substance except where the container is so small that it is not practicable to provide such information*
- Signal words such as HAZARDOUS”, “DANGEROUS”, “POISON”, “WARNING” or “CAUTION” clearly and prominently displayed (as per the Poisons Schedule or Hazardous Substance identification) *
- Directions for use (where appropriate)
- First Aid Procedure*
- Emergency Procedure*
- Expiry date (where relevant)
- Reference to the material safety data sheet*
Containers less than 500mL capacity may contain information listed above marked with an *.
Where containers are so small that this information cannot be provided on the actual container the following information should be provided by the Manufacturer as a minimum requirement:
- Product name
- Dangerous Goods Class and subsidiary risk where applicable
- Signal word(s)
- The name, address and contact telephone number of the Australian manufacturer or importer of the substance.
Additional information may be detailed on external packaging or information leaflets provided with the chemical.
6.2 Labelling of decanted substances
All hazardous substances that are decanted and not consumed immediately shall be labelled with the following information as a minimum requirement in accordance with NOHSC 2012 (1994).
- Product Name
- Risk and Safety Phrase(s)
A container shall remain labelled until cleaned so that it no longer contains any hazardous substance. The University chemical management database (InfoSafe) should be used to create decanted substance labels.
If the container is so small that the label cannot be placed on the actual container, the label can be attached by other means, such as a string around the neck of the container or supporting apparatus such as test tube rack.
6.3 Container not properly labelled
If a container is not properly labelled, for example the label has been lost, the container should have the product name, if known, attached to it. Unlabelled containers of an unknown chemical shall be labelled:
“CAUTION DO NOT USE: UNKNOWN SUBSTANCE”.
The container shall be removed from use and the waste management contractor (Environment Protection Authority approved) shall be contacted to arrange for its disposal.
7. Handling of chemicals
It is the responsibility of each school/work unit to prepare and implement Safe Work Instructions for the handling of chemicals in the workplace. Each chemical needs a proper risk assessment undertaken. Work instructions must cover at least the following:
- The hazards associated with storage, handling and use of the chemical.
- Incompatibility of substances when mixed (e.g. Mixing may result in a fire or an explosion). Precautions when pouring, decanting or transferring substances.
- Control measures to be used to minimize the risk of exposure. These may include:
- Substitution (with a safer chemical)
- Isolation (involves separating people from substance by distance
- Engineering Controls - physical controls that reduce generation of substances, suppress or contain substances or limit area of contamination. e.g.- laboratory fume hoods, local extraction ventilation, automation of process)
- Administration controls- Systems of work (e.g. - Safe Handling Procedures)
- Personal protective clothing and equipment. (Includes, lab coats, protective footwear, gloves, chemical resistant glasses, face shields, overalls and respirators)
Control measures must be used correctly and maintained. They should be reviewed on a regular basis to ensure their effectiveness
- Emergency response (steps to be taken in the event of a spill or exposure).
- Incident reporting.
The responsible manager is to ensure that all incidents involving exposure of persons to a hazardous substance and/or dangerous good are to be promptly reported to Human Resources and a RMIT incident report form is to be completed.
Where appropriate, signage may be used to communicate instructions.
Devices to ensure safe pouring of chemicals shall be used where possible. These devices must be able to bear the full weight of the container and allow safe control for the pouring of the chemical.
Mixing of chemicals and chemical processes shall be carried out in accordance with the risk assessment requirements and reviewed and signed off by the responsible Manager and by others as deemed appropriate.
8.1 Hazard identification
The relevant school/work unit shall follow a process of hazard identification and risk assessment on all storage facilities. Chemicals shall be stored in accordance with the relevant statutory legislation and where possible, consideration shall be given to reducing the quantities of chemicals stored. Segregation will be required where different classes of dangerous goods are stored in the same store. Appropriate signage may be required depending on quantities contained in the store.
Chemical storage containers (including gas cylinders) which are deemed to be unsafe (eg. damaged, leaking etc.) shall be labelled with ‘Do Not Use’ and immediately removed from the area by trained personnel and segregated and stored in an appropriate area until disposed of appropriately. Leaking or damaged containers (except gas cylinders) should be placed inside another suitable container to contain any leak or spill.
8.2 Dangerous Goods
Dangerous goods segregation distances are available in the attached chart.
9. Chemical use
A risk assessment shall be conducted for the use of chemicals in chemical reactions (mixing of chemicals) and chemical processes of Hazardous Substances and Dangerous Goods or products, which fall into these categories.
If a new chemical is synthesised a Material Safety Data Sheet must be generated to provide the necessary information to ensure the chemical can be stored and handled in a safe manner.
10. Information to interested parties
It is the responsibility of the security manager to ensure that information related to chemicals that are stored/used on site is passed on to the appropriate emergency services.
It is the responsibility of Human Resources to forward updated Chemical Registers to security. It is the responsibility of school/Work Unit to update the chemical inventory for the buildings they occupy and complete the chemical disposal form on a monthly basis.
Nominated security staff shall have access and be trained in the Infosafe Chemical Management Database.
This information should be in the form of:
- Dangerous good manifest
- Chemical register
- Chemical Management Database
- Site Location
11. Disposal and spills
All chemicals shall be disposed of safely in accordance with the Chemical Risk Assessment requirements and spill kits where chemicals are required to be disposed of off site this needs to be done by an Environmental Protection Authority approved registered contractor. On collection of a disposed chemical a certificate of destruction/disposal must be requested. On collection of disposed chemical an Environmental Protection Authority transport form must be completed.
12. Dangerous goods manifest
The Dangerous Goods Manifest shall be located in the Security Control Room. Individual manifests must be located at Emergency Warning and Intercommunication System panels at every building where manifest quantities are located.
The manifest shall be revised or updated if:
- There is a change in any of the information.
- There is a change in the relevant legislation.
The plan shall identify the places, buildings and structures on the premises where dangerous goods are stored above manifest quantities. It should be easy for the emergency services to read and understand. The plan of the premises should be to scale and shall contain the following information:
- Locations and identification number of code of:
- Bulk containers and bulk storages
- Storage areas for packaged dangerous goods and dangerous goods in intermediate bulk containers
- Legend for the identification numbers and codes for the above areas
- Main entrance and other entry points to the premises
- Location of essential site services including fire services and isolation points for fuel and power
- Location of the manifest for the premises
- Location of all drains on the site
- Nature of the occupancy on adjoining sites or premises
- Areas that are subject to public patronage, as well as public street names adjacent to the premises
- Evacuation routes.
13. Obtaining Material Safety Data Sheets (MSDS)
A manufacturer’s MSDS must be obtained for all chemicals stored or used on site prior to arrival at RMIT. The responsible manager or their nominated representative must ensure MSDS’s are obtained prior to the purchase of chemicals. The original supplier, manufacturer, or importer of the chemical must provide all MSDS’s.
It is recommended that hard copies of all original MSDS’s shall be held by each School or Work Unit. All new chemicals shall be obtained from suppliers/manufacturers when new chemicals are purchased or obtained and added to the Chemical management system by the School or Work Unit’s trained user.
14. Access to Material Safety Data Sheet (MSDS)
It is the responsibility of the responsible manager or his/her nominated representatives to ensure MSDS’s are obtained and available to all personnel for any chemical that is used and/or stored within the department.
Access to MSDS’s should be obtained via the School Chemical Management System and a hard copy being placed in an accessible location within the School or Work Unit where the chemicals are stored and used – and via the Chemical Management System database located in the RMIT Intranet website. The database shall be made available to anyone with access to the RMIT Intranet website. Staff and contractors who do not have access to the Intranet should be able to obtain MSDS’s via their Responsible Manager or his/her nominated representative.
15. Signage and placarding
Property Services working with school managers shall ensure that signage and placarding is displayed on all main entrances and buildings if the quantities stored are greater than the “Placarding quantity” in Schedule 2 of the Dangerous Goods (Storage and Handling) Regulations 2000. Security shall ensure that the Dangerous Goods manifest is maintained and updated.
16. Waste disposal
Chemical waste should not be allowed to accumulate. Chemical waste must not be mixed with other chemical waste unless the waste is of the same type. Personal protective equipment should be used when handling chemical waste as recommended in the MSDS and by the risk assessment. The area laboratory manager or Human Resources can be contacted for advice to safely dispose of waste.
1. Identify the waste category, waste type, UN No., class and HAZCHEM Code.
2. Prepare the waste for disposal by storing it in an appropriate container. The container must be of sound and leak-tight condition and be appropriate to the type of waste to be disposed. No harmful quantity of chemical waste should adhere to the outside of the container.
3. Label the container using a Waste Label available in supporting documents, complete the relevant information and paste onto container.
4. Complete the Waste Disposal Form available in supporting documents.
5. In consultation with the laboratory manager or senior technical employee, contact an approved Chemical Waste Disposal company to collect and dispose of all chemical waste. The persons generating the waste are responsible for the safe storage, packaging, labeling and disposal. Failure to comply with the above contravenes this procedure.
6. Costs associated with packaging, labeling and disposal is the responsibility of the cost centre generating the waste.
7. Schools are to keep records of wastes disposed of and must ensure that Environment Protection Authority transport certificates are completed for all waste collection.
17. Updates and records
- All MSDS’s shall be updated by the relevant manager or their nominated representative.
- The School/Work Unit Chemical Register or Infosafe Chemical Management System Database operators of each department shall ensure that records of new chemicals are entered into the Database inventory of their department. Chemicals that have been removed from site shall be deleted from the relevant database store. MSDS’s that have been superseded, or MSDS’s of chemicals that are longer being used or stored on site, shall be withdrawn from circulation and all points of issue.
- MSDS’s that are older than five years shall be considered as invalid and an updated MSDS shall be obtained from the supplier of manufacturer of the chemical. MSDS’s that have been superseded or updated are archived.
18. Scheduled hazardous substances (Carcinogenic substances)
There is a list of hazardous substances published in the National Occupational Health and Safety Commission’s National Model Regulations for the Control of Scheduled Carcinogenic Substances. [NOHSC: 1011(1995)]. These substances are considered to be carcinogenic to humans.
The responsible manager has a duty under the Hazardous Substances Regulations to apply for a license from WorkSafe Victoria to use schedule 1 or 2 carcinogens in the laboratory or a schedule 2 carcinogen at a workplace other than a laboratory.
A Risk Assessment must be conducted and attached to the application with all proposed controls detailed. The application form is available from the WorkSafe website.
19. Prohibited substances
The National Occupational Health and Safety Commission have published a list of chemicals that are prohibited from use in the workplace, as they are considered to dangerous to health and safety. The list can be obtained from the Safe Work Australia website.
20. Poisons and drugs
There are a range of chemicals defined in the Drugs, Poisons and Controlled Substances Act (1981) as listed in the Standard for the Uniform Schedule of Drugs and Poisons, (SUSDP). These chemicals have potential for use as therapeutic agents and/or drugs of addiction and thus require stringent control.
In addition to facilitating compliance with hazardous substances and dangerous goods regulations as appropriate there is an additional requirement for the responsible Manager to obtain a permit to purchase or obtain poisons or controlled substances from the Department of Human Services. A poisons control plan must be developed and maintained for each approved substance held on site.
A license is required for schedule 4, 7, 8 & 9 substances listed in the SUSDP and a Responsible Person must be registered with the Department of Human Services. Poisons are to be kept in a secured location and a log kept of usage for schedule 7, 8 & 9 poisons. Refer to the SUSDP for specific details. An application form can be obtained from the DHS website.
21. Copies of documents
Copies of the following must supplied to Human Resources:
- Dangerous Goods Notification
- Drugs, Poisons and Controlled Substances Licence and Registration of Responsible Person
- List of Prohibited Substances
- Notification of Scheduled Carcinogenic Substances