Chemical Management Plan
Chemical Management Plan
Chemical Management Plan
Plan
Curtin University
LIST OF TABLES
Table 1: Main Roles, Responsibilities and Authorities related to chemical management. 3
Table 6: Guidance on Storage Limits of Common Time Sensitive Chemicals.Error! Bookmark not
defined.
Table 8: Chemical covered by the National Code of Practice for Chemicals of Security Concern. 37
Table 9: Category 1 items under the Misuse of Drugs Act Regulations 1982, Schedule 3. 47
Table 10: Category 2 items under the Misuse of Drugs Act Regulations 1982, Schedule 4. 48
Name Definition
ADG Code The Australian Code for the Transport of Dangerous Goods by Road or Rail ('Australian
Dangerous Goods Code') 7th Edition.
Bulk storage Storage of liquids, such as petroleum products in tanks as distinguished from drum or
packaged storage
ChemAlert Authorised Curtin staff who have been provided with write access to the ChemAlert system by the
Users ChemAlert Administrator.
ChemAlert An electronic Safety Data Sheet (SDS) repository and chemical inventory management
system that aids Curtin University to meet its chemical regulatory requirements.
Chemical Term used to define chemical substances, including Dangerous Goods, Hazardous
Substances as well as substances that do not fall into either classification. They may be
solids, liquids or gases; they may be pure substances or mixtures.
Class Class of dangerous goods, means the number assigned to the goods in the ADG Code
indicating the hazard, or most predominant hazard, exhibited by the goods.
Container Means anything in or by which a hazardous chemical is, or has been, wholly or partly
covered, enclosed or packed, including anything necessary to perform its function as a
container.
Controlled Substances Controlled Substances is a classification of pharmaceuticals and poisons that require
licensing. Under the licence conditions there are restrictions on access, labelling and use.
Restrictions are determined by the Medicines and Poisons Regulations 2016 – means
any medicine, drug or toxic chemical scheduled under the Medicines and Poisons Act
2014 and associated regulations, for the purpose of protecting the public from harm.
Correct classification Means the set of hazard classes and hazard categories assigned to a hazardous
chemical when it is correctly classified.
Dangerous Goods Dangerous Goods are solids, liquids or gases, which have been classified as dangerous
under the Australian Code for the Transport of Dangerous Goods by Road or Rail, 7th
Edition (ADG Code 7). Due to their physical properties that have the immediate potential
to harm people, property or the environment.
Decant Means to transfer a hazardous chemical from a correctly labelled container to another
container within a workplace. Such a container may range from a small flask in a research
laboratory to a large vessel that is used to contain reaction components prior to use in a
mixing or reaction process.
Division Division of dangerous goods, means a number, in a class of dangerous goods, to which
the dangerous goods are assigned in the ADG Code.
Exposure standard Exposure standard represents the airborne concentration of a particular substance or
mixture that must not be exceeded. The exposure standard can be of three forms:
• 8-hour time-weighted average
• peak limitation
• short term exposure limit.
GHS Means the ‘Globally Harmonized System of Classification and Labelling of Chemicals,
3rd Revised Edition’, published by the United Nations as modified under Schedule 6 of
the WHS Regulations.
Hazardous substance Is a substance that has the potential to cause acute or chronic health effects as listed in
the List of Designated Hazardous Substances [NOHSC:10005 (1999)]
1. INTRODUCTION
1.1 Purpose
The purpose of this document is to outline aspects associated with the management of chemicals at all of
Curtin University’s Australian sites. This includes purchasing, safe use, storage, management,
transportation and disposal of chemicals. There may be other standards and legislation in addition to those
outlined in this document that may need to be considered as applicable.
1.2 Aim
The aim of this document is to outline Curtin University’s process and expectations for managing chemicals
and their associated risks to ensure:
• that arrangements are in place to minimise the risk of adverse health effects and protect the safety
of staff, students, contractors and members of the public, due to exposure to hazardous substances
and dangerous goods;
• the mitigation of adverse environmental impacts; and
• compliance with State and Commonwealth regulatory requirements.
1.3 Scope
This document applies to all Curtin University staff, students and contractors who are required to use
chemicals and/or controlled substances within the scope of their duties on Curtin University’s Australian
sites. This will include but is not limited to laboratory, studio, cleaning, gardening, maintenance, and
construction personnel.
The Chemical Management Plan is intended for the use of chemicals such as, but not limited to, hazardous
substances/chemicals, dangerous goods and otherwise controlled substances. The general legislative
requirements for hazardous substances and dangerous goods will be outlined in the first portion of the
document. The later portion will cover other controlled substances which require additional specific controls
(see section 2.4).
This document should be used in conjunction with other Curtin documentation and procedures surrounding
the management of chemicals (including specific area safety management plans, area and task specific
risk assessments and standard operating procedures). This document has been developed in line with
legislation and guidance that were current at the time of writing. New legislation and guidelines developed
since the authoring of this document must be considered.
1.5 Responsibilities
All staff, students and contractors who purchase, use, store or dispose of chemicals or controlled
substances on behalf of Curtin University are required to undertake their responsibilities in line with the
Health and Safety Responsibilities Procedures located at Curtin’s Policies page. For more detail on the
Health and Safety Responsibilities within Curtin University, including individual performance criteria for
each responsible party, please see the full procedure.
Table 1 provides a summary of the main roles and responsibilities for chemical management across the
Curtin campus. Specific responsibilities will also be outlined in each subsection where applicable.
Role Responsibility for health and safety Responsibility for chemical management Authority
(from H&S Responsibilities
Procedures)
Heads of Schools/Area To implement and maintain an To implement and maintain within the School or Allocate responsibility for
Managers effective health and safety system Area measures consistent with Curtin’s Chemical health & safety management
within the School or Area that is Management Plan, ensuring compliance with the and delegation of authority.
consistent with the Occupational Occupational Safety & Health Act 1984 and other (Including chemical
Safety & Health Act 1984 and other legislative requirements. management)
legislative requirements.
Individual workers/students To comply with the Occupational To comply with the Occupational Safety & Health Act
Safety & Health Act 1984 and all 1984 and all reasonable directive given in relation to
reasonable directive given in relation chemical management at work, to ensure
to health and safety at work, to compliance with University and Legislative health
ensure compliance with University and safety requirements.
and Legislative health and safety
requirements. To report all incidents, including those involving
chemicals, via the C.H.A.R.M system.
Dangerous Goods License Maintain quantities of Dangerous Goods within
Holders license limitations, and adhere to other license
conditions.
Maintain a Dangerous Goods Manifest and Site Plan
and make available to Emergency Services.
Emergency Management To co-ordinate any communication To ensure emergency planning is undertaken. Yes – Can authorise the issue
Department between Curtin and emergency of guideline and management
authorities for the purpose of documents.
planning emergency response.
Hazardous Materials To provide advice and governance Advisory
Governance Committee to the University on matters relating
to Hazardous Materials
Compliance Officers Ensuring compliance with the Maintaining the Compliance Risk Assessments Yes
relevant legislation and reporting to and Compliance Management Plans for relevant
regulators as required (as per Legislation for example Defence Trade,
Compliance Procedures). Poisons, Radiation and Dangerous Goods.
Monitor Legislation within area of responsibility
for updates and coordinate required actions with
Curtin’s relevant Offices and Departments.
The State and Commonwealth legislation that governs the use, storage, handling and disposal of chemicals
is complex and considerable. The following list represents the Acts and Regulations that may be applicable
to Curtin University They can be accessed by the following websites.
2.2 National & International Guidance Materials, Standards and Codes of Practise.
There is an extensive list of Standards, Codes and Guidance Materials relevant to the management of
chemicals at Curtin University. These include:
• GHS Hazardous Chemical Information List
• Australian Dangerous Goods Code [Edition 7.6 (2018)]
• International Air Transport Association (IATA) Dangerous Goods Regulations
• Standard for the Uniform Scheduling of Medicines and Poisons No 24. (SUSMP) June 2019
• Labelling of Workplace Hazardous Chemicals Code of Practice (2015, WHS)
• Workplace Exposure Standards for Airborne Contaminants (2013, WHS)
• Guidance on the Interpretation of Workplace Exposure Standards for Airborne Contaminants (2013,
WHS)
• Storage and Handling of Dangerous Goods Code of Practice.
• Approved Criteria for Classifying Hazardous Substances [NOHSC:1008(2004)]
• Hazardous Chemical Information System (HCIS)
• National Code of Practice for the Labelling of Workplace Substances [NOHSC:2012 (1994)]
The Australian Standards that may apply to the use, storage, handling and disposal of chemicals at Curtin
University can be accessed on SAI Global via the Curtin Library databases.
• AS/NZS 2243.1 Safety in Laboratories, Planning and Operational Aspects
• AS/NZS 2243.2 Safety in Laboratories, Chemical Aspects
• AS/NZS 2243.10 Safety in Laboratories, Storage of Chemicals
• AS/NZS 3833 Storage and Handling of Mixed Classes of Dangerous Goods, in Packages and
Intermediate Bulk Containers
• AS 1940 The Storage and Handling of Flammable and Combustible Liquids
• AS 3780 Storage and handling of corrosive substances
• AS 4775 Emergency Eyewash and Shower Equipment.
• AS 4332 The storage and handling of gases in cylinders.
• AS 1596 The storage and handling of LP gas.
• AS 1894 The storage and handling of non-flammable cryogenic and refrigerated liquids.
• AS 4326 The storage and handling of oxidising agents
• AS 2714 The storage and handling of organic peroxides
• AS/NZS 4452 The storage and handling of toxic substances
• AS 2780 The storage and handling of corrosive substances
• AS 4681 The storage and handling of class 9 (miscellaneous) dangerous goods and articles
• AS 1319 Safety Signs for the Occupational Environment
The procurement and possession of some chemical classifications have additional approval, permit and/or
licensing requirements. Refer to the relevant sections in this for details of these additional requirements.
• Hazardous Substances
• Nanomaterials
• Scheduled Carcinogens
• Dangerous Goods
• Security Risk Substances
• Chemicals of Security Concern
• Scheduled Poisons (including medicines and drugs)
• Precursor Chemicals for Illicit drugs
• Agricultural Chemicals and Veterinary Medicines
• Radioactive Chemicals
• Concessional Spirits
Individual Schools/Areas are required to ensure that the correct placarding is displayed on their sites.
Placarding is required under Dangerous Goods (Storage and Handling of Non-explosives) Regulations
2007 where volumes stored exceed placarding quantities. For details of these requirements please refer to
the Guidance for the Storage of Chemicals document, and contact the Department of Health & Safety for
advice. There are also signage requirements for chemicals stores (AS 1319).
Individual Schools/Areas are required to ensure that signage is displayed in appropriate locations to identify
the presence of hazardous chemicals.
Cupboards, lockers and refrigerators used for storing chemicals should be labelled to indicate the type of
chemicals being stored (e.g. the class label for a dangerous good). Additional signs may also be required,
such as “do not use to store food”.
The purpose of information, instruction and training is to ensure that personnel handling chemicals have
the skills and knowledge they need to perform their tasks in a manner that is safe and without risks to health
(their own and that of colleagues working around them) and the environment, so far as is reasonably
practicable. It should enable them to follow health and safety procedures and use risk controls that are set
in place for their protection. It should also provide them with an appreciation of the nature of the chemicals
used in the workplace and the risks associated with their use and the reason why risk controls are used.
The mix of information, instruction and training provided will depend on the severity of the hazards, the level
of responsibility of the person and what the person already knows about the chemicals and their use. Where
staff hold management responsibilities for chemicals in the workplace, additional training may be required.
All staff and research students with potential for exposure to (working with) chemicals, shall undertake
training and induction on the use of chemicals.
The topics that should be covered in chemical safety training and induction as required include:
• pre-purchasing requirements;
• legislation requirements;
• classification of chemicals;
• chemical risk assessment;
• labelling;
• storage and segregation requirements;
• Spills management and emergency procedures:
• handling, storing and disposing of chemical waste and containers;
• transportation requirements;
• PPE
• SDS and other information resources;
• Safe Work Procedures (SWP):
• Managers and Supervisors Training:
• Hazardous Materials:
• Gas Safety; and
• ChemAlert.
For more information regarding training and induction please refer to the Health and Safety training website.
Irrespective of the chemical and its associated risks, personal hygiene when handling and storing chemicals
is an integral part of controlling physical exposure. Personal hygiene requirements include:
• providing readily available clean wash up facilities;
The University recognises that for those who are intending to conceive, are pregnant or breastfeeding,
precautions in addition to normal safe work procedures and practices may be required. If you work directly
or indirectly with hazardous chemicals, please advise your line manager as soon as possible of your
intention to conceive, of your pregnancy or if you are breastfeeding so that all practicable steps may be
taken to minimise risks to you and your child. This information will be used solely for the purpose of
assessing the risks and any need to modify your role or transfer you to a safe position. The information will
be confidential to those staff who are directly involved in such decisions and putting such procedures in
place. For more information on working safely in laboratories while pregnant or preparing for pregnancy,
please refer to the Reproductive Hazards and Work Guidelines available at the Health and Safety Policies
and Procedures webpage.
4.4.1 Introduction
In addition to the documentation required for the activity to be undertaken, a review of the working area
should also be checked to determine if it is appropriate. This should include (but not limited to):
• Is the right equipment available?
• Does a fume cupboard need to be used? If so what type (recirculating or non-recirculating) and
does it need a scrubber? Is this available for use and are the previous chemicals used compatible
with what I am using?
• Is there adequate space to work in?
• Do I have the equipment and appropriate storage for the waste products being generated?
Packages should not be opened, or the contents accessed, in the actual storage cabinet, shelf or immediate
storage area to avoid the risks resulting from handling obstructions, close proximity to other packages,
accidental escape of chemicals, escape of vapours or dust during transfers and possible reaction with other
substances (AS2243.10).
Ventilation shall be provided for the dispensing area to remove vapours and dusts to levels that ensure a
safe environment. Exposure standards may be used for guidance. Fume cupboards may be necessary for
particularly hazardous chemicals.
Manual handling equipment and/or safe practices shall be utilised when opening or transferring packages.
Liquid dangerous goods should not be poured except from small containers while using appropriate
personal protection.
Decanting or pouring should be avoided to reduce the risk of splashing, overfilling, vapour escape and for
flammable liquids, the risk of static electricity discharge. Hand-operated dispensing pumps should be used
instead. If decanting is unavoidable (e.g. with viscous liquids), self-closing, non-combustible (preferably
metal) taps should be used.
The manufacturer/supplier/importer must update each of their SDSs at least every five years. If the
manufacturer/supplier SDS listed on ChemAlert is more than 5 years old, the Manager/Supervisor shall
request from the manufacturer/supplier a more recent version and provide it to the H&S ChemAlert
Administrator so that it may be uploaded into ChemAlert.
Areas are required to retain copies of SDSs for the hazardous chemicals that they order and must provide
employees with access to these SDSs in either hard copy or electronic format.
A Safety Data Sheet (SDS), previously called a Material Safety Data Sheet (MSDS), is a document that
provides information on the properties of chemicals and how they affect health, safety and the environment
in the workplace. For example an SDS includes information on:
• the identity of the chemical,
• health and physicochemical hazards,
• safe handling and storage procedures,
• emergency procedures, and
• disposal considerations.
An explanation of how to read a Safety Data Sheet can be found on the H&S hazardous materials website.
Where a chemical manufacturer is no longer in business and a supplied chemical is in use/stored and the
chemical must be disposed when the SDS expires, unless appropriate justification can be made to the
Head of School/Area to keep it. The justification will need to include an alternative comparable SDS and
approved risk assessment which includes an assessment of the chemical age, stability, container & label
into consideration.
6. CHEMALERT
Curtin uses ChemAlert as its electronic chemical management system to assist in meeting regulatory
requirements. It provides a register of hazardous chemicals stored, provides access to current
manufacturer safety data sheets and can be used to generate substance labels, local hazardous substance
registers and provides dangerous goods manifests for emergency services.
All university staff and students have read-only access to ChemAlert SDS database via the H&S website.
Authorised users with passwords can access the full version of ChemAlert for viewing and maintaining
chemical stores and manifests.
It is recommended that copies of SDSs for all chemicals be held by each School or Faculty and also made
available to the H&S ChemAlert Administrator for uploading into ChemAlert prior to use of the chemical.
Online training for ChemAlert is available for all staff and HDR students who may be required to use
chemicals. Specific Search & Stock training is made available through iPerform for staff who require a
ChemAlert login. The Head of School/Area shall nominate appropriate staff to manage ChemAlert. Contact
the H&S Department for further information.
All University workplaces must enter the maximum quantities of hazardous chemicals stored into the
ChemAlert Stockholding for the relevant storage location (a partly empty container must be considered as
full for this purpose). Each area shall check the ChemAlert Stockholding against the physical stock held
(i.e. stocktake) at least twice yearly to ensure all chemicals are entered and the information is correct. This
process should be completed prior to the chemical waste disposals.
Note: Refer also to section 10.5 Storage of Time Sensitive Chemicals where shorter timeframes are
specified for the physical inspection of some chemical holdings due to risk.
Authorised login holders can use ChemAlert to produce various reports and information about the stock
holdings. These include an Incompatibility Report to assist with the identification of potential chemical
storage incompatibilities. ChemAlert also has report functionalities that can provide information to identify
other regulatory information such as poisons scheduling on chemicals held. It should be noted that these
reports are a guide and are not a replacement for SDSs or risk assessment.
Before undertaking any task using hazardous or dangerous chemicals a risk assessment must be
undertaken to determine the possible hazards of the product and the control measures required for its safe
use. When performing risk assessments, utilise sources of health and safety information such as SDSs
from ChemAlert, (SDS database) and/or potential suppliers, together with information available from
reputable sources, such as Safe Work Australia, Worksafe and the World Health Organisation. Risk
assessment should be performed using the online Risk Assessment Module Available in C.H.A.R.M.
Managers and supervisors are responsible for ensuring that risk assessments are undertaken in the areas
of their control. The Manager/supervisor is also responsible for ensuring risk assessments are stored,
available and reviewed as required.
Task based risk assessments should be conducted by the person conducting the activity work with
chemicals. The manager/supervisor endorses the risk assessment ensuring that it has been reviewed by a
competent person who has understanding of the work being undertaken and that appropriate hazard control
measures will be implemented prior to commencement of work. (The competent person may also be the
manager supervisor)
Finally, the manager/supervisor must authorise the risk assessment to allow the work to commence.
Approval may be escalated based on an evaluation of the residual risk according to Curtin University’s risk
reference tables, located in the Risk Management Framework.
It is good work practice to review assessments whenever undertaking an activity. Safe Work Procedures
should be developed when an activity becomes routine and is used by multiple people. The Safe Work
Procedure records the residual risk only.
Risk Assessment should also be reviewed where there are changes to the environment or systems of work
that alter the effectiveness of the original controls such as:
• change of chemical supplier;
• a new chemical is introduced into the work area;
• the process or plant is modified;
• new information on the hazards for the chemical becomes available;
• monitoring (environmental or health surveillance) indicates that controls are not adequate;
• accidents and near misses occur;
• chemicals are moved to a new location; and
• improved control measures become available.
The Health and Hygiene Management Plan outlines the process for identifying, assessing, controlling and
communicating health risks associated with potential exposure to chemical, physical, biological and
ergonomic hazards, in order to prevent occupational illness and disease.
Health surveillance is required for workers who are exposed to noise or vibration, ionising radiation,
solvents, fumes, dusts and other chemicals or substances hazardous to health. Health surveillance will be
managed in accordance with the Health Surveillance Guideline.
7.6 Fieldwork
Fieldwork is any approved practical work, teaching, study or research activity, usually conducted outside
the normal place of University business. Information about the forms required for fieldwork can be found at
the Work Integrated Learning website. Where chemicals are required to be used during fieldwork, a risk
assessment should be undertaken and appropriate controls put be in place before handling them. Please
also refer to section 11.3 regarding the transport of chemicals in fieldwork.
8. PURCHASE
It is a Curtin requirement when ordering new chemicals into an area, that a Chemical or Gas Pre-purchase
Checklist is completed. Where the substances are regulated or controlled, evidence of appropriate
purchasing authority must be provided prior to sign off.
All chemicals must be purchased from an Australian supplier where possible. This ensures that the
chemical has come from a supplier required by Australian legislation to provide a compliant SDSs and
labelling. Where this is not possible, chemicals purchased from overseas suppliers will be considered,
however this incurs significantly greater regulation, See Section 8.2.
When a chemical is purchased directly from an overseas supplier, the purchaser is then considered to be
the importer or supplier of that chemical. Under Australian Occupational Health and Safety legislation, this
means the purchaser will be required to meet the legislative responsibilities of an importer and supplier.
This includes ensuring that the labelling of the chemical is compliant to Australian Legislation and the
production of an Australian Compliant Safety Data Sheet. Contact Health and Safety for further information.
Dependant on the chemical being purchased, there may also be additional legislative restrictions and/or
requirements that apply to the importation of that substance. Importation controls or restrictions may apply
under the following legislation. This is not an exhaustive list.
• Customs Act 1901 & Customs (Prohibited Imports) Regulations 1956 & Narcotic Drug Act 1967 (For
example controls apply to the import of narcotic drugs, psychotropic substances, precursors
chemicals and antibiotics androgenic/anabolic substances)
• Chemical Weapons (Prohibition) Act 1994 & Regulations 1997
• Industrial Chemical (Notification and Assessment) Act 1989
• Agricultural and Veterinary Chemicals Code Act 1995 & Regulations 1995
Research and educational institutions are often subjected to lighter import restrictions due to the nature of
the intended use of imported chemicals. Import restrictions should be investigated and confirmed on a case
by case basis.
As a general rule Curtin will not accept chemical donations as most often their provenance, age and stability
are difficult to verify. Exceptions can be made with the approval of a manager/supervisor, where sufficient
justification is made as to why Curtin is to accept the chemical. This must include a risk assessment
incorporating the life cycle of the chemical and cost of disposal.
8.3.2 Samples
When Curtin receives samples for research and or analytical purposes, planning and risk assessment must
be in place prior to receiving the samples. A sample management plan should be generated detailing what
is being accepted. This should include a risk assessment incorporating the life cycle of the sample.
Specific attention must be made to the disposal requirements of the samples. This must be agreed with a
client. All disposal costs should be defined with a client as part of the research contract before accepting
the samples into the University.
9. LABELLING
The purpose of labelling is to ensure that the contents of a container can be readily identified by product
name and to provide basic information about the contents of the container – its ingredient(s), hazards and
precautions for safe use.
9.2 GHS
The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is a single
internationally agreed system of chemical classification and hazard communication through labelling and
Safety Data Sheets (SDS). The GHS is published by the United Nations and is sometimes referred to as
‘the purple book’. It includes harmonised criteria for the classification of:
• physical hazards,
• health hazards, and
• environmental hazards.
A hazardous chemical is correctly labelled if the chemical is packed in a container that includes the
following:
• is written in English
• the product identifier
• the name, Australian address and business telephone number of either the manufacturer or importer
• the identity and proportion disclosed, in accordance with Schedule 8 of the WHS Regulations, for
each chemical ingredient
You may include any information on the label that does not contradict or cast doubt on any other information
that is required on the label. The following additional information should also be included on the label, where
available:
• an emergency phone number, for specific poisons or treatment advice
• the overseas name, address and telephone number of the manufacturer or supplier
• a valid website or internet address
• reference to the safety data sheet, for example a statement on the label that says: “Additional
information is listed in the safety data sheet”.
The information on a label may be presented using one or more panels, or sections, dependent on the size
and shape of the container. The label should be firmly secured to the outside of the container and should
be visible in the normal storage position. The label should be sufficiently durable so as to remain legible
and firmly attached to the container for the foreseeable lifetime of the product under normal storage and
handling conditions.
The information and hazard pictograms on any label should be printed in a colour or colours that provide a
distinct contrast to the background colour.
The following table is provided as a guide for the minimum dimensions for hazard pictograms and sizes of
text on containers of various capacities:
In most cases the simplest method to produce compliant labels is to print them from ChemAlert which
provides a range of labels suitable for drums, Winchesters and small bottles, including some label
templates. Additional labels may be required in the event that the vendor cannot or will not provide
replacement labels swiftly, or where decanting from the original container into smaller/additional containers
has occurred.
Where a hazardous chemical is packaged in a container that is too small to attach a label with information
that is required of hazardous chemical labels in general, then the label must be written in English and
include the following:
• the product identifier
• the name, Australian address and business telephone number of either the manufacturer or
importer.
• a hazard pictogram or hazard statement that is consistent with the correct classification of the
chemical, and
• any other information required for hazardous chemicals labels in general that is reasonably
practicable to include.
If a hazardous chemical is used for research purposes only or is a sample for analysis, the label must, at a
minimum, be written in English and include the product identifier and a hazard pictogram or hazard
statement that is consistent with the correct classification of the chemical.
A chemical Label Template for samples is available on the Health and Safety website.
If a hazardous chemical has been decanted or transferred from the container in which it was packed and it
will not be used immediately or it is supplied to someone else, the label must at a minimum, be written in
English and include the following:
• the product identifier, and
• a hazard pictogram or hazard statement consistent with the correct classification of the chemical.
Where the entire amount of a decanted hazardous chemical will be used immediately, labelling
of its container is not required.
A decanted hazardous chemical can only be considered to be used immediately in situations where:
• it is not left unattended by the person who decanted it
• the decanted hazardous chemical is used only by a person present at the decanting process
• the container is subsequently rendered free from any hazardous chemical immediately after use, so
the container is in the condition it would be in if it had never contained the chemical.
If a container is not properly labelled, for example the label has been lost, the container should have the
product name, if known, attached to it. Unlabelled containers of an unknown chemical shall be labelled:
The container shall be removed from use and the Chemical Waste Management Contractor contacted to
arrange for its disposal.
10. STORAGE
Chemicals must be stored appropriately according to legislative requirements. Properties have produced
the Guidance for the Storage of Chemicals to cover the design, construction and use of chemical stores
and storage. The management aspects of this document have been incorporated into this section. Storage
of gas cylinders should comply with Guidance for Gas Management and Gas Store Design.
When storing chemicals, it is imperative to consider storage compatibility for chemicals of different
dangerous goods classes. Chemicals may need to be isolated or separated by sufficient distance to
eliminate the risk of fire, explosion, or accumulation of toxic gases or vapours from a leak or spillage etc.
The principal source of guidance regarding conditions for safe storage and compatibility is the SDS for the
relevant chemicals. Information on compatibilities should be identified within the SDS. Table 4 provides
some guidance as to compatibility between the classes of dangerous goods.
ChemAlert also has an incompatibility reporting function that can assist in the identification of incompatible
chemicals based on DG class. Additional chemical specific incompatibilities will also need to be considered.
Class / Division 2.1 2.2 2.3 3 4.1 4.2 4.3 5.1 5.2 6.1 8 9
3 Flammable liquid B E C A B D B D D C B B
6.1 Toxic C B B C C C C F F A B B
8 Corrosive B B B B B B D D D B G B
Miscellaneous dangerous
9 B B B B B B B F F B B A
goods
Note: In this table, combustible liquids should be included with Class 3.
A - Most dangerous goods of the same class have similar primary hazards and are usually considered to
be compatible.
B - With a few exceptions, which should be indicated on the SDS, goods of these two classes are usually
non-reactive with each other. However, in an emergency such as a spill, leak or fire, the presence of
the second class may lead to different hazards or increased risk such that additional control measures
are required.
C - While goods of these two classes are usually non-reactive with each other, a fire involving the fire risk
goods may lead to the release of large clouds of toxic gases or vapours.
D - Goods of these two classes are likely to interact with each other in such a way as to significantly
increase risk. In some cases, interaction may result in fire or evolution of toxic vapours. For those that
do not interact, a fire involving one may be violently accelerated by the presence of the other. These
classes should not be kept in the same area unless it can be demonstrated that the risks are fully
controlled.
E - If the Division 2.2 has a Subsidiary Risk 5.1, then this is D, otherwise it is B.
G - If one material is a concentrated, strong acid and the other is a concentrated, strong alkali, then this is
D, otherwise it is A.
Where reasonably practicable chemicals should be kept in their original container with the original labelling
from the manufacturer/supplier. Where chemicals are decanted the new containers must be appropriate for
the chemical they will hold and be correctly labelled (see section 9.7.3).
Decanting chemicals in explosive atmospheres or chemicals that may produce explosive atmospheres
require special arrangements that will not produce static electricity (e.g. fume cupboards, earthing
equipment, non-synthetic protective garments). Decanting shall not be performed in chemical stores unless
the stores have been specifically designed for decanting.
Particular attention must be given to decanting chemicals that pose unique hazards such as:
• solvents which can create explosive atmospheres;
• asphyxiants; and
• chemicals that are toxic by inhalation.
Time Sensitive Chemicals can degrade over time and develop additional hazards if not correctly
maintained. These hazards have the potential to cause significant injury to personnel and damage to
surrounding infrastructure. A considerable number of chemicals stored and handled by Curtin are classified
as time sensitive, this number includes both pure chemicals and mixtures.
It is vital that all staff and students who handle or store chemicals are aware of the risks posed by time
sensitive chemicals. Chemicals affected by these risks include: isopropyl alcohol (2-propanol), diethyl ether,
tetrahydrofuran (THF), Chloroform, Picric Acid, Formic Acid and over 200 others.
The effective management of Time Sensitive Chemicals requires diligence in chemical labelling and
marking, tracking, inspection, and chemical specific hazard management.
Storage timeframes are critical. For this reason each classification of Time Sensitive Chemicals has a
specified acceptable storage duration, none of which will exceed five years.
DANGER!
‡ Fine crystals may be difficult to observe, the use of a strong flashlight is recommended.
If the above signs are observed you must immediately cordon off the area to prevent the chemical
being disturbed, contact Health and Safety on 9266 4900 and your Laboratory Technical Manager.
‡ For detailed advice refer to the tables contained in the Time Sensitive Chemicals (curtin.edu.au)
The quantities of hazardous chemicals stored in laboratories should not exceed those specified in Table 6,
with incompatible chemicals shall not be stored together unless properly segregated (Table 4). However it
is recommended that chemicals stored in the laboratory are located within a chemical storage cabinet and
not purely reliant on the below exempt volumes.
Maximum aggregate
200
quantity
Taken from AS/NZS 2243.10: 2004. Please refer to the AS for more details and additional table notes.
Chemical storage cabinets are the recommended method of storage for chemicals in the laboratory. They
are mandatory where there is a specific requirement to hold quantities above those permitted in Table 6
within the laboratory. Chemicals in quantities above those stated in Table 6 will be stored within a chemical
storage cabinet.
The capacity of any chemical storage cabinet used in a laboratory to store chemicals of Classes 4.1, 4.2,
4.3, 5.1 or 5.2 shall not exceed 50 L. For Class 3 any chemical storage cabinet located under a bench shall
not exceed 30 L in capacity. For other chemicals, the capacity shall not exceed 250 L.
Containers shall not be stored within the bund or lower floor of chemical cabinets.
Within a radius of 10 m, measured from any one cabinet, the cabinet storage capacity aggregated for all
cabinets in that radius shall not exceed 250 L or 250 kg. Incompatible chemicals shall not be stored
together. Separate chemical storage cabinets shall be used to maintain proper segregation. For further
information refer to the Guidance for the Storage of Chemicals.
Before obtaining a chemical cabinet confirm that a compliant location is ready. Refer to Guidance for the
Storage of Chemicals and contact Health and Safety for advice.
Laboratory refrigerators that are used to store flammable solvents or other volatile chemicals may
accumulate flammable or explosive atmospheres inside the unit. Under these conditions ignition sources
from the refrigerator may cause an explosion. AS 2243.2 Section 4.4.3 (c) requires the following:
For details of the requirements of chemical stores please refer to the Guidance for the Storage of
Chemicals.
Chemicals should be purchased in quantities to be used at that time and not be stored for long periods of
time. Where a chemical is required in more than one location, it shall be purchased in multiple small
quantities and the chemical shall be delivered and stored at each location where it is required. Where
transport of chemical, samples and/or gases is deemed essential, a risk assessment of the transportation
must be undertaken.
The exception for transporting chemicals would be the relocation of research from one facility to another.
At this time the preferred method of transportation will be for the move to be completed by an external party
(Curtin approved contractor) which will be included as part of the move costs. The contractor can be
arranged through Curtin Properties, Facilities & Development.
The movement of chemicals within a building or school will be controlled and managed by the building
manager, laboratory manager, and/or technical manager. For transportation to occur the following must be
properly documented and approved:
• Risk assessment
The possibility of incompatible materials contacting one another, as a result of a container failure while
being transported through or moved in the store, shall be evaluated. It shall be ensured that such materials
can be conveyed in a manner which will not allow chemical interaction.
Curtin does not and will not transport dangerous goods as defined in the Australian Dangerous Goods Code
Edition 7.6. If under exceptional circumstances dangerous goods of these quantities are required on site
they will be transported by specialist contractor Licenced to transport dangerous goods.
From time to time there may be a requirement to transport chemicals into the field. Any requirement for the
transport of chemicals for field work should be identified at the start of a project as part of the risk
assessment documentation. All appropriate documentation identified in Section 7.6 must be developed and
approved prior to going to site.
In addition to the above documentation, any requirements of the Department of Mines, Industry Regulation
and Safety (DMIRS) or those presented in the Australian Dangerous Goods Code Edition 7.6 for small
quantities, must be adhered to. The requirements of the SDS must also be followed.
12.1 Introduction
Chemical waste and its disposal is controlled by the Environmental Protection Act 1986 and the
Environmental Protection (Controlled Waste) Regulations 2004 in order to protect the environment. For the
purposes of this section, chemical waste is defined as any chemical whether solid, liquid, gaseous which
is discharged, emitted or deposited in the environment in such volume, constituent or manner as to cause
an alteration in the environment.
Chemical waste includes any otherwise discarded, rejected, unwanted, surplus or abandoned chemical
whether intended for sale or any further use (including recycling) regardless of value.
A full list of controlled waste can be found in Schedule 1 of the Environmental Protection (Controlled Waste)
Regulations 2004.
Where practicable chemical waste should be reduced to lower the impact on the environment. For example
a trained person could neutralise unwanted hydrochloric acid by adding sodium bi-carbonate. This would
reduce the impact on the environment as transport of the waste would be eliminated. Please refer to the
local area waste procedures and Water Corporation’s Trade Waste guidance.
Heads of Schools and areas are responsible for ensuring there is sufficient waste management process in
place. Managers/Supervisors must ensure, so far as is reasonably practicable, that chemicals are acquired
in minimum quantities that mitigate or reduce waste. Chemical waste remains the responsibility of the
purchaser or producer until the point of its authorised discharge or disposal.
Chemical waste should not be allowed to accumulate and must only be mixed with compatible waste,
personal protective equipment should be used when handling chemical waste as recommended in the SDS
and risk assessment.
Chemical waste must be correctly handled, stored and labelled to reduce the risk of spillage and unintended
reactions. The Managing Chemical Waste Guidelines provides advice on managing these risks.
Curtin arranges for a licenced contractor to collect chemical waste regularly, please refer to Health and
Safety’s website for collection details. If individual areas require waste collection more frequently, the area
can arrange an additional waste collection directly with the waste contractor. Chemical disposal contractors
will issue a receipt outlining the waste collected, which must be kept as a record for 3 years.
Some Curtin facilities have Trade Waste Permits that allow for certain types of chemical waste that meet
stipulated acceptance criteria to be discharged by the sewer system. However, chemical waste disposal by
a licenced contractor (as described in section 12.3) is the preferred method of waste disposal.
Where waste is collected for disposal, it must be stored in container that is fit for the purpose and, cleaned
of spills on the outside. The label must contain the following information:
• chemical name or , mixture ingredients, waste category, waste type, UN No., class and HAZCHEM
Code.;
• the statement “Chemical Waste For Disposal” on at least two sides of the container, departmental
name and number;
• dangerous goods class label or GHS pictogram (if applicable);
• packaging group;
• volume
Chemical waste must be stored appropriately (including segregation and bunding) so that the
container/receptacle is impervious to rodents and insects and in such a way that it does not detrimentally
affect the surrounding area by odour, visual pollution, air pollution, noise pollution and so on.
Chemical containers of some hazardous and/or dangerous goods may be classified as chemical wastes
and require dedicated disposal. Check the SDS and the ChemAlert product information for information
about a given chemical. All chemicals and used spill kits shall be disposed of safely in accordance with the
Safety Data Sheet and legislated requirements, by an Environmental Protection Authority (EPA) approved
registered contractor.
Chemicals older than 5 years shall be disposed of as a Curtin preference, unless appropriate justification
can be made to keep it. The justification will need to include a current compliant SDS and approved risk
assessment which includes an assessment of chemicals age, stability, container & label.
Note: Refer also to Section 10.5 – Time Sensitive Chemicals where specific maximum storage timeframes
are required due to risk, with none exceeding 5 years.
When you finish a project, leave a building/department or cease working at Curtin you must ensure that all
chemicals, reagents and chemical samples are safely disposed of before you leave. Alternatively they may
be handed over to another person familiar with the hazards of those substances if labelled with that person’s
name and on the approval of your line manager. Check storage areas including fridges and freezers for
any items that were your responsibility while at Curtin and arrange a chemical handover with your facility
manager.
The Bentley Campus University Emergency Procedures Booklet provides guidance for what to do in the
case of a chemical spill or gas leak, which are outlined below in section 13.1.1 and 13.1.2.
In a life threatening situation call 0 000. If there is an incident that requires an emergency response call
Curtin Safer Communities ext 4444 and follow the procedures in Section 14.1.
If the identity of the chemical spill is unknown treat it as a poisonous material and do not attempt to clean
up.
Attempts to contain or clean up spills or releases should not be attempted unless you have been trained to
do so. (See section 13.4 for spill response)
Action Steps
• Advise others in the immediate area to vacate immediately and report to the assembly area;
• Upon leaving the contaminated area close all doors;
• Do not allow other people to enter the contaminated area;
• If anyone is contaminated set up an isolation area and if available assist them to a safety shower to
wash off contamination. Affected area should be rinsed for a minimum of 15 minutes;
• Report what you have seen and done to Curtin Safer Communities at 4444 from an internal phone
or 9266 4444 from an external phone;
13.2 Preparedness
Each workplace shall be prepared for a spill event. This will be different for each laboratory and it will be
the responsibility of the laboratory manager or area supervisor to ensure appropriate preparedness is in
place.
Procedures for the handling and management of spills will be documented and approved. The procedures
will also state any special requirements (i.e. additional storage of calcium gluconate where HF is being
used, the use of CO2 or appropriate foam fire extinguishers where DG4.3 are being stored).
All areas where chemicals are being used and stored will have appropriate spill kits and cleaning facilities.
This may also include appropriate PPE suitable for the chemicals being cleaned up.
In order to try and prevent spills the following will be undertaken/ available:
• Procedures for the handling and management of spills
• Display response steps and contact numbers in work locations where spills are foreseeable
• Test chemical spill response preparedness at regular intervals
• Ensure a first aid kit is available and that the area has a designated First Aider. Any first aid
provisions specific to a chemical must be accessible to the First Aider (e.g. calcium gluconate for
Hydrofluoric acid or Medical Oxygen for cyanides), the First Aider must be appropriately trained in
the use of these specific provisions.
• Suitable spill kits readily accessible and checked on a regular basis
• Spill kit are restocked/replaced after a spill event
• Provision of suitable PPE
• Access (within 10 Seconds) to an eye wash station and emergency shower
• Provide safe facilities e.g. laboratory bench surfaces, drainage systems, ventilation systems, and
floors cleared of trip hazards.
• Ensure chemicals are stored appropriately including provision of well-sealed containers, bunding
trays, cabinets with inbuilt spill retention, and stores with bunding.
• Ensure suitable equipment (fume cupboards and ventilation systems) are available, tested and
used.
Spill clean-up should only be undertaken by trained personnel who can make a determination of if the spill
clean-up can safely be managed locally. Spill Response Procedures produced by the local area and the
guidance of the SDS should be followed used in the first instance, where local procedures are not available
the following general advice can be followed:
1. Ensure the surrounding area is secured and if appropriate evacuated.
2. Assess the risks to yourself and others, obtain and consult the SDS of the chemical that has been
spilled.
3. Call for help from other trained personnel. If the event requires emergency services, or is beyond the
capability of available personnel to control call Curtin Safer Communities on 9266 4444 immediately
as per section 14.
4. If safe to do so, stop and contain the spill. Protect nearby drains from the spill.
5. Ensure any casualties are accounted for. If safe, apply first aid (this includes moving to emergency
shower and eye wash) and/or if appropriate move to a safe location.
6. Ensure the laboratory manager or supervisor has been informed of the incident.
7. If safe to do so, start cleaning up the spill following the procedures developed:
• Apply spill kit as per the instruction contained in the kit
• If appropriate dilute residue and wash down with water
• If the spill is on the floor or walkway ensure appropriate signage is in place informing people to
be aware of potentially slippery surfaces.
8. Appropriately dispose of waste material and used spill kits items as chemical waste.
All incidents and spills involving hazardous substances must be reported on the online reporting system
C.H.A.R.M. Investigation of these incidents and notification of external authorities will occur in line with the
Curtin University Incident and Hazard Reporting and Investigation Procedures.
If an incident requires an emergency response, call the Curtin Safer Community Team on
4444 who will assess the situation and escalate to the Emergency Management Team
where appropriate.
Emergency procedures must be prepared in accordance with the Curtin Emergency Management Plan,
which incorporates AS 3745-2010 Planning for Emergencies in Facilities.
The manager/supervisor of an area or laboratory must ensure that local emergency procedures are
developed to guide response to chemical hazards particular to the area.
Up to date chemical register information is vital in responding to chemical incidents, it is the responsibility
of each Schools to update ChemAlert for their locations when new chemicals are purchased, used or
disposed.
The local area emergency procedures should be documented prior to the commencement of a process,
these procedures should take into account the outcomes of a risk assessment:
• the physical properties of the chemical/s including: fire and explosion, environmental damage and
the likely health impacts. This information will be provided on the SDS.
• the full life-cycle and intended use of the chemical from delivery/receipt through to waste collection.
• equipment or infrastructure available in the area that will aid in the detection of or response to an
incident
• the safe management of spills and leaks;
Sites holding a Dangerous Goods License will keep a copy of the Manifest and Site Plan at the Fire Indicator
Panel (FIP). A backup copy of the Dangerous Goods Manifest and Site Plans will also be located in the
Curtin Safer Communities Control Room.
The university and some individual staff are empowered by licence or campus permit to possess certain
drugs or other controlled substances. Some of these drugs and substances may be subject to misuse,
diversion for illicit trafficking or conversion to other drugs for misuse. Workplaces are to ensure adequate
arrangements are in place for security, storage, record-keeping and general control in accordance with the
requirements of the permit conditions and relevant legislation.
In addition to reporting any incidents involving chemicals (see section 14), all incidents in which there are
reasonable grounds to suspect:
• Theft: a theft or loss of a chemical, drug, or prohibited substance
• Unaccounted loss: a quantity of chemicals, drugs or prohibited substances that cannot be
reasonably accounted for, or
• Suspicious behaviour: A staff member and/or contractor who has access to chemicals, drugs or
prohibited substances exhibits such behaviour that you or others reasonably suspect that the person
may be abusing or diverting drugs or other chemical substances.
• Must be reported to the Director Health and Safety ext. 4900.
16. RECORDS
The following documents must be kept for the period specified.
1. Risk assessments that identify a hazard or significant degree of risk to health are to be kept for 30
years. Monitoring results and health surveillance reports must also be kept for 30 years;
2. risk assessments identifying no hazards/significant degree of risk to health must be kept for 5 years;
3. training records are to be kept for at least 5 years;
4. tank inspection records are to be kept while the tank remains in service;
5. fire protection system testing records are to be kept;
6. incident investigations involving material harm must be kept for the life of the facility
17. NANOMATERIALS
17.1 Terminology
Nano-objects are defined as materials with one (nanoplate), two (nanorod) or three (nanoparticle) external
dimensions in the nanoscale (i.e. between approximately 1 and 100 nm). Nano-objects can form
agglomerates and aggregates. For the purpose of this document, the term nanomaterials shall apply as a
collective for to the above materials.
17.2 Legislation
There is currently no WA legislation dealing specifically with nanomaterials. However, legislation covering
chemicals is applicable to nanomaterials. In WA, nanomaterials are covered under the Occupational Safety
& Health Act & Regulations as part of the regulations that cover hazardous substances/chemicals.
While some occur naturally, many nanomaterials are engineered with specific properties in mind. Table 7
provides details on some of the more common types of engineered nanomaterials to which this guide might
be applied.
There are specific issues associated that should be considered as part of the planning and risk assessment
of work involving nanomaterials. Nanomaterials are generally considered more hazardous than their larger
form counterparts because of the potential for nanomaterials to express property changes such as
increased flammability and reactivity, from their larger counterparts and the potential of some nanomaterials
to form explosive dust clouds. In addition to this, increased particle number and combined surface area,
other particle characteristics might influence the biological response, including solubility, shape, charge and
surface chemistry, catalytic properties, adsorbed pollutants (e.g. heavy metals or endotoxins), as well as
degree of agglomeration.
As nanotechnology is an emerging field and the reasons described above, SDSs for nanomaterials may
not adequately cover all the hazards of these materials. Due to this, research has been undertaken into
what standard controls would be suitable for working with nanomaterials to reduce exposure. It has been
shown that existing controls utilised for dusty processes are effective controls for use with nanomaterials.
From this research a principle of control banding has been developed, which is based on an evaluation of
the known health risks of the nanomaterial product and the potential exposure identify an appropriate
control band. When undertaking a risk assessment for work involving nanomaterials, specialist advice may
be required to identify the appropriate control band.
Conceptually, the five control band levels detailed in the ISO Standard consist of:
17.6 Labelling
Manufacturers/importers have a duty to correctly classify chemicals and include information on known
hazards on the label in accordance with Occupational Safety & Health & Regulations. (Part 5, r. 5.6)
Where the hazards associated with engineered nanoparticles have not been fully characterised the
manufacturer/supplier should include an interim statement on the label such as:
Where engineered nanomaterials are labelled with the above phrases, they should be included on the label
of any container to which the nanomaterial is decanted.
17.7 Spills
Methods to control spill and accidental release of nanomaterials should be identified in pre-planning
activities. Where on-site personnel might reasonably be expected to deal with a spillage of nanomaterials,
consideration may be given to the use of wet wipe cleaning methods, barriers to minimise air currents
across areas affected by a spillage and tested and certified HEPA filters, for dry materials or dried spills.
Dry sweeping should be avoided.
The properties of a nanomaterial must be considered when determining the appropriate method of waste
disposal. Consideration needs to be given to the following characteristics:
• Type of nanomaterial or nano-product from which nanowaste is derived can effect waste
characteristics. These characteristics include Flammability, Corrosivity, Reactivity ,Toxicity,
Physical form (e.g. material size can effect waste characteristics)
• The sources of nanomaterial waste may include the Manufactured Nanomaterials themselves (e.g.
Carbon Nanotubes), Nano By-products - organic or inorganic, Liquid Suspensions Containing
Nanomaterials, Items Contaminated with Nanomaterials (e.g. Wipes/PPE), the waste of animals to
which nanomaterials have been administered, Solid matrices with Nanomaterials
• Due to the above, waste containing nanomaterials may require, Separation from other waste
streams, to be Bagged and sealed, to be labelled as per clinical waste protocols and ADG Code,
storage on site, to be recycled where possible. For the time being, disposal of waste via incineration
plants should be avoided where little is known about the behaviour or there is high concentrations
of nanoparticles.
The term Security Risk Substances (SRS) has been given to dangerous goods of particular security
concern because their misuse may lead to mass casualties and/or destruction.
Western Australia has developed dedicated regulations for SRS under the Dangerous Goods Safety Act.
The requirements of the SRS Regulations are in addition to the requirements of the other dangerous goods
safety regulations and any other legislation that may apply.
Security Risk Substances are substances containing more than 45% Ammonium Nitrate, which is not an
explosive or an aqueous solution consisting of a homogeneous mixture of 2 or more components in a single
phase. The above substances will collectively be referred to as Security Sensitive Ammonium Nitrate
(SSAN)
In general, the manufacture, import, export, supply, transport possession, access or use of Security Risk
Substances requires a Licence, issued by the Department of Mines and Petroleum. An exemption to the
licencing requirements for the possession of SRS exists for educational institutions (persons employed by
and & students of educational institutions).
This exemption is conditional on a legitimate research, teaching or analysis requirement for the SRS that
do not involve the manufacture of an illegal product and a limit of 3kg of SRS held in any laboratory/building.
This is to be recorded and managed on ChemAlert. Should more than of 3kg of SRS be required, Contact
the Director of Health and Safety on ext. 4900 to discuss the requirement for a licence.
SRS’s are considered to be a Chemical of Security Concern. Please see section 19 for recommendations
on management of Chemical of Security Concern.
19.1 Introduction
Chemicals are legitimately used by individuals and organisations every day throughout Australia. However,
a small percentage of these chemicals have been diverted and for unlawful purposes, including facilitating
terrorist attacks. The Council of Australian Governments (COAG) have identified 96 chemicals as chemicals
security concern, due to their potential to produce explosive or toxic weapons.
A voluntary National Code of Practice for Chemicals of Security Concern applies to 11 of the 96 Chemicals
of Security Concern that are precursors to homemade explosives. Ideally the code should be applied to the
additional 84 toxic chemicals of security concern as security risk management is part of good business
practise. The remaining Chemical of Security Concern is Ammonium Nitrate as covered by the Dangerous
Goods Safety (Security Risk Substance) regulations 2007 (see Section 18). The National Code of Practice
for Chemicals of Security Concern outlines measures to increase responsibility, security, monitoring of
inventory and the reporting of suspicious behaviour.
Table 8: Chemical covered by the National Code of Practice for Chemicals of Security Concern.
11 precursor chemicals
Ammonium perchlorate ≥ 65% or pure aqueous solution ≥ 10%
Hydrogen peroxide All pure aqueous solutions, mixtures with other chemicals ≥15%
Nitric acid ≥ 30%
Nitromethane ≥ 10%
Potassium chlorate ≥ 65% or pure aqueous solution ≥ 10%
Potassium nitrate ≥ 65% or pure aqueous solution ≥ 10%
Potassium perchlorate ≥ 65% or pure aqueous solution ≥ 10%
Sodium azide ≥ 95%
Sodium chlorate ≥ 65% or pure aqueous solution ≥ 10%
Sodium nitrate ≥ 65% or pure aqueous solution ≥ 10%
Universities Australia developed a National Code of Practice for Chemicals of Security Concern - guidance
note for laboratories - in universities, health or industry. The guidance outlines advice for implementing the
code in laboratory based workplaces. The advice is separated into 3 sections. The importance of the
National Code of Practice for Chemicals of Security Concern and the controls in place should form part of
your training & induction programme.
1. The overarching responsibility for integrating the Code of Practice for Chemicals of Security
Concern sits with someone in a position to implement and promote the code. As part of
organisational risk assessment the assessment of security risk and implementation of security
measures should be considered together with ensuring that personnel who are able to order
chemicals are verified as trustworthy people, making laboratory mangers & supervisors aware of
the code, the importance of reporting suspicious behaviour and reviewing waste disposal
procedures. At Curtin this is the Director of Health and Safety.
2. Laboratory managers can implement the Code of Practice by a risk assessment approach that may
include the following controls. Reviewing security measures, ensuring that chemicals are stored in
a secured area, restricting access arrangements to those who have a legitimate need, maintaining
an accurate inventory, being familiar with and encouraging supervisors to be familiar with the
chemicals and volumes being used by students and technicians & limiting the number of people
authorised to purchase chemicals.
19.4 Reporting
Report any suspicious activity or unexplained discrepancies to the Director of Health and Safety ext. 4900,
who will then contact the National Security Hotline.
The Medicines and Poisons Act 2014 regulates and controls the possession, sale and use of poisons,
medicines and drugs to protect the public from harm associated with the misuse of these substances.
Poisons, medicines and drugs controlled under the Medicines and Poisons Act 2014 (WA) are classified
into Schedules (listed below) based on their toxicity, use and potential for misuse. The Standard for the
Uniform Scheduling of Medicines and Poisons (SUSMP) is the legislative instrument that has been adopted
as the list of poisons classified into each schedule. Many poisons by their nature are also hazardous or
dangerous and as such the requirements of the Medicines and Poisons Act 2014 are in addition to those
of other applicable legislation unless specifically stated. The Schedules of a poison can also be found on
the SDS, where available.
The Schedules as defined in the Medicines and Poisons Act 2014 are:
• Schedule 1, currently not used.
• Schedule 2, Pharmacy Medicines; Substances, the safe use of which may require advice from a
pharmacist and which should be available from a pharmacy or, where a pharmacy service is not
available, from a licensed person.
• Schedule 3, Pharmacist Only Medicines; Substances, the safe use of which requires professional
advice but which should be available to the public from a pharmacist without a prescription.
• Schedule 4, Prescription Only Medicine or Prescription Animal Remedy; Substances, the use or
supply of which should be by or on the order of persons permitted under the Act to prescribe and
should be available from a pharmacist on prescription Schedule 5, Caution: Substances with a low
potential for causing harm, the extent of which can be reduced through the use of appropriate
packaging with simple warnings and safety directions on the label.
• Schedule 6, Poison: Substances with a moderate potential for causing harm, the extent of which
can be reduced through the use of distinctive packaging with strong warnings and safety directions
on the label.
• Schedule 7, Dangerous Poison; Substances with a high potential for causing harm at low exposure
and which require special precautions during manufacture, handling or use. These poisons should
be available only to specialised or authorised users who have the skills necessary to handle them
safely. Special regulations restricting their availability, possession, storage or use may apply.
• Schedule 8, Controlled Drug; Substances which should be available for use but require restriction
of manufacture, supply, distribution, possession and use to reduce abuse, misuse and physical or
psychological dependence.
To purchase, use and hold poisons in schedules 2, 3, 4, 7, 8, or 9, Curtin must hold an appropriate permit
for either research, educational, or industrial purposes. The purchase, use or holding of Schedule 5 and 6
Poisons do not require a permit.
The permit must be held by a person (nominated by the School/Department) with sufficient education or
experience in the handling of Poisons (generally this is a tertiary qualification or 5 years’ experience,
relevant to the poisons listed on the permit). Permit holders are responsible for ensuring that all permit
conditions are met. Staff who require the purchase, access and use scheduled poisons must be authorised
to do so by the permit holder.
Permits are only valid for the named poisons/schedules and locations. Manufacture, distribution, sale or
supply of Scheduled Poisons is prohibited under these permits. Schedule 9 substances may only be used
with the gazetted approval of the Department of Health CEO for certain research and teaching purposes.
Applications for Schedule 9 substances are separate authority.
Permits may outline additional conditions for use, storage, and record keeping for individual poisons or
entire schedules. Permits may also detail any limitations on the size or quantity allowed under the permit.
Poisons covered under a Poisons Permit cannot be used for purposes other than those for which the permit
has been granted.
Please contact Health and Safety for enquiries about applying for a new Poisons Permit or the amendment
of an existing poisons permit.
This section does not include the legal requirements and obligations for prescribing and administering
drugs/medications to people (including authorised personnel and labelling). The use of scheduled poisons
in human or animal research must be approved by the corresponding ethics committee.
20.4 Purchase
It is a requirement for a permit to be in place prior to the purchase of the scheduled poisons above. Permits
must either list the chemicals being used on the permit or list the relevant schedule for them to be compliant.
Suppliers are required to ensure the appropriate permit is held by Curtin prior to the supply of scheduled
poisons requiring a permit.
All purchases of Scheduled poisons must follow Curtin’s chemical pre-purchasing check list (Section 8).
The purchase should be made by the Permit holder or as a minimum the permit holder must provide
authorisation for the purchase.
All Scheduled Poisons must be stored securely. Additional conditions for storage may be stipulated in
Individual Permit conditions.
As a minimum Schedule 4 Poisons must be stored within a locked room or dedicated locked
cupboard/cabinet, with authorised access only.
Schedule 8 and 9 substances must be located within an approved safe. (The safe must meet the
requirements of the Medicines and Poisons Regulations 2016 or the approval of the WA Health
Department).
Schedule 4 poisons require purchase and usage records to be kept. The records should be detailed enough
so that discrepancy of use, lost or stolen poisons would be reasonably detected.
Schedule 8 and 9 poisons require records of purchase and usage and destruction to be kept in a dedicated
record book obtained from the supplier. Inventory records must be entered at least monthly.
20.7 Labelling
Schedule poisons when packaged and sold solely for dispensary, industrial, laboratory or manufacturing
purposes should be labelled according to the requirements of (Section 9)
When packaged for consumer usage (i.e. prescribed medicines), scheduled poisons must be labelled
according to the labelling requirements of the SUSMP – Standard for the Uniform Scheduling of Medicines
and Poisons.
The labelling requirements for decanted drugs, poisons and controlled substances must follow the decanted
labelling requirements outlined in (Section 9.7.3)
20.8 Disposal
Poisons must be disposed of without creating risk to the public. Schedule 8 poisons can only be destroyed
by or under the supervision of a person authorised by the Medicines and Poisons Regulations 2016.
Curtin University currently has an exemption from the excise due to the low volume of ethanol use, although
records must still be kept for a minimum of 5 years. The records must include:
• Amount of ethanol held;
• Amount of ethanol obtained;
• Date the ethanol was obtained;
• Name of supplier; and
• Purposes for which the ethanol is used.
• More information on concessional spirits is available from the Australian Taxation Office website.
Carcinogenic chemicals are hazardous substances that may cause cancer. Three schedules of
carcinogenic chemicals have been declared under The Occupational Safety and Health Regulations 1996
(WA). If the use of a scheduled carcinogen is required, contact Health and Safety for information..
The scheduled substances below are not an exhaustive list of carcinogens. If a chemical is classified as
carcinogenic, a thorough risk assessment should be performed.
The listed carcinogenic substances are subject to the scheduled restrictions as a pure substance; or in a
mixture containing 0.1% or more of that substance determined as a weight/weight (w/w) concentration for
solids or liquids, or a volume/volume (v/v) concentration for gases. They must not be used without the
approval of the Commissioner of Worksafe.
The listed Schedule 5.4 substances have been identified as Carcinogenic substances to be used only for
bona fide research under the Occupational Safety & Health Regulations 1996. The Commissioner must be
notified of the intention to use a Schedule 5.4 carcinogenic substance in the workplace prior to the
commencement of work.
23.3 Carcinogenic substances only to be used for purposes approved by the Commissioner
The listed Schedule 5.5 substances have been identified as requiring approval by the Commissioner of
Worksafe under the Occupational Safety & Health Regulations 1996. This approval must be obtained prior
to the commencement of work.
The Schedule 5.6 substances listed below require approval from the Commissioner of Worksafe for the
purposes of research and analysis under the Occupational Safety & Health Regulations 1996. This approval
must be obtained prior to the commencement of work.
Records must be maintained and kept for each person who works with a scheduled carcinogenic substance.
The records must contain:
• the person’s full name;
• the person’s date of birth;
24.1 Introduction
In addition to the general chemical management requirements, there are additional legislative requirements
for agricultural and veterinary chemicals under the Agricultural and Veterinary Chemicals Act 1995 &
Regulations 1995. The WA government departments that control the use of agricultural and veterinarian
chemicals regulation in WA are the Department of Agriculture and Food and the Department of Health WA.
All agricultural and veterinary products or their active constituent sold in Australia must be registered by the
Australian Pesticides and Veterinary Medicines Authority (APVMA) which provides approval for a product
for the purpose and use as stated on the label.
24.2 Purchase
All chemical purchases require a Chemical or Gas Pre-purchase Checklist to be completed. Due to the
nature of the products, many agricultural & veterinary products are also scheduled poisons. Please refer to
(section 20) for more information about the requirements for poisons.
Use of an agricultural or veterinary chemical other than as directed by the label is termed ‘off label’ use and
requires an APVMA research permit. A Public Chemical Registration Information System Search
(PubCRIS) is maintained on the APVMA website. Contact Health and Safety if you require a permit.
There are controls on the use of agricultural & veterinary chemicals for Agricultural and Veterinary practices
to protect people, animals, crops, and the environment. They cover aspects such as spray drift, overuse
and maximum residue levels and withholding periods for agricultural produce. If an agricultural & veterinary
chemical is required for research into agricultural or veterinary practices or produce, additional licensing or
permit requirements may apply.
Permits to use agricultural chemicals including herbicides, fungicides, baits and poisons, and insecticides
are regulated by the Department of Agriculture and Food https://www.agric.wa.gov.au/ and the Department
of Health WA www.health.wa.gov.au/ in conjunction with APVMA.
Veterinary practitioners are authorised to obtain, possess, use or supply most drugs and poisons for the
lawful practice of their profession, i.e. for the veterinary treatment of animals under their care. You will need
to provide proof that you are a registered veterinarian and that you hold the required poisons permits to
purchase many veterinarian pharmaceuticals.
Manufacturers must ensure that Agricultural and veterinary chemicals have a label in English that complies
with the requirements of the Australian Pesticides and Veterinary Medicines Authority and also includes the
following:
any hazard statement that is consistent with the correct classification of the chemical, and
any precautionary statement that is consistent with the correct classification of the chemical.
The use of certain agricultural chemicals may require health surveillance. This is particularly relevant to
pesticides that contain organophosphates and or benzenes. Health Surveillance will be managed in
accordance with the Health Surveillance Guideline.
24.7 Legislation
25.1 Introduction
In addition to the general chemical management requirements, there are additional legislative requirements
for precursor chemicals and ancillary equipment known to have been used for the manufacture of illicit
drugs under the Misuse of Drugs Act 1981 & Regulations 1982.
Two categories of precursor substances and ancillary materials known to have been used in the
manufacture of drugs are listed in the Misuse of Drugs Act 1981 & Regulations 1982. Stricter controls
applied to Category 1 Items. Research & Education Institutions are exempt from some possession and
supply restrictions, however purchase controls still apply.
Category 1 items (substances and things) are listed in Schedule 3 of the Misuse of Drugs Act Regulations
1982. Purchasers of Category 1 items will be required to hold an account with the supplier, provide a written
order for the item, fill out an end user declaration and provide sufficient evidence of identity on order and
receipt of the item. Suppliers will not supply a Category 1 item with 24 hours of ordering, during which time
the supplier must provide a copy of the end user declaration to the Commissioner of Police.
Division 1 — Substances
Division 2 — Things
Item Description
1 Any storage device containing ammonia gas where the mass of the
storage device is less than one tonne.
Category 2 items (substances and things) are listed in Schedule 4 of the Misuse of Drugs Act Regulations
1982. Purchasers of Category 2 items will be required to either hold an account with the supplier and
provide a written order for the item or alternatively fill out an end user declaration and provide evidence of
identity on order and receipt of the item. Copies of end user declarations for Category 2 items will be
provided to the Commissioner of Police as soon as practicable.
Table 10: Category 2 items under the Misuse of Drugs Act Regulations 1982, Schedule 4.
Division 1 — Substances
Ethanamine Monoethylamine
N-Ethylephedrine
N-Ethylpseudoephedrine
Formamide
Hydrobromic acid Hydrogen bromide
Hypophosphite salts
Isosafrole 1, 3-Benzodioxole,
N-Methylformamide
Palladium (including salts)
Phenylalanine
Piperidine
Piperonal 3,4-Methylenedioxy-benza 50 g
ldeyde, Heliotropine
Alkali metal - Potassium
Sassafras oil 91 ml
Sodium Borohydride
Division 2 — Things
Description Details
Gas cylinder containing hydrogen sulphide gas
Gas cylinder containing hydrogen gas
Gas cylinder containing methylamine gas
Description Details
Round bottom reaction flask Capacity 500 ml or greater (including the repair or
modification)
Condenser Joint size B19 or greater
Splash heads and distillation heads
25.4 Legislation
• Misuse of Drugs Act 1981 (WA)
• Misuse of Drugs Regulations 1982 (WA)
• Code of Practice for Supple Diversion into Illicit Drug Manufacture (PACIA)
26.1 Scope
The general chemical management requirements are relevant to the management of radioactive chemicals.
Additional requirements for radioactive chemicals are identified in this section.
26.2 Introduction
26.3 Legislation
26.4 Registration
The Radiation Safety Act 1975 (WA) requires Curtin University to hold a Certificate of Registration for the
possession and use of all radiation sources. The University’s Registration is centrally controlled and
maintained by Curtin University’s Radiation Safety Officer (RSO), reporting to the University Radiation
Safety Committee. The RSO is responsible for instituting and maintaining a system of radiation safety at
the University, which includes maintaining registration limits of all radiation sources used by Curtin and
coordinating modifications to the current registration.
26.5 Licensing
The Radiation Safety Act 1975 (WA) requires individuals working with radioactive chemicals to hold, or
work under the supervision of someone holding, a radioactive substances licence. Licences are obtained
from the Radiation Health branch of the WA State Government Department of Health. Initial applications
for a licence must be forwarded to the University RSO who will confirm eligibility and write a letter of support
for the applicant. Subsequent licence renewals can be forwarded directly to the Radiation Health Branch.
The responsibility for implementation of the safe management of radioactive chemicals rests with the Heads
of Schools, managers and supervisors. Each workplace is responsible for enforcing the procedures and for
ensuring that staff and students have the necessary information, instruction, training and supervision before
commencing radiation work. To assist Heads of School, managers and supervisors, each area may
nominate a local Radiation Safety Supervisor to liaise with both local Health & Safety personnel and the
University RSO. These representatives are listed in the Radiation Safety Manual
All supervisors of projects involving radioactive substances at the University are required to complete a
radioactive substances project application. The application must be completed in the InfoEd systems and
submitted to the University Radiation Safety Officer (RSO) for final approval. Further details can be found
in the Radiation Safety Manual. InfoEd user guides and templates can be found at the Manage Your
Research website.
26.8 Training
All radioisotope users at the University are required to have a level of training appropriate to the work they
are conducting. This training can be one of the WA Regulator accredited courses or an equivalent level
qualification. The licence holder must retain documentary evidence of the training of each user under his/her
supervision. The University RSO can provide further information related to accredited courses.
A radioactive substances project application (or amendment) must be submitted before any new purchase
of radioactive chemical, as some facilities may require modifications to accommodate certain radionuclide
activity levels. Maximum activities for each radioisotope are registered at each location so it is important to
ensure the total activities remain below these limits. For repeat orders of radioactive chemicals already
covered by an existing approved project it is only necessary to inform the local Radiation Safety Supervisor
to ensure activity limits for the location are not exceeded. The RSO should be contacted if the limits at any
location need to be changed.
Records following the movement of radioactive substances must be kept and regularly updated. Records
must detail activities, physical form of radioisotopes, supplier, arrival date, use details, disposal method and
disposal date. Comments could also be included on the form of packaging and if necessary, the quality of
the packaging. Signed receipts should be obtained. The container and the storage location should be clearly
marked with a radiation tri-foil symbol. Decanted radioactive chemicals must be written in English, include
the product identifier and the activity. Locations and activities of all stored radioisotopes should be kept and
forwarded to the RSO for registration purposes.
The objective of radiation monitoring is to ensure that existing safety procedures are effective at keeping
dosage and exposures from scattered or incidental radiation as low as reasonably achievable (ALARA).
Monitoring and Testing techniques include personal radiation monitoring badges, biological monitoring, and
wipe testing and radiation surveys. All radioisotope laboratories should adopt one or more of these
techniques appropriate for the work being conducted. Details about the most appropriate technique(s) can
be found in the Radiation Safety Manual
All solid radioactive chemical waste and insoluble liquid waste must be put in a thick-walled plastic liner
and subsequently placed in a sturdy cardboard box. Different radioisotopes should not be mixed in the
same box. The box should be labelled with the radioisotope, the activity, the date, a contact name and
department. These wastes will need to be delivered to the Curtin Radioactive Waste Store. The RSO should
be contacted to arrange this disposal. Soluble liquid waste should be disposed of using a flushing sink in a
registered radioisotope laboratory. The activity flushed must be within the regulatory limits.
For further advice on managing risks in university workplaces, including procedures, guidance, forms and
training courses, please go to the Health and Safety Policies and Procedures website, including:
Health and Safety Policy
Health and Safety Responsibilities Procedures
Health and Safety Management Standards
Pre-purchase checklist for Chemicals
Pre-purchase checklist for Gases
Pre-purchase checklist for Materials
Pre-purchase checklist for Plant and Equipment
Generic Risk Assessment Template
Safe Work Procedure template
Workplace Inspection Checklist
Induction Checklist
Waste Disposal Manifest
Management of Time Sensitive Chemicals
Managing Chemical Waste Guidelines
Emergency Response information including First Aid and Warden information can be found at Emergency
Management.