Have you started storing dangerous goods (DG) but don’t know where to get the information you need to understand your legal obligations?
Or, perhaps you’ve started to improve your dangerous goods compliance but feel like you are going around in circles and running into dead-ends! As you may already know, storing and transporting dangerous goods is regulated at all levels of government because the consequences of an incident involving dangerous goods can be deadly.
Recent large warehouse fires in Melbourne, and other international incidents such as container ship fires and the large port explosion in Tianjin, China illustrate how dangerous goods incidents can be devastating and unexpected.
We understand that meeting compliance standards can be overwhelming and figuring out which steps to take towards meeting compliance can be confusing and expensive. The information you need is not in one place. There are national codes of practice, state government regulations, multiple regulator agencies, and industry standards… and there always seems to be something you haven’t done!
We’ve compiled a list of six tips to help you better manage your dangerous goods in storage. These six tips don’t provide all the answers in all situations but each one is an essential element in an efficient DG management system.
Tip 1: Organise your storage area
Known as housekeeping, along with placarding and labelling, will make your storage area look professional and in control.
➢ Label storage areas with DG hazard labels; separate them from each other
➢ Ensure waste is removed and disposed of appropriately
➢ Clear aisles and exits of equipment and packaging
➢ Tidy stock/storage rooms; treating them like they’re visible office areas
➢ Ensure exits are clear in case of an emergency or evacuation
Did you know: waste storage is still considered dangerous goods and should be handled with the same risk controls (e.g. Spill containment and fire protection)
Tip 2: Use Safety data sheets (SDS) to manage your dangerous goods
The SDS is a requirement of manufacturers and importers of dangerous goods to declare the components and other data relevant to the management, storage and handling of the particular product.
➢ Every DG that is stored on site must have an up to date SDS
➢ SDS’ are produced by the manufacturer or importer of hazardous substances in Australia and most can be downloaded by searching the manufacturer.
➢ The SDS contains information such as:
The hazard classification and regulatory information
Risks in using and storing the product
Information about the components of the product
Did you know: you are required to make the SDS for each dangerous goods product available at your work place to the people that may come in contact with it.
Tip 3: Maintain a dangerous goods register
Record the class and quantity of all DG products being stored and keep it up to date at regular intervals (such as monthly or when quantities change significantly).
➢ Use the SDS to determine the class of each DG
➢ Organise products by class
➢ Determine the quantity in storage for each class
➢ When threshold quantities are reached refer to your State/Territory regulator to determine additional obligations including:
• Licences and notifications to regulators
Below is an example of a simple DG register:
Class (sub risk)
Eg. Flammable liquid cabinet
I, II, or III
Eg. 20L drum
Did you know: you can identify the DG class by identifying class diamonds on packaging and container labels, the SDS, or transport documentation.
Tip 4: Assess the risks
A Risk Assessment will determine the level of risk and the controls required for the safe storage and handling of dangerous goods at your site. A risk assessment can be substituted by closely following a recognised industry standard or code of practice.
➢ Risk assessments should be conducted by a competent person with a knowledge of:
The work processes involving the chemicals
Consultation with people at the workplace
Reference to past incidents and industry knowledge
The relevant Health and Safety legislation
Codes of practice
Interpreting the contents of the SDS.
There are several methodologies for conducting a risk assessment, you can download a simple guide to conducting a risk assessment from Safe Work Australia.
Did you know:
Risk controls include:
• Spill kits
• Fire protection
• Emergency/evacuation procedures
• PPE etc.
Tip 5: Record your procedures and controls
Document the procedures and controls you have in place to enable them to be managed. This will also make it easier to make changes when required and they can also be presented to regulators or others that may want to see evidence of your system.
Procedures may include:
• Site emergency plan
• Spill procedures
• Safe work methods statements
• Incident management Process
• Training plans and training records
• Traffic management
• Contractor management
• Hot work permits.
Did you know: your existing workplace health and safety procedures (OH&S, or HSE) will form an important part of your dangerous goods management system.
Tip 6: Monitor and review
The “management system” you have in place needs to be monitored to ensure it is operating as intended and reviewed regularly to make sure it continues to meet your requirements.
➢ Make sure any risk controls and documented procedures are part of your management system
➢ Confirm somebody is responsible for maintaining the procedures and controls, keeping them current and up to date
➢ Risk assessments should be conducted yearly or whenever a significant change occurs
➢ Emergency plans should be reviewed every two years or when a change occurs