Have you started storing dangerous goods 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, 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.

Insight #1_Organise your storage area

Otherwise known as housekeeping, along with placarding and labelling, will make your storage area look professional and in control.

• Label storage areas with dangerous goods (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 

Waste storage is still considered dangerous goods and should be handled with the same risk controls (e.g. spill containment and fire protection)

Insight #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
  • Emergency procedures

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

Insight #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:
  • Placards
  • Manifests
  • Licences and notifications to regulators

You can identify the DG class by identifying class diamonds on packaging and container labels, the SDS, or transport documentation

Insight #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 (here).

Risk controls include:

• Spill kits
• Fire protection
• Emergency/evacuation procedures
• PPE etc

Insight #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.

Your existing workplace health and safety procedures (OH&S, or HSE) will form an important part of your dangerous goods management system

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Insight #6_Monitor & 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
• Did you know: a practice drill of the emergency evacuation plan should be conducted annually, and your local fire brigade is happy to provide advice and feedback, particularly if you are storing dangerous goods.

A practice drill of the emergency evacuation plan should be conducted annually, and your local fire brigade is happy to provide advice and feedback, particularly if you are storing dangerous goods

Disclaimer

The information in this article is not intended to be used as a complete guide, it won’t suit every storage situation or type of storage, it contains recommendations of a general nature.  Compliance requirements and safety standards can only be met by applying professional advice specific to each storage situation.

If you’d like more information or require advice for your dangerous goods management system, please contact us here.