Chemical Management

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.