Are you storing your Dangerous Goods/Hazardous Chemicals appropriately?

There are several resources available to duty holders which include, but are not limited to, the Victorian Dangerous Goods and the Occupational Health and Safety (OHS) legislation which captures hazardous substances. Whereas some of the other States and Territories are governed by the Work Health and Safety (WHS) legislation which does not differentiate between dangerous goods and hazardous substances (chemicals). Additional information is required to be resourced, when despatching and receiving dangerous goods as these products/articles are covered by the Australian Dangerous Goods Legislation and Codes for Transport.

The relevant Regulators have also developed various Compliance Codes and guidance material for duty holders to follow. These resources are written in layman terms for understanding and by applying these guidelines, a duty holder may be able to demonstrate they have taken reasonably practicable steps to meet their obligations with storing and handling dangerous goods/hazardous chemicals.

When determining what is ‘reasonably practicable’ in the circumstances, all relevant matters are taken into account, including:

a)    The likelihood of the hazard or the risk concerned occurring;

b)    The degree of harm that might result from the hazard or the risk;

c)    What the person concerned knows, or ought reasonably to know, about the hazard or risk, and about the ways of eliminating or minimising the risk;

d)    The availability and suitability of ways to eliminate or minimise the risk; and

e)    After assessing the extent of the risk and the available ways of eliminating or minimising the risk, the cost associated with available ways of eliminating or minimising the risk, including whether the cost is grossly disproportionate to the risk.

Most of the compliance codes refer to Standards which need to be purchased at an additional cost to the duty holder from Standards Australia Store | Standards Australia Store.

Standards are published documents that are designed to provide guidance to assist with safety, performance and reliability through the specifications of goods, services and systems. Standards are not laws, so there is no general requirement on a duty holder to conform to a Standard. However, conforming to a specific Standard is mandatory, if there is a law which says you must conform with it.

Organisations must develop and implement systems of work to manage the storage and handling dangerous goods/hazardous chemicals, such as Safe Operating Procedures (SOPs), registers and retaining Safety Data Sheets (SDSs) which are readily available to the workers.

These systems can be audited by internal or external parties from time to time for continual improvement, which is a great initiative. However, if the person conducting these audits does not have the specific knowledge of the requirements for storing and handling dangerous goods/hazardous chemicals, it would be advisable for the duty holder to request a reference point from these parties in the reports.