WHAT’S YOUR REACTION?

Has recent legislation change precipitated confusion about

chemical management in schools?

Mandy TimmersSenior Health and Safety Consultant

Department of Education, Training and EmploymentSeptember 2013

Part 1……….Recent legislative changes

What legislation applies now? What is the Globally Harmonised System (GHS). What is important about the Work Health and Safety

Regulation 2011.

Part 2………What does all this mean for schools?

Impact on hazardous chemicals management in schools. Who is responsible for what. Safe storage, handling and use - managing the DG-GHS

transition Management impacts

:

Session summary

Work Health and Safety Act 2011 (WHS Act) Work Health and Safety Regulation (WHS Regulation)

Chapter 7 covers hazardous chemicals Dangerous Goods Safety Management Act 2001

Safety obligations that existed under previous legislation for hazardous substances and dangerous goods at workplaces are now incorporated into the safety obligations for hazardous chemicals.

Under the WHS Regulation 2011 hazardous substances and dangerous goods are now classified as hazardous chemicals in line with the Globally Harmonised System (GHS).

Part 1 What legislation applies now?

The GHS is a new system of chemical classification and hazard communication on labels and material safety data sheets (SDS).

The GHS is now in effect in Queensland.

There is a transitional period for moving to the new GHS-based system, which will allow for the two systems (DG and GHS) to be used concurrently until 31 December 2016.

What is the Globally Harmonised System?

Comparison of GHS hazard pictograms with corresponding ADG Code class labels.

After 31 December 2016 all chemicals must be classified and labelled according to the GHS and labels and SDS must be updated.

Training will be required for staff to understand the GHS

Pictograms for immediate hazard identification Understanding and interpreting hazard info on

labels Understanding and applying SDS information When to use GHS and when to use DG systems

Part 2 What is the impact on schools?

Some manufacturers and suppliers have already started using GHS for classifying chemicals, producing SDS and labelling.

The problem is that we may see either DG or GHS or both classifications on chemicals

We must continue to use DG classifications for transport, safe storage (separation and segregation) and placarding for chemicals.

What is confusing about the transition from DG to GHS?

After 31 December 2016 all SDS must be in GHS format. All DG SDS expire after this date

Until then, we may see DG or GHS format SDS

The GHS SDS has 16 standardised sections.

The majority of changes to Australian GHS will relate to sections where GHS information is required.

Section 2 of the GHS SDS holds the hazard identification info. If S2 is blank, then you can assume the chemical is not classed as hazardous.

The SDS should always be referred to when storing, handling and disposing of chemicals and assessing risks in the workplace.

What happens to the SDS?

Transition period for full implementation of the GHS system the label for a substance made up in the workplace today can comply with either:

NOHSC National Code of Practice for the Labelling of Workplace Substances [NOHSC:2012 (1994)] - the existing system (current)

OR

Workplace Health and Safety Queensland Code of Practice ‘Labelling of Workplace Hazardous Chemicals Dec 2011’ (the GHS system)

What label is required?

Labels will change from the DG pictogram and risk (R) and safety (S) phrase hazard identification to: GHS Pictograms GHS hazard statements GHS Precautionary statements GHS other information

GHS Labelling changes

Some issues to be aware of- The GHS flammable symbol

covers all the previous DG symbols. This will be a challenge for workplace segregation (e.g. flammable solids vs flammable liquids)

To verify placarding requirements, you will need to convert the GHS classification to back to DG (e.g. calcium hypochlorite)

(tip: see S14 of the SDS for help)

Labelling challenges

Do labels on existing stocks of chemicals have to be changed?

Not yet. Full compliance by 1 January 2017 Any opportunity to update to the new system should be taken such

as during laboratory clear outs, annual stock takes, refurbishment or relocation

GHS code numbers should not appear on labels

For small containers, some label elements can be omitted when the label does not have enough space:

It is important that the label is legible Include hazard statements (no precautionary phrases unless they fit) Where info is omitted (e.g. precautionary phrases) you must put the

statement “Refer to the safety data sheet before use.”

Labelling of small containers

Storage is usually based on incompatibility To manage the storage of incompatible goods, you

must:

identify each of the hazardous chemicals used, stored or handled at the workplace hazchem register

recognise those goods or other materials that are incompatible use the SDS

implement suitable measures to prevent the interaction of incompatibles separation and segregation

Use the DG system to determine storage, not the GHS

Management of chemical storage

Control measures may include: segregating of incompatible materials in chemical

storage cabinets.

segregate using distance or by using inert materials.

segregate using cut-off/partitioned storage areas.

segregate using detached storage e.g. unleaded fuel.

train staff.

Storage in schools

Also known as HAZCHEM signage Is required by s349-350 of the WHS Regulation Workplace must be placarded if your worksite exceed

any of the quantities listed in column 4 of Schedule 11 in the WHS Regulation.

Schedule 13 of the regulation tells you how to determine signage information

Use the DG system to determine storage, not the GHS (you may have to convert GHS to DG).

Ideally, try to keep stocks below the placard threshold.

Placarding

A Hazardous Chemical Register (HCR) is required under S346 of the WHS Regulation.

It is the person in charge of the workplace’s duty to ensure there is an HCR at the workplace that contains information for the whole site.

Since hazardous chemicals are classified using the GHS hazard classes and categories, the template for a HCR will need to change accordingly.

Hazardous chemical register

While we are in the transition phase, we don’t really need to do too much…….. BUT we should begin to make changes as we go to reduce the workload and more importantly, make sure hazardous chemicals continue to be safely managed in our workplace.

Transport, storage and placarding remains within the DG system

Work towards: training workers about the GHS (esp. labelling and SDS changes and

their interpretation in the workplace) all SDS in GHS format (must be vendor SDS) all labels on chemicals in GHS format Hazardous Chemical Register in GHS format

Management impacts

Principals are responsible to ensure the following is undertaken in the workplace: Undertake a risk assessment Keep a Hazardous Substance register Label all hazardous substances in the workplace Obtain a Safety Data Sheet (MSDS) from the supplier Ensure the SDS’s are reviewed at least every 5 years Determine how to eliminate or reduce any risks Inform and train your staff about the identified risks Keep a register of staff induction and training

In addition, the Principal is required to implement risk control measures to: Contain risks leaks or spills Protect containers/pipes from damage Ensure chemical stability Control risks from storage and handling systems Ensure that an emergency plan and safety equipment is provided Manage atmospheric concentrations do not exceed the exposure standards Keep the amount of flammable and combustible substances at the lowest

practicable quantity.

In summary: