Storage of Dangerous Goods

Worksafe Victoria on the 10th August have released a Safety Alert reminding employer/occupiers of their specific duties when storing dangerous goods. In many cases employers/occupiers may store dangerous goods in 'Transit' for up to five days, as long as the organisation has assessed and controlled the risks.

With the recent breakout of the coronavirus COVID-19 some organisations may reduce operations or even shutdown over this period. WorkSafe has issued an alert about the importance of having a plan to manage the risks of dangerous goods when temporarily shutting down or reducing the extent of your operations due to the coronavirus (COVID-19) pandemic.

The regulator has identified some safety issues that need to be addressed when there is a significant risk arising from the presence of dangerous goods at the workplace. Risks associated with dangerous goods that need to be managed when temporarily ceasing or significantly restricting operations include:

• The built up of vapours and fumes from flammable material with little ventilation.
• Inadequate leak or spill management to ensure incompatible dangerous goods do not encounter each other.
• 'Benign' materials that, when degraded or contaminated, become hazardous, for example batteries, garden or agricultural chemicals, ammonium nitrate.

Employers/Occupiers must identify the hazards related to dangerous goods that are present at their workplace or premises, assess the risks, and implement risk controls. There are some valuable resources that employers/occupiers could access to management these risks which include but are not limited to:

The Victorian Code of Practice for the Handling and Storage of Dangerous Goods.
https://www.worksafe.vic.gov.au/resources/code-practice-storage-and-handling-dangerous-goods

Managing Chemicals in the workplace
https://www.worksafe.vic.gov.au/resources/managing-chemicals-workplace-step-step-guide

In particular, prior to shutting down or significantly reducing operations, occupiers of premises storing or handling dangerous goods should eliminate risks by removing or consuming dangerous goods where practicable.

If this is not practicable, occupiers should:

• Consider the minimum staffing requirements to ensure the continued safe management of materials on the premises.
• Ensure that all staff on site are fully informed of the risks associated with the dangerous goods and the risk controls implemented during reduced operations.
• Ensure that safety data sheets (SDS) are available for all dangerous goods on the premises.
• Ensure that package markings and class or hazard class information are clearly visible, including to emergency services.
• Ensure that buildings subject to shutdown are adequately ventilated so that flammable or toxic materials cannot accumulate.
• Ensure that processes that rely upon a regular rate of consumption (for example LNG, cryogenic ammonia) do not heat up to a hazardous degree as a result of reduced operations.
• Ensure that the safety aspects of security inspections are sustained (for example physical inspections, CCTV, thermal imaging).
• Confirm that fire systems are functional.
• Ensure adequate signage is displayed, such as outer warning placards and are visible to emergency services.
• Ensure that the manifest for the site is up to date and placed in a location that is accessible to emergency services.

Occupiers should also plan to manage risks that will arise when bringing the business back to normal operations following shutdown or reduced operations. Both shut down and start-up are process conditions, which need special attention to prevent the occurrence of chemical accidents. Recent severe incidents in India (Visakhapatnam) and Italy (Ottaviano) were caused by failures to ensure that robust controls were implemented prior to restarting a business after shutdown.