As auditors and trainers, we find that employers and employees do not really understand their duties when it comes to Hazardous Substance Management. They pose both Safety and Environment risks.
Here are a couple of pictures of what we actually observe on site.
Hazardous Substances being stacked outside the mechanical warehouse:
The issues identified, no bunding to ensure chemicals do not spill onto the ground, and personnel using the tins to butt out their smokes, these chemicals are highly flammable. Not only an Environmental issues, but a safety concern.
Hazardous Substances being stacked outside the manufacturing plant:
The issues identified, no bunding to ensure chemicals do not spill onto the ground.
Hazardous substances do not have risk assessments, therefore it is unknown if these substances can be mixed in the sane area, there are no ‘Safety Data Sheets’ SDS’s available to educate personnel about the Hazardous Chemicals, and so much more.
Hazardous Chemicals being placed in the general waste bin, oily rags being placed in the general waste bin, and so much more.
What the Law says:
Employers must provide and maintain, so far as is reasonably practicable, a working environment for their employees that is safe and without risks to health. OHS Act s21 18.
To ensure that employers provide a working environment that is safe and without risks to health, they must eliminate risks to health and safety so far as is reasonably practicable, and if it is not reasonably practicable to eliminate the risks to health and safety, reduce those risks so far as is reasonably practicable. OHS Act s20 Read more here
What are the Requirements:
Employers have a number of specific duties under the OHS Regulations to manage risks associated with hazardous substances in the workplace, such as the duty to ensure that:
a) they obtain a current SDS on or before a hazardous substance is first supplied to their workplace OHS Regulations r155,
b) a current SDS is readily accessible to any employee who may be exposed to the substance OHS Regulations r156,
c) an SDS is not altered OHS Regulations r157,
d) a container in which a hazardous substance is supplied to their workplace is labelled with the manufacturer’s or importing supplier’s label OHS Regulations r158,
e) a container labelled under regulation 158 of the OHS Regulations, remains labelled until it has been cleaned or its contents neutralised, cured or chemically deactivated to the extent that it is not a risk to health OHS Regulations r159,
f) a hazardous substance in plant (such as a pipe) or any plant that forms part of a manufacturing process is identified to employees who may be exposed to the substance OHS Regulations r160,
g) containers of waste produced or generated at a workplace from a hazardous substance are identified OHS Regulations r161,
h) a register of all hazardous substances supplied to the workplace is prepared and maintained OHS Regulations r162,
i) any risks associated with hazardous substances in the workplace are controlled, so far as is reasonably practicable OHS Regulations r163,
j) atmospheric monitoring OHS Regulations r166 and health monitoring is carried out if required. OHS Regulations r169.
Instruction and Training Requirements:
When providing information, instruction and training to employees and independent contractors it is important to include information about:
the risk management process,
the information included on labels of containers of hazardous substances and the meaning and effect of that information,
how to locate and use an SDS,
what information is in an SDS,
hazards and potential risks associated with hazardous substances to which employees may be exposed,
appropriate work practices and procedures to be followed when using hazardous substances, including handling, storage and disposal,
control measures, including information on the correct use and maintenance of risk controls,
how to use, maintain and clean personal protective equipment (PPE),
emergency procedures, including any evacuation or special decontamination procedures,
how to use any fire protection equipment,
first aid and incident reporting procedures to be followed in case of injury or illness,
the reasons for atmospheric monitoring and health monitoring (if required).