By Matt Butterworth, Safety and Risk Consultant

Worksafe WA recently completed a series of industry focused inspection campaigns with the results raising concerns over failure to comply with workplace safety laws on hazardous substances.

Childcare centres, sports and recreation clubs and primary schools found worryingly low levels of compliance with the laws applying to hazardous substances in workplaces.

In fact, across the three industry groups, more than 50 per cent of all the Improvement Notices issued related to lack of training, no hazardous substances registers and no risk assessments.

Employers and self-employed people have a legal responsibility to obtain adequate information about hazardous substances used in their workplaces.

Any organisation, regardless of size or activity, will have some usage or exposure to chemicals or hazardous substances in their workplace. This includes domestic cleaning products, pesticides, insecticides or flammable liquids, for example.

Hazardous substances may have harmful effects on people, either directly through toxic effects, or indirectly through causing a fire or hazardous reaction.

Hazardous substances may be in the form of a liquid, solid or gas. Examples are poisons, and substances that could cause burns, eye irritation or breathing difficulties. 

Under the OSH Regulations 1996, a substance is a hazardous substance if it meets criteria under: 

  • the Approved Criteria (AC) classification system, or 
  • an international system called the Globally Harmonised System of Classification and Labelling of Chemicals (GHS classification system). 

The key to managing your duty of care obligations and the risks associated with the storage, use, and transport of chemicals and hazardous substances is to be aware of what exactly you have in your inventory.

To achieve this, an employer should ensure they have up-to-date Safety Data Sheets (SDS) for each substance they have in stock.

Chemicals can be classified as either hazardous or non-hazardous according to the SDS.

For substances which are not classified as hazardous, there is a general duty of care to ensure there is enough information provided so that the chemical can be used safely. This may be information from the label, product information sheet or SDS (if available).  

This information should be used to identify any potential hazards that may arise from the use, storage, and transportation of the chemicals.

A risk assessment is required for hazardous substances and employers should consult with workers on practical ways to control the hazards. These risk assessments should then be integrated into a hazardous substances register.

Under the OSH Regulations 1996, the employer, main contractor or self-employed person must keep a current register of each hazardous substance used at the workplace. 

A hazardous substance register must have as a minimum:

  • a list of all the hazardous substances used in the workplace 
  • the SDS for each hazardous substance, and
  • a notation against each hazardous substance as to whether a risk assessment has been completed.

A hazardous substance register must be readily available to all workers potentially exposed to the hazardous substances, including emergency services.

Tips for managing your chemical or hazardous substances safely

  • Ensure cleaning chemicals are stored in sealed chemical-resistant containers with original labelling.
  • Regularly check the condition of all chemical storage containers to ensure they are free from leaks and the lids are fastened tightly when not in use.
  • Store chemicals on sealed ground (such as reinforced concrete) to prevent spilled materials from leaching into the soil or groundwater. Ideally, chemical storage areas should have perimeter bunds. A bund is a small wall or barrier that restricts the flow of substances and contains them in a particular area.
  • A suitable method for dispensing chemicals such as funnels, measuring containers, dispensing systems should be implemented to reduce the risk of spills and prevent chemical overuse.
  • Where chemicals are in constant use, such as where decanting, dispensing and mixing of chemicals occur, place drip trays or a similar containment system to capture and recover any spilt material.
  • Ensure all staff are trained in chemical handling and use.

For assistance with identifying your hazards and managing them in accordance with WA’s OSH laws, contact osh@cciwa.com or call 9365 7415.