Hazardous substances FAQs
The following information is about substances that meet the definition of 'hazardous substances' in the Occupational Safety and Health Regulations 1996. There are also requirements for ensuring the safety with other chemicals at the workplace and these are outlined under Chemical control and Safety priorities for working with hazardous substances.
Many hazardous substances are also classified as dangerous goods. Dangerous goods are substances and articles that have the potential to cause harm to people, property and the environment. Dangerous goods are regulated by the Department of Mines, Industry Regulation and Safety (Dangerous Goods branch).
What is a hazardous substance?
Hazardous substances may have harmful effects on people, either directly through toxic effects, or indirectly through causing a fire or hazardous reaction. Hazardous substances may be in the form of a liquid, solid or gas. Examples are poisons, and substances that could cause burns, eye irritation or cancer.
Under the OSH Regulations 1996, a substance is a hazardous substance if it meets criteria under:
- the Approved Criteria (AC) classification system; or
- an international system called the Globally Harmonised System of Classification and Labelling of Chemicals (GHS classification system).
At this stage Western Australia has not mandated the use of the GHS, however, if businesses export/supply to other states or territories within Australia that have already implemented the GHS, they will need to be GHS compliant. If WA businesses do not export/supply to other states and territories and do not wish to use the GHS at this time, they can continue using the existing Australian classification system (known as the Approved Criteria).
The person manufacturing or importing the chemical is responsible for conducting the hazard classification and can choose whether to use the AC or GHS classification system.
- Under the AC classification system, a substance is a hazardous substance if:
- any of its ingredients is entered in the Hazardous Substances Information System (HSIS) database at concentrations above the cut-off concentration; or
- it meets the criteria in the document Approved Criteria for Classifying Hazardous Substances [NOHSC: 1008 (2004)].
The AC classification system is based on health hazards.
- Under the GHS classification system (also called the GHS or the Globally Harmonised System of Classification and Labelling of Chemicals 3rd revised edition), a substance is a hazardous substance if it meets any of the criteria in this system. Under the GHS system Material Safety Data Sheets (MSDS) are referred to as Safety Data Sheets (SDS).
In general, the GHS has a bigger scope due to the inclusion of both health and physicochemical hazards in the criteria and as a result a larger number of chemicals will be classed as hazardous under the GHS compared to the AC classification system.
If a substance is classified as a hazardous substance, there are specific duties under Part 5 of the OSH Regulations 1996 for:
- those who manufacture, import or supply it; and
- the employer, main contractor or self-employed person in relation to its use at the workplace.
Where do I find information on the Globally Harmonized System (GHS)?
What do manufacturer and importers of a hazardous substance need to do?
Manufacturers and importers must:
- determine whether substances they manufacture or import are hazardous substances;
- before the hazardous substance is supplied to workplaces, prepare a MSDS/SDS (see below) and ensure it is available;
- review and revise the MSDS/SDS as often as necessary to keep it up to date, and at least every five years;
- provide the MSDS/SDS to a person who buys the hazardous substance from them for the first time;
- provide the MSDS/SDS to a person who has previously bought, or is considering buying, the hazardous substance from them at the request of that person; and
- correctly label hazardous substances they supply (see below).
What is a MSDS?
A Material Safety Data Sheet (MSDS) is a document that provides information about a hazardous substance and how to safely use it at the workplace. It must be written in English and contain the information outlined in the National Code of Practice for the Preparation of Material Safety Data Sheets [NOHSC: 2011 (2003)].
For hazardous substances classified under the GHS classification system, the Safety Data Sheet (SDS) must contain the hazard classification, hazard statements and precautionary statements set out in the Globally Harmonised System of Classification and Labelling of Chemicals 3rd revised edition.
How do I write a MSDS?
Guidance on the information required in a MSDS is given in the National Code of Practice for the Preparation of Material Safety Data Sheets [NOHSC: 2011 (2003)] and the Commission guidance note, Material Safety Data Sheets.
Guidance on the information required in a SDS for hazardous substances classified under the GHS is set out in the Preparation of Safety Data Sheets for Hazardous Chemicals.
What are the requirements for labelling a hazardous substance?
A supplier of an AC classified hazardous substance (see above) for use in a workplace must ensure that:
- the container in which it is supplied is labelled in accordance with the requirements of the National Code of Practice for the Labelling of Workplace Substances [NOHSC: 2012(1994)]; and
- the chemical name of any type II or type II ingredient is disclosed on the label or, where the identity of a type II ingredient is commercially confidential, the generic name of that ingredient.
A supplier of a GHS classified substance for use in the workplace must ensure that any container in which the substance is supplied is labelled in English with:
- label information required by the Globally Harmonised System of Classification and Labelling of Chemicals 3rd revised edition (the GHS); and
- the name of the supplier, their Australian address, their telephone number and an Australian emergency telephone number.
Guidance on the labelling of workplace hazardous chemicals classified under the GHS can be found in the Safe Work Australia Code of Practice “Labelling of Workplace Hazardous Chemicals”.
How do I know if a substance I have purchased for use at work is a hazardous substance or not?
The supplier should be able to provide you with a MSDS or SDS for the substance. MSDS’s formulated under the Approved Criteria will contain a statement such as This product is classified as hazardous according to the criteria of Safe Work Australia or This product is not classified as hazardous according to the criteria of Safe Work Australia. This terminology is not mandatory for SDS using the GHS. For SDS using the GHS, Section 2 of the SDS will provide detail on the type of hazard (eg. May cause an allergic skin reaction), and any GHS hazard in this section indicates the substance is hazardous. Signal words such as ‘WARNING’, ‘DANGER’, ‘POISON’ or ‘HAZARDOUS’, may also be found on the label and are a good indicator that the substance is hazardous.
If you are not sure whether the substance is hazardous, contact your supplier or the manufacturer/importer and ask the question. Always request that they provide their answer in writing.
What are the duties of employers, self-employed people and main contractors in relation to hazardous substances that will be used at work?
- consult with people who might be exposed to the hazardous substance at the workplace about the intention to use the substance and the safest method of using it;
- obtain (from the supplier) a material safety data sheet (MSDS) / Safety Data Sheet (SDS) before or on the first occasion a hazardous substance is supplied to the workplace;
- keep a current hazardous substances register of all hazardous substances used at the workplace from time to time and ensure it is readily available (see below);
- undertake a risk assessment for all hazardous substances, including air monitoring if needed, and in some cases prepare a risk assessment report (see below);
- provide information and training to people likely to be exposed to a hazardous substance at the workplace before they start work, including information and training on:
- the potential health risks and any toxic effects;
- the control measures and their correct use;
- correct care and use of PPE; and
- any need for, and details of, health surveillance.
- keep records of the information and training provided;
- reduce the risks to people at the workplace that could arise from exposure to a hazardous substance by means of preventing of exposure, or where this is not practicable, reducing exposure using controls other than personal protective clothing and equipment (PPE). Only use PPE where other controls are not practical or not sufficient;
- ensure no person is exposed at the workplace to a hazardous substance above its exposure standard (see below);
- in certain situations, ensure there is health surveillance – see below.
How do I do a ‘hazardous substances’ risk assessment?
Any competent person can do a ‘hazardous substances’ risk assessment. Some straightforward assessments can be done in-house. Others may be more complex and you may need to engage someone with expertise such as an occupational hygienist. Consultants can be found in a telephone directory or online under ‘occupational health and safety’ or ‘occupational hygiene’. Some occupational hygienists are listed by the Australian Institute of Occupational Hygienists.
The employer, main contractor and self-employed person must assess the risk of injury or harm that could occur to people as a result of being exposed to each hazardous substance at the workplace. Substances with similar hazards that are used in the same way can be assessed as a group (eg a spray painter may assess all 2-pack isocyanate based paints as a group).
The risk assessment must include, as far as practical:
- identification of each hazardous substance used at the workplace;
- a review of the MSDS and label for the substance;
- a review of how the substance is actually being used;
- assessment of the likelihood and seriousness of injury or harm that may occur as a result of exposure; and
- the outcome of the assessment must be recorded in the hazardous substances register (see below).
Where a risk assessment for a hazardous substance finds there is a significant risk of injury or harm occurring, a report, including action items, must be prepared.
Risk assessments must be reviewed if it appears that there is an increase in the risk, or when it has been five years since the last assessment was completed.
Information on how to do a risk assessment for the use of ‘hazardous substances’ can be found in the Guidance Note for the Assessment of Health Risks Arising from the Use of Hazardous Substances in the Workplace, on the Safe Work Australia website.
To assist you:
What are exposure standards and where are they listed?
Regulation 5.19 of the OSH Regulations 1996 requires an employer, main contractor or self employed person to ensure that no person is exposed at the workplace to a hazardous substance above its exposure standard.
Exposure standards represent airborne concentrations of substances in a person’s breathing zone, which should neither impair the health of nor cause undue discomfort to nearly all workers. Additionally, the exposure standards should guard against narcosis or irritation, which could cause accidents.
The easiest way to find current exposure standards is by using the Hazardous Chemicals Information System (HCIS) database on the safe Work Australia website and searching either by the Chemical Abstracts Service (CAS) number of the chemical or by the chemical name. The HCIS database is regularly updated by Safe Work Australia.
Interpretation of airborne chemical concentrations can be complex and should be done by a competent person and with reference to the Guidance on the Interpretation of Workplace Exposure Standards for Airborne Contaminants.
What is a hazardous substances register?
Under the OSH Regulations 1996, the employer, main contractor or self-employed person must keep a current register of each hazardous substance used at the workplace.
A hazardous substance register must have as a minimum:
- a list of all the hazardous substances used in the workplace;
- the MSDS/SDS for each hazardous substance; and
- a notation against each hazardous substance as to whether a risk assessment has been completed.
A hazardous substance register must be readily available to all workers potentially exposed to the hazardous substances, including emergency services.
A sample index for a ‘hazardous substances register’ is available from the WorkSafe website. A register of hazardous substances (including the list, MSDS and reference to risk assessments) may be provided electronically if all workers who may need to access the Register have access to a computer and are trained on how to use the system. There should be a system in place to ensure the register will be readily available in the event of foreseeable incidents such as a power failure or network failure. For example, a local copy of the register on a charged laptop could be used in the event of power/network failure; or a hard copy of the register may be used as a backup.
Are ‘hazardous substances’ and ‘dangerous goods’ the same thing?
Hazardous substances are substances that meet criteria under either the AC classification system or the GHS classification system (see above). Dangerous goods are substances or articles that, because of their physical and chemical (physicochemical) or acute toxicity properties, present an immediate hazard to people, property or the environment. Many substances are both hazardous substances and dangerous goods, however there are substances that are hazardous substances but not dangerous goods, and vice versa.
In WA, dangerous goods are regulated under the Dangerous Goods Safety Act 2004 – see the Department of Mines, Industry Regulation and Safety (Dangerous Goods section) for more information on dangerous goods.
Is a hazardous substances register the same as a dangerous goods manifest?
No. These information sources contain different information to meet different needs. A hazardous substances register is mainly for use by people at the workplace who are potentially exposed to hazardous substances, whereas a dangerous goods manifest is for use by emergency services. More information on dangerous goods requirements is available from the Department of Mines, Industry Regulation and Safety.
How do I know if my workplace contains asbestos containing material?
Workplaces where asbestos is present should have an asbestos register prepared by a competent person, showing which materials contain asbestos or have been presumed to contain asbestos. Buildings built before the late 1980s commonly contain asbestos materials. Asbestos materials are also found in some plant (eg in gaskets or friction materials), may be processed at waste handling facilities, and may be found at contaminated sites or be naturally occurring in some areas.
The only sure way to find out if the material does contain asbestos is to get a small sample analysed by a laboratory. Accredited laboratories can be found via the National Association of Testing Authorities website.
More information on asbestos handling and management.
How do I know if I need to measure the levels of chemicals in air at my workplace?
Your risk assessment should help you to work out if you need to do air monitoring. Some indicators of a need for monitoring may include:
- frequent or long duration use of a chemical or process which generates hazardous vapour, dust, mist or fume; and
- efficiency of ventilation is not known or no mechanical ventilation; and/or
- people in the workplace are complaining of health concerns that may be due to the vapour, dust, mist or fume; and/or
- there is the potential for serious health effects if controls are inadequate; and/or
- it is a complex work environment and it is difficult to estimate exposure.
If you are still unsure, consult an occupational hygienist for advice.
Can WorkSafe measure the levels of airborne chemical contaminants in my workplace?
WorkSafe does not offer a consultancy service to assess the risk from the use of hazardous substances in workplaces.
You can make enquiries for the names of likely consultants through:
- professional associations such as the Australian Institute of Occupational Hygienists
- your local trade or industry association;
- business colleagues and organisations;
- professional associations;
- the yellow pages of the telephone directory under ‘occupational health and safety’, ‘risk management consultants’ or ‘analysts’; or
- internet search engines, using keywords such as ‘occupational hygienists’.
I have a flammable liquid storage cabinet at my workplace, what do I need to know to use it safely?
Your cabinet should be constructed in accordance with Australian Standard, AS 1940 The Storage and Handling of Flammable and Combustible Liquids. This is available for purchase from SAI Global or you can view it at the WorkSafe library.
The bottom of the cabinet is designed to hold spills and should not be used for storage.
Use your cabinet only for flammable and combustible liquids – do not store other classes of dangerous goods in it, unless you have checked that they are compatible with the flammable and combustible liquids.
The self-closing mechanism of the doors should be in good working order.
The cabinet should be marked with a Class 3 Flammable liquid label and the words ‘No Smoking, No Ignition Sources within 3m’ and the maximum storage quantity of the cabinet.
Containers in the cabinet must be closed tightly (unless the container requires vapour release).
Cabinet ventilation may be required for very volatile, toxic or corrosive substances. This can be determined by a risk assessment. If your cabinet smells, ensure it is clean and that all containers are clean and tightly closed. If cabinet ventilation is required, it must be to the outside of the building away from air intake points and the ventilation must not reduce the level of fire protection of the cabinet or create an ignition source. (Note: opening cabinet ventilation outlets without venting to the outside is not recommended, as it could allow flammable vapours into the work environment and reduce the fire protection of the cabinet).
The cabinet should be located:
- so as not to impede emergency exits; and
- 3m or more from ignition sources other than ceiling lights.
For further information refer to Australian Standard, AS 1940 The Storage and Handling of Flammable and Combustible Liquids.
For large quantities of flammable liquids, refer to the dangerous goods requirements administered by the Department of Mines, Industry Regulation & Safety.
What quantity of flammable liquid requires a flammable liquid cabinet?
Quantities requiring a cabinet (or a flammable liquid store) depend upon the type of workplace, the floor space and the nature of the flammable or combustible liquid. Refer to AS 1940 - The Storage and Handling of Flammable and Combustible Liquids for further information.
What do I do if the SDS for the hazardous substance I have at my workplace is out of date?
Consider if the hazardous substance is still required at the workplace or no longer used, as you may decide to dispose of it. If the product is retained, a recent SDS (no more than 5 years old) must be readily available where practicable at the workplace.
In the first instance an updated version should be requested from the supplier, manufacturer or importer. However, if the manufacturer has ceased trading, and an updated SDS is not available, the old SDS can be kept on the register with a note that it is the most recent. More recent information should be used to supplement it (to ensure for example that users are aware if the hazards have been reclassified). This could be a recent SDS from another supplier provided the formulation is the same (eg pure chemicals), or it could be a third party SDS (ie prepared by a consultant), or equivalent information.
For further information – Safe Work Australia: Safety data sheets
- Hazardous substances compliance tools;
- Hazardous substances register
- Record of risk assessment for a hazardous substance
- Safe Work Australia Managing risks of hazardous chemicals in the workplace 2012
- Safe Work Australia Managing risks of storing chemicals in the workplace
- Hazardous Substances Information System (HSIS) database
- Approved Criteria for Classifying Hazardous Substances [NOHSC: 1008 (2004)].
- Hazardous Chemicals Information System (HCIS)
- Guidance on the Interpretation of Workplace Exposure Standards for Airborne Contaminants
- Health Monitoring For Exposure to Hazardous Chemicals – Guide for Medical Practitioners
- Asbestos handling and management
- Removal from lead work – management of workers
- Health surveillance
- GHS - Globally harmonised system of classifying and labelling of chemicals
- Safe Work Australia’s GHS FAQ
- WA GHS bulletin
- Classifying chemicals using the GHS
- The GHS – Third Edition
- Globally Harmonised System of Classification and Labelling of Chemicals 3rd revised edition (the GHS);
- Guidance on the labelling of workplace hazardous chemicals classified under the GHS can be found in the Safe Work Australia Code of Practice Labelling of Workplace Hazardous Chemicals
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