WHAT’S YOUR REACTION?

1. WHAT’S YOUR REACTION? Has recent legislation change precipitated confusion about chemical management in schools? Mandy Timmers Senior Health and Safety Consultant Department of Education, Training and Employment September 2013

2. Session summary 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 :

3. Part 1 What legislation applies now? • 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).

4. What is the Globally Harmonised System? • 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.

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

6. Part 2 What is the impact on schools? • 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

7. What is confusing about the transition from DG to GHS? • Some manufacturers and suppliers have already started using GHS for classifyingchemicals, 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 DGclassifications for transport, safe storage (separation and segregation) and placarding for chemicals.

8. What happens to the SDS? • 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.

9. What label is required? • 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)

10. GHS Labelling changes • 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

11. Labelling challenges • 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)

12. Labelling of small containers • 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.”

13. Management of chemical storage • 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

14. Storage in schools • 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.

15. Placarding 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.

16. Hazardous chemical register 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.

17. Management impacts • 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

18. In summary: • 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.