Chemical management

Definitions

Chemical safety uses terms that have slightly different meanings from their common use ones as defined below.

Term/Acronym Definition
APVMA Australian Pesticides and Veterinary Authority
ARPANSA Australian Radiation Protection and Nuclear Safety Agency
Chemicals of Security Concern This is a list of chemicals that have been used to make bombs or toxic weapons. 15 are categorised as particularly high risk and 81 as high risk.
Dangerous Goods Chemicals assigned to one of 9 classes based on harmful action e.g. flammable liquids (DG class 3) or toxics (DG class 6.1).
License Authorisation to make and/or sell types of poisons
M/SDS Material Safety Data Sheet/Safety Data Sheet
Manifest Quantities A quantity of dangerous goods greater than the quantity specified in relation to those goods in the column headed ‘Manifest Quantity in Schedule 1 - Storage and Handling Regulations, 2007.
Permit Authorisation to use and hold types of poisons
PG Packing Group - this is the grading of danger within a class of division according to the relative hazard presented by the material. It is represented by roman numerals. I = great danger, II = medium danger, and III = minor danger.
Placarding Panel fixed to a building, vehicle, or container to alert people that it holds dangerous goods at or above a legislative threshold. The threshold is different for different substances; more hazardous substances have 
a lower placarding threshold than less hazardous ones.
Precursor chemical A chemical which can be used to make illicit drugs or chemical weapons.
RED The most dangerous colour banding category within the ChemAlert system. Red items pose significant 
health problems if a user is exposed to them.
S2-S9 Schedules of poisons outlined is the SUSMP from the TGA.
Schedule 10.1, 10.2, 10.3 Schedules of carcinogens outlined in the Work Health & Safety (General) Regulations 2022.
SUSMP Standard for the Uniform Scheduling Medicines and Poisons
TGA Therapeutic Goods Administration
  • Roles and responsibilities

    UWA and all Workers have obligations under the WHS Act to manage chemicals safely and thus reduce the risks they pose to themselves and others.

    Role Responsibilities
    Senior Executive Management To seek assurance from Heads of Schools, Heads of Research or Business Unit Directors that chemical risks within their portfolio are being appropriately managed. 
    Heads of School, Heads of Research and Business Unit Directors etc. To ensure all chemical risks within their work area are managed by responsible Managers/ Supervisors.
    Managers / Supervisors  To communicate and consult with Workers to understand chemical hazards in their area and ensure appropriate risk controls are implemented in a timely manner. Managers / Supervisors must monitor, and review controls implemented to ensure risks are abated. 
    Staff and Students  To identify, assess and where possible control hazards and risks within their area of work.
    Where the implementation of risk controls exceeds a Worker’s capability or authority to manage identified hazards, they must work with their immediate Manager / Supervisor and/or UWA Management in managing identified risks.
    Visitors  To report all chemical hazards, incidents or near misses they are involved in to the local area UWA Staff.

    Legislation, standards and policies

    Refer to the links below. Please note that printed copies are uncontrolled.

    Links Relevant information
    Legislation
    Acts can be found on the Department of Justice's website, follow the link above 

    Dangerous Goods Safety Act 2004 (WA)
    Work Health and Safety Act 2020 (WA)
    Work Health & Safety (General) Regulations 2022 (WA)

    Standards and Codes of Practice
    Standards can be accessed using TechStreet, follow the link above for more information

    Codes of Practice can be accessed at WorkSafe.

    AS/NZS 2243.10 Safety in Laboratories Part 10: Storage of chemicals. 
    AS1940: The storage and handling of flammable and combustible liquids.
    AS3780: The storage and handling of corrosive substances.
    AS/NZS ISO 45001 - Requirements with guidance for use OHS Management systems.
    Managing risks of hazardous chemicals in the workplace 2020. SafeWork Australia.
    Control of Scheduled Carcinogenic Substances [NOHSC:2014(1995)].
    Labelling of workplace hazardous chemicals.
    Managing risks of hazardous chemicals in the workplace.

    Guidance Notes
    Approved Guidance Notes can be accessed at WorkSafe.

    Assessment of health risks arising from hazardous substances.
    UWA Policies
    UWA Policies can be found in the Policy library, follow the link above
    UWA Safety & Health Policy
    UWA Safety & Health Strategic Plan 2021 to 2025
    UWA Safety & Health Leadership and Governance Framework
  • Risk management and emergencies

    Chemical safety training

    All staff and students must complete the following training and be assessed as competent prior to working with chemicals.

    Training Course For When Details
    Local Area WHS Induction All staff and students On the first day of commencing work (or the first week if fully supervised when on premises) Condcut a local area WHS induction
    UWA Safety and Heath Induction All staff As a new starter, refresher required every 2 years Comple the mandatory staff Safety and Health induction
    UWA WHS Risk Management Training Managers / Supervisor / Senior Leaders / Executives As a new starter in a manager/supervisor role, refresher required every 2 years Complete the UWA WHS Risk Management training module
    UWA Laboratory Safety Course Staff and students Before working in a laboratory, refresher required every 5 years Laboratory Safety Course
    ChemAlert Training Staff and students Before working with chemicals Access ChemAlert

    Safety data sheets (SDSs)

    An SDS must be available for all hazardous or dangerous items that are used or stored in your area. SDSs may be supplied as electronic or paper copies and must be <5 years old.

    Accessing safety data sheets

    The SDS file is found on thereports tab of the product details for the ChemAlert entry for an item.To retrieve a SDS go to ChemAlert and search for your product. If the SDS product is not available you may request its addition by contacting [email protected]

    Many SDSs are also available electronically from the websites of the manufacturers or suppliers. To have one uploaded to the ChemAlert system contact [email protected].

    Chemical risk assessments

    During the planning of any procedure involving chemicals and prior to purchase, potential hazards must be identified, and the risks assessed. This ensures that all staff, students and visitors are aware of potential hazards, and that appropriate handling techniques and control requirements are in place to minimise risk to personnel and University property.

    Refer to complete a chemical risk assessment.

    Chemical Emergency Prevention Measures

    In addition to UWA Safety general emergency procedures, the following should be available in your local area:

    • Emergency numbers prominently displayed.
    • First aid supplies, and training, are suitable for the chemicals used and stored.
    • Suitable spill kits are available
    • Remoteness or other complicating factors have been considered when developing your emergency procedures.
    • Any other emergency procedures and requirements (as outlined in the SDS) are available.

    Health Monitoring

    Where monitoring is required, baseline samples must be taken prior to working with the reagent and a sample schedule has been organized. Records must be kept for thirty years for each person who works with substances requiring health monitoring.

    Check the following links to determine if health monitoring is required:

    Scheduled carcinogenic substances

    Refer to the section below on Dangerous goods and chemicals of high consequence or concern: carcinogens, mutagens and teratogens.

  • ChemAlert

    ChemAlert is an online program available to all UWA staff, students and visitors for the management of chemicals via the intranet and the retrieval of Safety Data Sheets (SDS).

    The ChemAlert program should be used for:

    • maintenance of chemical inventories
    • retrieval of current SDS
    • label printing for hazardous substances and dangerous goods
    • management of storage and segregation of dangerous goods.

    It is also a necessary tool for assisting in development and completion of:

    • Chemical risk assessments
    • Annual chemical audits
    • Emergency protocols
    • Waste disposal protocols
    • Chemical safety training

    ChemAlert can also be used for:

    • add chemicals made in-house to an inventory
    • manage risk assessments
    • access region-specific product details and reports
    • access links to many resources for e.g., changes in legislation

    Some of the features require a username and password.

    To access the full functions of ChemAlert, including training for the program, refer to Access ChemAlert.

  • Procurement, permits and licenses

    Procurement

    Before acquiring any chemical, ensure you are aware of the following:

    Before acquiring Your laboratory has suitable storage and all necessary permits/licences if required
    Chemical is suitable for purpose
    People in your laboratory are trained to handle it safely
    You are aware of the cost to dispose this item
    At time of acquisition Chemical has a compliant label
    SDS provided with chemical, or before collection
    After acquiring Store appropriately
    Add to you ChemAlert holdings inventory with a UWA chemical barcode.
    Advise people in your laboratory of any hazards
    Dispose of safely

    For more information on how to submit a purchase order, refer to Purchase Goods and Services.

    Permits and licenses

    You must have a permit to purchase and use the following types of chemicals. Ensure the necessary permits or licences are arranged before you import or export a chemical.

    Concessional Spirits

    Drugs and Scheduled Poisons

    Some Agricultural and Veterinary Chemicals, including chemicals of Security Concern and Chemical Weapons Precursors

  • Storage

    Segregation

    Refer to the AS/NZS 2243.2:2021 and specifications from the manufacturer/supplier:

    • Segregate wet chemicals from dry

    • Store liquids below dry reagents

    • Where necessary store bunded or on deep trays to contain spills/leaks 

    Dangerous Goods

    • Dangerous Goods must be separated and segregated according to quantities and incompatibilities listed in section 10 of the SDS 

    • Store in dangerous goods cabinets where appropriate. Chemical cabinets must meet the relevant Australian Standards (AS1940 and AS3780).

    Gas cylinders

    • Pressurised gas cylinders must be secured. Where possible have gas piped into a lab.

    Signage/placarding

    • Entry signage is in place and up to date. Contact [email protected] for guidance on entry signage. 

    • Cupboards, lockers, and refrigerators used for storing chemicals are signed to indicate the type of chemicals (e.g. Class) being stored. 

    • Additional signs where required, e.g. “do not use to store food”, are displayed. 

    • Where manifest quantities of dangerous goods are stored appropriate placarding is displayed. 

    Holdings

    • Ensure that your ChemAlert site holdings are updated annually. 

    • Match the item to the same supplier and product number. 

    • If your chemical isn't available in the ChemAlert database, contact [email protected] to have it added. 

    • Report loss or diversion of chemicals of concern to your laboratory/facility managers. 

    Controlled storage and access requirements

    By law access to the following must be strictly controlled and documented

    • scheduled carcinogens 

    • some scheduled poisons 

    • radioactive materials 

    • precursor drugs 

    Holdings of Chemicals of security concern, including Ammonium Nitrate fertilisers, must be secured, and stocks regularly reconciled to detect theft or diversion. 

    Access to scheduled veterinary chemicals must be limited to only registered veterinary practitioners or staff/students directly under their control.

  • Labelling

    Correct labelling of all chemicals is critical to workplace safety, is a legal requirement and avoids costly disposal of unknown products.

    There are different labelling requirements for hazardous and non-hazardous substances and also for chemical wastes.

    Commercially available chemicals should be appropriately labelled by the manufacturer and will not generally require relabelling. If a label is damaged, obscured, or chemicals are decanted into a new container or used to make a new solution, a new label is required. This procedure supplies the information that is required for different types of chemical products, and how to print labels out.

    Labelling hazardous substances

    Hazardous substances are required by law to be labelled with the following information:

    • signal word(s) and/or dangerous goods class label
    • product name, chemical name, United Nations Number, ingredients
    • risk phrases and safety phrases
    • directions for use*, first aid procedures and emergency procedures*
    • details of manufacturer or importer
    • expiry date (where relevant)* and reference to Safety Data Sheet (SDS).

    The above are required by law on the label of any hazardous substance in a container 500ml or 500g or larger. If the container is smaller than this the asterisked (*) information can be omitted from the label. If the container is too small to have a label attached (i.e. 1ml microcentrifuge tube), legislation requires that the label be tied to the container with string, or that the container is placed in an appropriately labelled outer container (refer to Work health and Safety (General) Regulations 2022 and National Code of Practice for the Labelling of Workplace Substances).

    Labels containing the required information can be printed for chemicals using ChemAlert by:

    1. opening ChemAlert
    2. entering the chemical requiring a label into the terms to search box
    3. right-clicking on the product requiring a label and selecting view/print product report
    4. selecting the desired label size from the Report Type drop-down box
    5. clicking on the label setup button and selecting the desired number of labels
    6. and clicking view/print button.

    ChemAlert labels can be printed onto Avery Parcel Label sheets which come in a variety of sizes (1, 4, 8 etc per A4 sheet) and types (laser, colour, clear, waterproof).

    Labelling non-hazardous substances

    Since non-hazardous substances should pose little threat to personnel there have less stringent labelling requirements. Non-hazardous substances are required to be labelled with the following information:

    • full chemical name and concentration of constituents (abbreviations and chemical symbols/structures are not adequate)
    • name of the user and contact number
    • date
    • location (school/section, building, lab number).

    Non-hazardous substances can be labelled with a label from ChemAlert. However, templates for printing labels of various sizes are available at the bottom of this page. These labels can be filled in electronically and printed onto label paper or printed and filled in by hand, providing a quick and easy solution to correctly labelling your non-hazardous substances.

    Labelling chemical waste

    All chemical wastes must be correctly labelled to ensure the safety of personnel and to prevent costly disposal of unknown substances. Waste containers should be labelled before waste is collected and as far as practicable chemical wastes should be segregated (refer to the section below on Chemical Management: Disposal).

    Offsite chemical waste disposal is coordinated through Safety and Health for the University. Items that do not display a completed and correct UWA chemical waste label will not be collected.

    Non-hazardous substance label templates

    Non-hazardous substance labels (4 per A4 sheet)

    Non-hazardous substance labels (8 per A4 sheet)

  • Audits of inventory

    Annual local chemical stocktake

    It is essential that an annual chemical stocktake is conducted in your local area to ensure the safety of all personnel and compliance with legislative requirements for the storage and use of chemicals.

    The role of the annual stocktake within the chemical management system is to ensure that:

    • the inventory of chemicals in your workplace is accurate
    • Safety Data Sheets are current and available for all substances
    • all substances are appropriately labelled
    • substances are correctly stored and dangerous goods segregated
    • products no longer in use are disposed of appropriately.

    Annual chemical stocktake procedure using ChemAlert

    The annual chemical stocktake should be a part of the chemical management system for each school or section. It should be used in conjunction with ChemAlert and procedures provided by Safety and Health.

    ChemAlert allows stock inventories and storage incompatibility reports for chemical storage locations to be printed, and these can be checked against the physical holdings during the stocktake. If ChemAlert is being used the stocktake process should involve:

    1. printing stock holding report and storage incompatibility report for the area being audited
    2. checking physical holdings against the stockholding report
    3. checking labelling and replacing damaged or deficient labels using ChemAlert
    4. checking storage of chemicals (for example, that there is nothing in fume cupboards)
    5. correcting any storage incompatibilities identified in the storage incompatibility report
    6. disposing of chemicals no longer in use
    7. update the ChemAlert register to reflect physical holdings.

    If the stocktake is performed in this way it will ensure that:

    • a current register of hazardous substances is available
    • a current manifest of dangerous goods is available
    • current Material Safety Data Sheets are available for all products
    • all products are correctly labelled, stored and segregated.

    Chemicals no longer in use

    The annual chemical stocktake should identify any products that are no longer in use or are too old or deteriorated to be of future use. These products should be disposed of appropriately, or donated to an area that has use for them. This can be organised through contacting the Safety team by emailing: [email protected].

    Annual school chemical audit

    The annual school chemical audit aims to assess a school's chemical management system and its operation.

    The audit will indicate areas within the school's chemical management system that require attention in order to improve the level of safety for personnel and ensure compliance with regulatory requirements. The focus of the audit is the practical implementation of chemical safety across UWA, and improvement of the chemical management system.

    Audit aims

    The general aim of the audit process is to develop and maintain a culture where chemicals are safely used and managed, by ensuring that:

    • chemical management systems are in place and documented
    • training and induction is carried out and documented
    • chemical inventories are current
    • Safety Data Sheets (SDS) are current and available
    • chemicals are appropriately stored and segregated
    • emergency response procedures are in place and are practised
    • waste management and disposal protocols are in place
    • a system for risk assessment is in use
    • personnel are aware of their responsibilities in the chemical management system

    The audit will also provide an opportunity for specific feedback to Safety to allow improvement of the University chemical management system.

    Audit procedure

    The school chemical audit is divided into the following sections

    1. Chemical management structure

    Identification of the chemical management structure in the area being audited. Every chemical storage area in the section should be covered by identifying all groups storing and/or using chemicals (teaching, research, workshops). Each group should have a supervisor and a person who is responsible for chemical stock control.

    2. Chemical management system

    The system by which chemical registers, manifests and SDS are stored and maintained. UWA uses ChemAlert for management of chemicals.

    3. Procedures and protocols

    Waste, emergency, after hours, and so on.

    4. Training and induction

    Refer to Chemical Safety: Risk management and emergencies - chemical safety training.

    5. Chemical risk assessment system

    Refer to complete a chemical risk assessment. 

    6. Physical inspection of chemical storage areas

    • inventory/manifest and SDS available
    • chemicals (including wastes) appropriately labelled
    • chemicals stored appropriately and segregated (no fume cupboard storage, storage above 1.5m, cabinets used)
    • Dangerous Goods Cabinets in good repair, bunds clear, only appropriate items within cabinet
    • emergency response equipment and information available – spill kit, emergency shower/ eye wash station
    • after hours contact information clearly available (on wall near exit and hand basin)
    • risk assessments documented and available
    • general tidiness
    • access ChemAlert safety information and SDS
  • Disposal

    Assess and prepare items for disposal 

    Plan waste management before working with a chemical. Regularly dispose of unwanted or waste reagents using UWA's recycling arrangements or biannual waste disposal arrangements. 

    When handling items for disposal:

    • Read the SDS and wear appropriate PPE (safety glasses and double layer of nitrile gloves as a minimum)
    • Dispose of soiled gloves into laboratory waste bins
    • Don't work in isolation - ensure colleagues are within calling distance
    • Use sturdy transparent plastic bags available in case anything needs sealing up
    • Use sturdy plastic tubs and safe transport practices when moving items to the collection location
    • Don't open, sniff or otherwise investigate anything

    Prior to disposing, consider the following:

    Is the chemical old or in poor condition?

    If the chemical has been sitting in the container for a number of years there may be some hazards associated with moving it.

    For example there have been cases where chemicals have been stored for a long time in sealed Winchesters – in this time crystals have formed, or pressure has built up in the bottles, and the containers have later exploded without warning. Moving containers like this increases the risk of explosion. 

    If your chemicals are old read the Safety Data Sheet very carefully before you move them at all and contact the Chemical and Safety Adviser if you are still unsure.

    Correctly label and segregate chemical waste

    Segregating wastes is a good safe work practice and makes disposal of waste simpler and cheaper. Chemical wastes must be labelled with a completed UWA chemical waste label (available in various sizes) with the following information:

    • full chemical names and concentrations of all constituents (abbreviations and chemical symbols/structures are not adequate)
    • an indication as to whether the waste contains either hazardous substances or dangerous goods
    • the name of the user and contact number
    • the date over which waste was collected
    • the location from which the waste was collected (school/section, building, lab number).

    Refer to the section above on Chemical Management: Labelling for more information and forms. 

    Fill in the Chemical Disposal Manifest Form for UWA Safety's biannual collection

    UWA Safety co-ordinates two University-wide collections of unwanted and/or waste chemicals per year. To access this collection, refer to the entry on how to Manifest Chemicals for Disposal.

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