Chemical management

Ammonium nitrate is classified as High Consequence Dangerous Good in Victoria due to security risks associated with its sale, supply, storage and use.   Under the High Consequence Dangerous Goods (HCDG) Regulations 2016 (Vic), most organisations must apply for a licence if they store, use or handle any quantity of ammonium nitrate.

Tertiary education institutions are exempt from licensing requirements for small quantities if:

1. The HCDG is for the purpose of educational instructions, research or testing; and
2. The total quantity held across the whole institution is no more than 3kg.

The University does not hold a HCDG license and therefore total holdings of ammonium nitrate for the whole University must remain under 3kg.

The University’s Ammonium Nitrate Management Plan details how the conditions of the education institution are implemented at the University of Melbourne.

To ensure compliance with the education institution exemption, staff and students using ammonium nitrate for educational instructions, research or testing must follow the Ammonium Nitrate Management Plan

Note that only staff can obtain ammonium nitrate by submitting their request via ServiceNow ticket. Students who do not have access to ServiceNow must ask their supervisor to submit the request through ServiceNow for them.

Detailed information is available internally. (View Knowledge Based Article; KB002878)

A chemical risk assessment is a record of the identification of hazards and risks associated with chemicals, and the risk controls that have been implemented to mitigate these factors.

Managers/Supervisors need to ensure that all chemicals located in their area of responsibility have chemical risk assessments completed prior to use.

For further support view the Safety Bulletin - Triggers for chemical risk assessment and Safety Bulletin - Chemical risk assessment resource

Detailed guidance is in the Chemical management guidelines. For the University's general Risk Management framework, refer to Implement page within Management System.

Who does the Risk Assessment?

Chemical Risk Assessments must be completed by staff or students who are competent in the risk assessment process, and familiar with the chemical in question and the interaction of that chemical with the activity.

Training may be required - refer to the Chemical management guidelines

When should the Risk Assessment be done?

Before first purchase

A preliminary risk assessment must be performed using the Health & Safety: Pre-purchase checklist before purchasing a chemical for the first time.

Before first use

A detailed risk assessment must be completed before using a chemical for the first time.

For chemicals that have been used before and processes that have been completed before, your area should have a suitable existing risk assessment available. Consult your laboratory manager, OHS Coordinator or supervisor to confirm. If a suitable risk assessment is available, and has been reviewed on the required occasions, you do not need to complete another.

Subsequent review

An existing Risk Assessment should be reviewed at regularly scheduled intervals. Frequency should be determined based on the level of risk, and must not exceed 5 years.

Review is also required when changes to the environment or systems of work occur that affect the effectiveness of previous controls - for examples, see the Chemical management guidelines.

Ensuring the Risk Assessment is available to users

A chemical risk assessment must be kept where all staff and students performing work associated with the chemical can access it. Chemical users need to consult the risk assessment to safely manage the chemical, and to know how to respond in the event of an adverse incident.

Types of chemical risk assessment

Individual

Individual chemical risk assessments are required when chemicals:

• have unique risks
• have unique controls
• are used in a manner other than the intended purpose of the manufacturer or supplier
• are assessed as high risk because there could be severe physical or environmental outcomes from an adverse incident.

New chemical risk assessments can be created in the Enterprise Risk Management System (ERMS) using the WHS Risk module or use the Chemical risk assessment form.

Generic

When a group of chemicals has the same associated risks and controls, and does not meet the criteria for an individual risk assessment, the group may be accounted for collectively using a generic risk assessment.

In deciding whether to use a generic risk assessment, it is important to confirm that the general risk assessment genuinely accounts for all situations and conditions in which each chemical will be used or stored in practice.

Process Chemical Risk Assessment

A process chemical risk assessment is a risk assessment of a chemical process in which multiple activities and/or multiple chemicals may interact. In these cases, it may not be valid or reasonably practicable to complete a separate risk assessment for each chemical involved. Instead, complete a risk
assessment setting out the process steps of the activity. An example of a process chemical risk assessment is available in the Laboratory notebook sample.

Consult the Chemical management guidelines for advice on the following further general requirements for chemical management:

• Purchasing and Acquisition
• Importation
• Manufacture or Supply
• Labeling
• Storage and Handling
• Signage
• Monitoring
• Health Surveillance
• Training
• Waste Management
• Access Arrangements
• Emergency Procedures

What are Dangerous Goods?

Dangerous Goods are substances that present an immediate hazard to people, property or the environment due to properties including flammability, explosiveness, acute toxicity and dangerous reactivity.

Suppliers of Dangerous Goods are obliged to:

• assign a Class, Subsidiary Risk and Packing Group to the goods, which will be represented by a Hazard Class Diamond; and
• pack the goods in a special way that complies with the packaging requirements.

Hazard recognition using Hazard Class Diamonds

In Victoria, Dangerous Goods are grouped into classes based on their dangerous properties. Each class is labelled with a coloured, diamond-shaped Class Label to ensure that people can quickly recognise the dangers it presents.

All Dangerous Goods must be labelled with their appropriate diamond-shaped Class Label.

Class Label visual reference

Illustrations of Class Labels are included in the following chart:

• Dangerous goods classes
• Recognising Dangerous Goods Segregation Chart

The above chart also includes pictograms associated with the national adoption of the Global Harmonisation Scheme (GHS). Refer the chemical management guidelines for more detail.

Compliance requirements for Dangerous Goods in the workplace

To use or store Dangerous Goods in a workplace, you must meet the following requirements:

• This includes determining safety requirements via risk assessment, with reference to the safety data sheet.
• A number of generic risk assessments for Dangerous Goods are available under Forms at the top right side of this page.
• A further set of requirements specific to Dangerous Goods, as described below.

Packaging

In the event that you need to transport Dangerous Goods, you will need to pack the goods according to their Packaging Group classification - refer to the Chemical management guidelines.

Dangerous Goods Manifest

A Dangerous Goods Manifest must be kept listing all Dangerous Goods stored in the workplace. You can fulfill this requirement by keeping a chemical inventory as described under Chemical Inventories (under GoldFFX on this page).

At the University of Melbourne, a Dangerous Goods Manifest is kept in the fire panel of certain designated buildings, to ensure its availability to emergency services. The Building Emergency Controller for each designated building is responsible for keeping the manifest up to date. The Director, OHS and Injury Management, determines which buildings are designated to have this requirement.

Storage

Specific requirements for the storage and handling of dangerous goods are outlined in the chemical management guidelines. Information associated with dangerous goods storage are outlined in the following guidelines:

• Procurement and maintenance of dangerous goods storage cabinets
• Health & Safety: Dangerous good segregation and storage requirements (chart)
• Refer to the Chemical management guidelines for more detailed advice.

Placarding of Buildings and Entrances

• HAZCHEM outer warning placards are required on all entrances to buildings where Dangerous Goods are stored in quantities that exceed the Placarding Quantity. Dangerous Goods Class Labels are also required on or near storage locations whose contents exceed the Placarding Quantity.
• The Placarding Quantity is set out in Schedule 2 of the Dangerous Goods (Storage and Handling) Regulations 2000. This Schedule is available in the Chemical management guidelines.
• To determine whether your building exceeds the Placarding Quantity, you will need to determine the quantity of Dangerous Goods in the building.
• Refer to the Chemical management guidelines for more detailed advice.

What is a hazardous substance?

A Hazardous Substance is a chemical that has the potential to cause harm to a person's health, and which meets the following criteria:

• it is listed on the Safe Work Australia Hazardous Substances Information System (HSIS), and it has a concentration equaling or exceeding the cut-off level for health effects listed in the HSIS;
• it meets the Approved Criteria for Classifying Hazardous Substances (NOHSC:1008[2004])

Exposure to Hazardous Substances usually occurs through inhalation and skin contact or absorption, and can cause immediate or long term health effects.

Storage and handling: Quick reference

Quick reference information for handling and storing Hazardous Substances is available on the chemical storage and handling for minor quantities in laboratories poster. Detailed safety requirements for Hazardous Substances in the workplace should be determined by chemical risk assessment with reference to the Safety Data Sheet.

Compliance requirements for Hazardous Substances in the workplace

Hazardous Substances have the same general requirements for chemical management as all chemicals, in addition to the further requirements described below.

Register of Hazardous Substances

A Register of Hazardous Substances in the workplace must be kept.

You can fulfill this requirement by keeping a chemical inventory.

Labeling

The word HAZARDOUS should be displayed clearly and prominently on the label of all Hazardous Substances.

This is in addition to general labeling requirements set out in the Chemical management guidelines.

Health Surveillance

If any of a certain list of Hazardous Substances is in use in the workplace, health surveillance is required.

Costs of health surveillance are borne by the relevant Division or Faculty.

A list of Hazardous Substances requiring health surveillance is available in the Chemical management guidelines. However, for the most current list please consult Occupational Health.

What is a Scheduled Carcinogen?

Scheduled Carcinogens are a special category of Hazardous Substances.

A Scheduled Carcinogen is a hazardous substance that may cause cancer. Scheduled Carcinogens are listed in Schedule 1 and Schedule 2 of the National Model Regulation for the Control of Scheduled Carcinogenic Substances (NOHSC:1011[1995])

Schedule 1 and Schedule 2 carcinogens have different prohibitions and requirements associated with them.

What are controlled substances?

Controlled substances are substances that are controlled by particular legislation, and include:

• prescription medicines;
• pharmacy-only medicines;
• drugs of dependence; and
• many household, industrial and agricultural chemicals.

Controlled substances are classified into Schedules 1-9, which each have different restrictions associated with them. The broad definition of these schedules appears in the Chemical management guidelines.

The list of controlled substances that fall into each schedule is a combination of the Poisons Code (Vic) and the Standard for the uniform scheduling of drugs and poisons(Cth).

Compliance requirements for controlled substances in the workplace

• Compliance requirements for controlled substances in the workplace

Poisons Licence or Permit

Applications to apply for a new licence or make changes to an existing licence are completed on-line from the Department of Health:

• Licences to possess (and possibly supply) scheduled substances.

Labelling

All controlled substances should display their Poison Schedule on their label.

This is in addition to general labelling requirements set out in the Chemical management guidelines.

Access

Access to Drugs, Poisons and Controlled Substances that require an Industrial and Educational Permit should be restricted to persons who:

• work directly with the scheduled poison;
• have received chemical training;
• have been fully briefed on the chemical risk assessment; and
• are the nominated responsible person, or are staff/students directly under the control of the nominated responsible person.

Records

Transaction records must be kept for Schedule 4, 8 and 9 poisons. For requirements for the content of these records, refer to the Chemical management guidelines.

Records can be kept by either hard copy (eg logbook) or computer provided that they meet the requirements and cannot be altered, obliterated, deleted or removed without detection.

High Consequence Dangerous Goods (HCDG)

What are HCDG?

The term High Consequence Dangerous Goods refers to dangerous goods that are of security concern due to their potential to cause mass casualties and/or destruction.

The following chemicals have been declared to be HCDG:

• ammonium nitrate in concentrations > 45%; and
• calcium ammonium nitrate in concentrations > 45%.

Compliance requirements for HCDG in the workplace

To use or store HCDG in a workplace, you must meet the following requirements:

• All general requirements of chemical management, as described in Chemical Management Key Topics.
• All requirements for dangerous goods, as described in Dangerous Goods.
• Licensing requirements:
  • Victorian tertiary education institutions are exempt from licensing requirements if: the HCDG are used for the purposes of an educational institution, research or testing; and the quantity does not exceed 3 kg per area (laboratory).
  • If these criteria cannot be met, a license will be required. Contact your laboratory manager for further advice.
• If these criteria cannot be met, a license will be required. Contact your laboratory manager for further advice.

Weapons of Mass Destruction

What is a Chemical Associated with Weapons of Mass Destruction?

Chemicals associated with Weapons of Mass Destruction have been scheduled by an international treaty called the Chemical Weapons Convention (CWC).

The CWC schedules, which list the chemicals in question, are available from the Department of Foreign Affairs and Trade publication, Chemical Weapons Convention: A Guide for Industry Producing, Using or Trading Chemicals 2014.

Compliance requirements for Chemicals Associated with Weapons of Mass Destruction

To use or store chemicals associated with Weapons of Mass Destruction in a workplace, you must meet the following requirements:

• A further set of strict laws and constraints, which are described in Chemical Weapons Convention: A Guide for Industry Producing, Using or Trading Chemicals 2014.
• Special Access Arrangements: in addition to the general safety precautions described in the Chemical Management Guidelines, consider reducing the opportunity for theft or other illegal behavior with further security measures such as inventory tracking systems.

What is a Precursor Chemical or Apparatus?

Precursor Chemicals are chemicals that are known to have been used in the illicit manufacture of drugs. Precursor Apparatus are apparatus that can be used to manufacture illicit chemicals.

A current list of affected chemicals and apparatus is available in the Drugs, Poisons and Controlled Substances (Precursor Supply) Regulations 2010 (Vic), which can be accessed via http://www.legislation.vic.gov.au.

Compliance requirements for Precursor Chemicals and Apparatus

Use and storage

To use or store chemicals and apparatus associated with illicit chemical manufacture in a workplace, you must meet the following requirements:

• All general requirements, as described in Chemical Management Key Topics.
• Special Access Arrangements: in addition to the general safety precautions described in the Chemical Management Guidelines, consider reducing the opportunity for theft or other illegal behaviour with further security measures such as inventory tracking systems.

Purchase

When purchasing precursor chemicals or apparatus, you will be asked for an End User Declaration (whose format differs between suppliers).

More details are available in the Chemical management guidelines.