Chemical Management

Policy

The purpose of this policy is to ensure that risks associated with the storage, handling, use and disposal of chemicals in schools are effectively managed

Summary

• The Occupational Health and Safety (OHS) Act 2004 (Vic), OHS Regulations 2017 (Vic), the Dangerous Goods (Storage and Handling) Regulations 2022 (Vic) and the Dangerous Goods (Explosives) Regulations 2022 (Vic) requires the department to manage the risks associated with dangerous goods and hazardous chemicals stored and used in schools, for example fireworks, methylated spirits, petrol, and aerosol cans.
• The principal and/or their delegate must ensure that these chemicals are identified, recorded on a Chemical Register and the appropriate controls are put in place for their storage, use and disposal.
• The principal and/or their delegate must ensure that there are appropriate emergency procedures in place in the event of a chemical emergency.
• Under the OHS Act 2004, employees while at work must take reasonable care for their own health and safety and the safety of others who may be affected by their actions or omissions.
• Central and regional offices provide a range of supports and services to assist principals and employees to be safe and well, including access to the OHS Advisory Service and local OHS regional officers, who can provide free advice on managing risks related to dangerous goods and hazardous chemicals.
• The Chemical Management Procedure (in the Procedure tab) must be followed, and sets out the practical step-by-step instructions for implementing this policy.
• This policy forms part of the department’s OHS Management System. Refer to OHS Management System (OHSMS) Overview for further information.

Details

The principal and/or their delegate must ensure that:

• all dangerous goods and hazardous chemicals in the workplace are identified in consultation with the Health and Safety Representative(s) and employees
• for all chemicals onsite, the Safety Data Sheets (SDS) (issued within the last five years) are accessible
• hard copies of current SDS for dangerous goods and hazardous chemicals and from the manufacturer or supplier are maintained and accessible to those people required to use the chemicals
• all dangerous goods and hazardous chemicals are recorded in the school’s Chemical Register, or equivalent template
• chemicals on the prohibited or restricted list are not stored or used at the school (refer to Guidance Sheet 3 Prohibited and Restricted Chemicals)
• a risk rating is assigned for the storage and handling of each chemical in the Chemical Register
• a Safe Work Procedure is completed (using the Safe Work Procedure Template) for the storage and handling of dangerous goods and/or hazardous chemicals with a high or extreme risk rating as identified in the Chemical Register.
• no new dangerous goods and/or hazardous chemicals are introduced into the workplace without first obtaining the manufacturer’s SDS and completing the OHS Purchasing Checklist template. Information from the SDS should be used to determine if the chemical can be safely introduced into the workplace
• the OHS Purchasing Checklist is used to assess the level of risk prior to buying new chemicals for the workplace
• the risk controls identified in the Chemical Register are implemented
• all dangerous goods and hazardous chemicals are labelled, including storage containers, mixtures of chemicals, decanted chemicals and enclosed systems and appropriate signage is displayed (if required)
• chemicals no longer in use are correctly disposed of and minimal quantities of chemicals are stored on site by regularly reviewing the chemicals held in storage
• appropriate storage areas are provided for chemicals (for example, flame proof chemical cabinets, corrosion resistant cabinets and fire risk dangerous goods are stored at least five metres away from ignition sources) and incompatible chemicals are appropriately segregated, refer to Guidance Sheet 1 Chemical Storage and Guidance Sheet 2 Dangerous Goods Classification System
• emergency management procedures are in place for chemicals stored and used on site (for example, identification of fire wardens and evacuation points)
• emergency management equipment like spill kits / containment areas are available
• training and Personal Protective Equipment (PPE) is provided for employees who may be exposed to dangerous goods and hazardous chemicals
• there is a process for incidents to be reported to the principal and/or their delegate and logged on eduSafe
• WorkSafe are notified of the escape, spillage or leakage of any substance including dangerous goods
• ventilation (mechanical and natural) is in place for the safe use and storage of chemicals (for example, fume cupboards, exhaust fans). More detailed information can be found in Guidance Sheet 1 Chemical Storage.

The Chemical Management Procedure provides further information on the process for meeting the above requirements.

Definitions

Dangerous goods
Dangerous goods are substances that may present an immediate safety hazard through exposure to their explosive, flammable, radioactive, corrosive or toxic properties.

They are easily recognisable by the diamond shaped sign displayed on the substance label. They are designated into nine classes according to their immediate physical or chemical effects.

For further information, refer to Guidance Sheet 2 Dangerous Goods Classification System.

eduSafe Plus
The department’s online hazard and incident reporting and management application, accessible on the intranet at eduSafe Plus. Employees log on using their employee number and password.

Emergency management procedures
Procedures in place to manage hazardous substances and/or dangerous goods spills and leaks (i.e. spill containment, spill kits, spill clean-up, appropriate disposal) including local emergency management plan detailing evacuation directions, medical treatment and assistance and alerting emergency services.

For further information, refer to:

• Guidance Sheet 4 Chemical Spill Management
• Guidance Sheet 5 Major Chemical Spill Management
• Guidance Sheet 6 Hazardous Chemical Disposal.

Hazardous chemicals
Hazardous chemicals are classified based on their health effects, both short and long term. They can enter the human body through inhalation, ingestion and contact through the skin and mucous membranes such as the eyes. The level of subsequent risk depends upon both the substance itself and the nature of the work being done with it.

Examples of types of hazardous chemicals (depending on their concentration) include:

• acids
• caustic substances
• disinfectants
• herbicides and pesticides
• solvents and thinners.

Safety Data Sheet (SDS)
A document prepared by the manufacturer, importer or supplier of a dangerous good, hazardous substance or other chemicals. A SDS describes the properties and uses of a particular substance including details about substance identity, chemical and physical properties, health hazard information and precautions for storage, use and safe handling.

Related policies

• Contractor OHS Management
• Mosquito Risk Management
• OHS Induction and Training
• OHS Management System (OHSMS) Overview
• OHS Purchasing
• OHS Risk Management

Related legislation

• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)
• Dangerous Goods Act 1985 (Vic)
• Dangerous Goods (Storage and Handling) Regulations 2022 (Vic)

Chemical Management Procedure

Overview

The Chemical Management Procedure must be followed, and sets out the practical step-by-step instructions for implementing this policy.

It contains the following chapters:

1. Identify dangerous goods and hazardous chemicals
2. Establish/review the chemical register
3. Obtain safety data sheets
4. Prohibited and restricted chemicals
5. Procurement of dangerous goods and hazardous chemicals
6. Risk assessment of dangerous goods and hazardous chemicals
7. Controlling risks associated with dangerous goods and hazardous chemicals and their mixtures
8. Emergency procedures
9. Consultation, information and training
10. Record-keeping
11. Legislation, codes of practice, standards and guidance

1 Identify dangerous goods and hazardous chemicals

The principal and/or their delegate must ensure that all dangerous goods and hazardous chemicals are identified within the workplace.

Examples of locations where dangerous goods and hazardous chemicals may be found include:

• art rooms
• classrooms
• kitchens/canteens
• maintenance/garden sheds
• materials technology areas
• photographic dark rooms
• science laboratories
• storage areas (including the cleaner’s cupboard)
• swimming pool plant and/or storage room

Note: There are a number of prohibited substances which must not be stored or handled in any school, see Section 4 of this Procedure.

2 Establish/review the chemical register

The principal and/or their delegate must ensure:

• details of all dangerous goods and hazardous chemicals stored or handled in the school are entered into a Chemical Register
• the Chemical Register is reviewed when new or additional quantities of chemicals are introduced into the school, or when risk controls have changed, or are no longer effective

3 Obtain safety data sheets

The principal and/or their delegate must ensure a hard copy collection of current Safety Data Sheets (SDS) from the manufacturer or supplier is maintained. Current means first prepared, or reviewed, within the last 5 years.

The SDS obtained for each dangerous good and hazardous chemical must be the authorised version prepared by the manufacturer or first supplier within Australia. Where a SDS has not been provided by the manufacturer or supplier, a SDS can be obtained from GoldFFX (ChemWatch — staff login required).

The principal and / or their delegate must ensure the Chemical Register and associated SDS are kept in a suitable location which is known, and accessible to all employees in the school, as well as any other relevant party who is likely to be exposed to the dangerous goods and/or hazardous chemicals.

4 Prohibited and restricted chemicals

Some chemicals are prohibited or restricted for use in schools due to the level of risk, refer to Guidance Sheet 3 Prohibited and Restricted Chemicals.

If any listed prohibited chemicals are found in the school, it must be immediately disposed of following advice from local government authorities or chemical disposal agent.

5 Procurement of dangerous goods and hazardous chemicals

The principal and/or their delegate, in consultation with the Health and Safety Representative (HSR) and employees, must ensure that no new dangerous goods and / or hazardous chemicals are introduced into the school without first obtaining the manufacturer’s SDS and completing the OHS Purchasing Checklist template.

Information from the SDS should be used to determine if the chemical can be safely introduced into the school.

6 Risk assessment of dangerous goods and hazardous chemicals

6.1 Risk assessment of, and Safe Work Procedure for the storage and handling of dangerous goods and hazardous chemicals

The principal and/or their delegate are to ensure that a Safe Work Procedure is completed for the storage and handling of dangerous goods and/or hazardous chemicals with a high or extreme risk rating as identified in the Chemical Register. The Safe Work Procedure Template can be used for this purpose.

Note: Refer to the Instructions tab in the Chemical Register labelled ‘Risk Assessment and Additional Information’ for further instructions on the risk assessment of a ‘single’ chemical for the purpose of purchasing, storing or using it.

In order to complete the Safe Work Procedure Template, the SDS must be reviewed to determine whether or not the handling and storage requirements defined within the SDS can be met by the school and/or other persons such as employees, students, contractors, volunteers who may be exposed to, or use the chemical.

6.2 Risk assessment for the preparation of chemical mixtures

The principal and/or their delegate in consultation with the HSR and employees must ensure that a risk assessment using the Risk Assessment Template, or equivalent is conducted by employees who, as part of their role, are required to prepare chemical mixtures (for example, school gardener preparing a dilution of herbicides for weed spraying) containing dangerous goods and/or hazardous chemicals or products which fall into these categories.

If the risk assessment identifies the process as a high or extreme risk, then a Safe Work Procedure (SWP) must be completed using the Safe Work Procedure Template.

6.3 Risk assessment for science experiments

The principal and/or their delegate must ensure that a risk assessment is conducted using the Risk Assessment Template or equivalent by the Science Coordinator and/or Science Teachers for any new or existing science experiments in the classroom.

Laboratory Technicians must ensure that a risk assessment is conducted for the preparation of chemicals that are to be used in science experiments in the classroom. If the risk assessment identifies the process as a high or extreme risk, then a safe work procedure must be completed using the Safe Work Procedure Template.

7. Controlling risks associated with dangerous goods and hazardous chemicals and their mixtures

The principal and/or their delegate, in consultation with the HSR and employees are required to reduce risks, so far as reasonably practicable, in accordance with the information provided in the SDS, from dangerous goods and/or hazardous chemicals and their mixtures.

When determining controls to reduce risks the hierarchy of controls outlined in the OHS Risk Management Procedure should be followed.

Examples of effective control actions (from most to least effective) include:

• Elimination: Eliminate the use of the chemical (for example, using a physical process instead of a chemical process)
• Substitution: Use a safer chemical or a safer form of the chemical (for example, using a detergent instead of chlorinated solvent for cleaning)
• Engineering: Physical controls that eliminate, isolate or reduce exposure to people or property (for example, provision of drip trays to limit the area of contamination in the event of spills and leaks, using a local exhaust ventilation system such as a fume cupboard)
• Administrative: use the developed Safe Work Procedure and provide training in the safe use and storage of the chemical
• Personal Protective Equipment-PPE: protective clothing and equipment for employees, students, contractors, volunteer workers and visitors (for example, overalls, gloves, chemical-resistant safety glasses)

7.1 Safe application of pesticides and herbicides

The principal and/or their delegate must ensure that all pesticides and herbicides:

• are labelled correctly (if they are diluted) — refer to section 7.5 of this procedure
• have current SDS available for employees using them (for example, gardener)
• are scheduled for use on weekends, or during school vacations, or outside school hours, preferably after school on Fridays, to protect students and employees from unnecessary exposure
• are scheduled for use on still days.

Where necessary, application of pesticides and herbicides may occur during school hours to mitigate real or perceived risks to human health, such as in response to mosquito activity where increased risk of mosquito-borne disease is evident.

7.1.1 Safe application of herbicides

The principal and/or their delegate must ensure that:

• licensed operators for application of the following pesticides: 2; 4-D; Paraquat and Diquat. These two herbicides are highly toxic, with paraquat being one of the most toxic herbicides in agriculture.
• registered herbicides for the weeds requiring control. For restricted non-schedule 7 agricultural chemicals refer to: Department of Primary Industries (Agriculture Victoria).

7.1.2 Safe application of pesticides

At times it may be necessary to use pesticides when other measures (hand removal or water jets) fail. Pesticides should only be used in accordance with the label and the pest should be clearly identified to ensure correct control measures. The principal and/or their delegate must ensure that only appropriately registered pesticides are used.

The following information describes alternate and recommended insectides:

Pyrethroids
Obtained from the dried flowers of some chrysanthemum species and effective against a wide range of insects, including:

• aphids
• caterpillars
• bugs.

Important: Pyrethoids are plant products that may cause allergic reactions

Synthetic pyrethoids
Man-made analogs of natural pyrethroids designed for longer life or improved control. All registered synthetic pyrethroids are safe if used according to the label.

Garlic spray
Can be applied with a mild detergent and is effective against caterpillars and sucking insects

White oil
Useful against scale, mealy bugs and aphids. Can sometimes be mixed with pyrethroids and synthetic pyrethroids to increase its effectiveness against a wide range of pests. Check the labels to determine whether this can be done.

Derris (Rotenone)
As it is a stomach poison, it is effective against chewing pests

Soap flakes spray
Occasionally useful in the control of some caterpillars and other larvae

Note: Any pesticides registered for use in domestic premises can be safely used in schools. Some pesticides are best left to licensed pest control technicians, for example termiticides. For information on on termicides refer to the Protocol for Use of Termicides in Schools (in the Resources tab).

7.2 Fireworks safety management

Fireworks are defined in the Dangerous Goods (Explosives) Regulations 2022 (Vic) and contain one or more explosives with or without other substances.

The principal and/or their delegate must ensure that OHS risk controls are implemented for the use of fireworks in schools including:

• engaging a licensed pyrotechnician for fireworks use. The licensed pyrotechnician must not discharge fireworks without written approval from WorkSafe and the local council
• managing the licensed pyrotechnician per the Contractor OHS Management Policy
• checking with their local council, on any time and place restrictions, if they wish to use fireworks.
• providing fire protection and suitable means of firefighting
• controlling spectators, by barriers if necessary, and kept at a safe distance from the fireworks discharge point
• providing security against unauthorised access to the discharge point or storage area
• searching of the display site for unfired fireworks is conducted at the end of the display.

7.3 Exposure standards and atmospheric monitoring

The principal and/or their delegate must ensure that employees are not exposed to atmospheric concentrations of a substance that are above the exposure standard (if any), for that substance.

Further information on exposure standards is available from Workplace Exposure Standards for Airborne Contaminants accessible on the Hazardous Chemical Information System (HCIS).

If there is uncertainty as to whether the exposure standard is or may be exceeded, atmospheric monitoring is required to determine whether there is a health risk.

7.4 Health surveillance

The principal and/or their delegate must refer to the current SDS for the hazardous chemicals to determine the health surveillance requirements for any employees exposed to any hazardous chemical in the school.

7.5 Labeling

The principal and/or their delegate must ensure that all dangerous goods and hazardous chemicals storage containers are clearly labelled. The label on the container in which the dangerous good and/or hazardous chemical is supplied must remain intact, legible and unaltered. The date of receipt of a hazardous chemical should be marked on the original container to allow for monitoring of the age of the chemical and promote the use of older materials first.

The principal or their delegate must ensure that all mixtures of chemicals and decanted chemicals are correctly labelled unless used immediately, including the product name and Dangerous Goods Class/Division (if applicable).

Where chemicals are decanted, the container must be suitable for the chemical contents and preferably be of a type that is recommended by the manufacturer or supplier. For further information, refer to: Guidance Sheet 2 Dangerous Goods Classification System.

Containers with unknown substances in them should be labelled ‘CAUTION DO NOT USE: UNKNOWN SUBSTANCE’ and then disposed of in accordance with Guidance Sheet 6 Hazardous Chemical Disposal.

7.6 Labeling of enclosed systems

The principal and/or their delegate must ensure that dangerous goods and/or hazardous chemicals contained in an enclosed system (such as a pipe or piping system or a process) are identified and labelled accordingly.

Suitable means of identification include colour coding (AS 1319, Safety Signs for the Occupational Environment) and labelling (AS 1345 Identification of the Contents of Piping, Conduits and Ducts).

7.7 Storage

The principal and/or their delegate must ensure that storage of chemicals is conducted in accordance with Guidance Sheet 1 Chemical Storage.

Where possible, the principal or their delegate must ensure that only minor storage quantities of dangerous goods are maintained in the school. Storage quantities should be kept to a minimum to cater for demand and excessive storage for long periods should be avoided.

If quantities exceed minor storage contact the Department OHS Advisory Service on 1300 074 715 as there may be specific safety and legislative requirements that apply.

7.8 Signage

The principal and/or their delegate must ensure that if the school is storing dangerous goods exceeding minor storage quantities, placards are provided as a visual warning.

The principal and/or their delegate must ensure that all purpose-built cupboards, cabinets and refrigerators for storing chemicals are labelled to indicate the type and class of chemicals being stored in them. Additional warning signs may also be required, such as ‘DO NOT USE TO STORE FOOD’.

7.9 Chemical waste and disposal of chemicals

The principal and/or their delegate must ensure that chemical waste is properly packaged, labelled and stored in suitable designated areas whilst awaiting collection. Labelling must include at a minimum the product identifier, workplace details and a hazard pictogram consistent with the correct classification of the chemical (if relevant).

Chemical waste must not be mixed with other chemical waste with an incompatible Dangerous Goods classification. Personal Protective Equipment (PPE) must be used when handling chemical waste as per the SDS.

The principal and/or their delegate must ensure that containers of waste produced or generated at the school are correctly labelled with the product name and Dangerous Goods Class/Division (if applicable).

The principal or their delegate must ensure dangerous goods, hazardous chemicals and chemical waste are disposed of as per the SDS and with reference to Guidance Sheet 6 Hazardous Chemical Disposal.

8 Emergency Procedures

The principal and / or their delegate in consultation with the HSR and employees, must ensure that appropriate emergency management provisions are available for use in the event of a chemical emergency. The emergency management provisions may include:

• spill kits or containment equipment
• safe work procedures for spills or release of chemicals
• fire blankets / extinguishers
• first aid kits
• eye wash stations / eye wash kits / emergency showers
• emergency shutdown procedures for equipment
• appropriate numbers of trained emergency wardens and first aiders
• appropriately displayed emergency contact details
• PPE

Refer to Guidance Sheet 4 Chemical Spill Management and Guidance Sheet 5 Major Chemical Spill Management for additional information.

The principal and / or their delegate must ensure that all fire protection equipment is maintained in an operable condition and that all relevant emergency contact telephone numbers are displayed in prominent locations at the school (for example, where the chemicals are stored).

9 Consultation, information and training

The principal and/or their delegate must ensure that arrangements are in place for consultation with the HSR and employees, in relation to chemical management. Consultation should occur in relation to:

• the introduction of new chemicals to the school
• the identification and assessment of risks associated with chemicals at the school
• development of Safe Work Procedures
• decisions about control measures to be implemented
• induction and training requirements

The principal and/or their delegate must ensure records are maintained of any such consultation i.e. meeting minutes, emails, induction checklist, purchasing checklist etc. For general requirements related to consultation, refer to the OHS Consultation and Communication Procedure.

Where employees are required to use dangerous goods and/or hazardous chemicals or where employees may potentially be exposed to dangerous goods and/or hazardous chemicals in the school, the principal or their delegate must ensure employees are trained in the safe use and storage of that chemical. This training is to include:

• the requirement for, and type of information provided on labels of products
• the location of, and how to read the SDS for dangerous goods and hazardous chemicals
• the nature of the hazards and risks associated with the tasks being performed
• the control methods required to reduce the risk of an incident, near miss or harm to human health occurring (for example, SWP to be followed in the use, storage, transport and disposal of dangerous goods and hazardous chemicals)
• the proper use and fitting of PPE
• first aid treatment, incident reporting procedures and emergency management protocol to be followed in case of a spill or release of chemicals or injury or illness arising from an exposure to chemicals

Records of this training are to be kept and maintained by the principal or their delegate per the OHS Induction and Training Procedure.

10 Record-keeping

The principal and/or their delegate must ensure the following records are maintained in relation to dangerous goods and hazardous chemicals in the school:

• risk assessments
• Safe Work Procedures
• consultation records
• purchasing records
• training records
• Chemical Register and SDS
• any atmospheric monitoring / health surveillance records (if applicable)
• inspection and testing records for engineering controls

11 Legislation, codes of practice, standards and guidance

• Dangerous Goods Act 1985 (Vic)
• Dangerous Goods (Explosives) Regulations 2022 (Vic)
• Dangerous Goods (Storage and Handling) Regulations 2022 (Vic)
• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)
• Code of practice for the storage and handling of dangerous goods 2013 (Vic)
• Australian Dangerous Goods Code 7th Edition (ADG7 Code)
• Australian Standard 1319:1994 Safety Signs for the Occupational Environment (PDF)
• Australian Standard 1345:1995 Identification of the Contents of Piping, Conduits and Ducts (PDF)
• Hazardous Chemical Information System (HCIS) Safe Work Australia

Resources

Templates relevant to this policy and procedure

• Chemical register (XLSX) – a template that schools can use to record chemicals
• OHS Purchasing checklist template (DOCX) – must be completed where new dangerous goods and/or hazardous chemicals are introduced into the school
• Risk Assessment template (DOCX) – conducted by employees who , as part of their role, are required to prepare chemical mixtures (for example, a school gardener preparing a dilution of herbicides for weed spraying) containing dangerous goods and/or hazardous chemicals
• Safe Work procedure template (DOCX) – must be completed for the storage and handling of dangerous goods and/or hazardous chemicals with a high or extreme risk rating as identified in the Chemical Register

Guidance sheets

• Guidance Sheet 1 Chemical Storage (DOCX)
• Guidance Sheet 2 Dangerous Goods Classification System (DOCX)
• Guidance Sheet 3 Prohibited and Restricted Chemicals (DOCX)
• Guidance Sheet 4 Chemical Spill Management (DOCX)
• Guidance Sheet 5 Major Chemical Spill Management (DOCX)
• Guidance Sheet 6 Hazardous Chemical Disposal (DOCX)

Guideline

Termiticides in Schools Guidelines (DOCX) – provides guidance for effective and safe control of termites in schools

Websites

• Department of Primary Industries (Agriculture Victoria) – has a list of restricted non-schedule 7 agricultural chemicals
• Workplace Exposure Standards for Airborne Contaminants accessible on the Hazardous Chemical Information System - further information on exposure standards
• Chemwatch MSDS database (staff login required) – Material Safety Data Sheets