Hazardous Substances Management Policy

1.

Objectives

Flinders University is committed to ensuring that:

• all areas of the University comply with legislation;
• staff and students working with hazardous substances have received all requisite training, are aware of the potential hazards involved and follow established procedures.

2.

Policy

Flinders University will take all reasonable steps to minimise exposure of employees, students and visitors to all hazardous substances used on the premises. In addition, facilities and procedures will be established to reduce exposure to any hazardous substance to as low as reasonably achievable and in any case, below the Exposure Standards for Atmospheric Contaminants in the Occupational Environment (National Occupational Health and Safety Commission (NOHSC)) as updated from time to time.

3.

Definitions

'Atmospheric monitoring' means the sampling of the atmosphere in a workplace to determine a quantitative estimate of the amount of a hazardous substance in the air.

'Biological monitoring' means the measurement and evaluation of a hazardous substance or metabolites in the body tissues, fluids or exhaled air of a person.

'Central Register of hazardous substances' means a list of all hazardous substances (electronic or hard copy) held by the University on University premises.

'Chemwatch' is the chemical database used by the University to assist with management of chemicals.

'Contractor' means any organisation or person (not being an employee of The Flinders University of South Australia) engaged by the University to perform some work or service on University premises.

'Cost Centre register of hazardous substances' means a list of all hazardous substances (electronic or hard copy) and a Material Safety Data Sheet (MSDS) for each substance held within the Cost Centre.

'Hazardous substance' means a substance that is listed in the List of Designated Hazardous Substances (NOHSC) as updated from time to time, or a substance that is determined to be a hazardous substance by a manufacturer or importer of the substance on the basis of the Approved Criteria for Classifying Hazardous Substances (Worksafe Australia).

'Health surveillance' means the monitoring of persons to identify changes (if any) in their health due to exposure to a hazardous substance and includes biological monitoring. Health surveillance records are confidential and held by the Medical Practitioner performing the health surveillance, or by the OH&S Unit.

'Local register of hazardous substances' means a list of all hazardous substances and a copy of the manufacturer's MSDS for each hazardous substance held within the area of the University, under the authority of any one supervisor. Included in the local register of hazardous substances are completed records comprising completed risk assessment forms for tasks requiring the use of hazardous substances and records of exposure measurements with regard to hazardous substances used locally.

'MSDS' means Material Safety Data Sheet and is an information sheet about a hazardous substance prepared by a manufacturer or importer of the hazardous substance. The MSDS must conform to the format set out in the Approved Code of Practice for the Preparation of Material Safety Data Sheets (South Australian Government).

'Premises' means any building, structure or property.

'Risk Phrases' convey a general description of the hazard and should give notice of the hazards present with the normal, or reasonably foreseeable, handling or use of the substance. For example: ‘Flammable’ or ‘Irritating to the skin’ or ‘Harmful if swallowed’.

‘Safety Phrases’ provide information on safe storage, handling and personal protection. For example: ‘Keep container dry’; or ‘When using do not eat or drink’; or ‘Wear suitable protective clothing and gloves’.

‘Signal words’ are words prominently displayed on labels to indicate the relative severity of the hazard. For example: HAZARDOUS or POISON.

'Substance' means any natural or artificial substance whether in solid, liquid or gaseous form.

'Supervisor' means a person who provides guidance and/or instruction as defined in the Occupational Health, Safety and Welfare policy.

4.

Implementation of the Policy

All major Cost Centres must ensure that the following matters are addressed.

4.1 Identification of all hazardous substances that are held on the premises, that are brought onto the premises and that are known to be produced on the premises. Where necessary this identification shall be extended to include by-product and waste hazardous substances.

4.2 Provision of an appropriate label and an MSDS for each hazardous substance used in the workplace. The MSDS of the hazardous substance must be readily available to all staff and students who could be exposed to the hazardous substance.

4.3 Provision of information about the hazards and training in the means of assessment and control of exposure to hazardous substances for all staff and students who could be exposed to hazardous substances in the course of their work.

4.4 Provision for the assessment of risk arising from exposure to hazardous substances and the facilities and resources for minimisation of the risk.

4.5 Provision for the atmospheric monitoring of exposure to hazardous substances where required and, if necessary, provision for health surveillance.

5.

Responsibilities

For the purpose of management of hazardous substances, the following responsibilities have been assigned.

5.1. The Vice-Chancellor

As the responsible officer under the OHS&W Act 1986 the Vice Chancellor is responsible for providing the infrastructure for the central register of hazardous substances by:

1. provision of adequate resources to establish and maintain the central register of hazardous substances; and
2. ensuring that all staff who require it are instructed in the use of the central register of hazardous substances.

5.2 Cost Centre Heads

The Head of each Faculty, the University Librarian and the Director of Administration and Registrar shall be responsible for:

1. nomination of a Hazardous Substances Manager for the Cost Centre; and
2. ensuring adequate resources are available to set up and maintain the Cost Centre register of hazardous substances.

5.3 University Hazardous Substances Manager

The University Hazardous Substances Manager is responsible for providing advice to the Cost Centre Hazardous Substances Managers.

5.4 Cost Centre Hazardous Substances Managers

The Cost Centre Hazardous Substances Managers are responsible for coordinating the management of hazardous substances within their Cost Centre. The Hazardous Substances Managers are responsible for:

1. ensuring that when supervisors notify them of hazardous substances, those substances are entered on the register of hazardous substances;
2. compiling a Cost Centre register of hazardous substances. The Cost Centre register must be updated regularly;
3. ensuring that each hazardous substance used, stored and (where applicable) produced by the Cost Centre for supply has a current Material Safety Data Sheet (MSDS) which is kept on file in the Cost Centre register of hazardous substances;
   
   ensuring that any substance that a supervisor imports directly from outside Australia into the Cost Centre is accompanied by an MSDS from the supplier and is entered on the register;
   
   ensuring that the supervisor of the area importing a substance directly is aware of the need for it to be classified according to the Approved Criteria for Classifying Hazardous Substances.

5.5 Staff Producing New Substances

Staff must inform the Cost Centre Hazardous Substances Manager of all new substances produced for supply and must consult with the Hazardous Substances Manager regarding application of the Approved Criteria for Classifying Hazardous Substances.

5.6 Supervisor

Supervisors shall:

1. inform the Cost Centre Hazardous Substances Manager of any new hazardous substance that is acquired, held and (where applicable) produced by the Cost Centre and;
2. ensure that any substance imported directly is classified according to the Approved Criteria for Classifying Hazardous Substances;
3. ensure that the local hazardous substances register and MSDSs are readily available to any employee/student who may be exposed to any locally used hazardous substance during the course of their work/study;
4. inform all staff and students of the hazardous substances used in the local area, the types of hazards posed by the hazardous substances, and the location of the local hazardous substances register and MSDSs;
5. ensure that a suitable and sufficient risk assessment is conducted for any task requiring the use of a hazardous substance. Depending on the situation this can be accomplished by either reviewing the MSDS, or by undertaking a generic assessment for a given substance, or by undertaking a more detailed task-based assessment (see Section 9 of this Policy);
6. ensure that staff and students who handle hazardous substances or are likely to be exposed to hazardous substances undertake appropriate training (see Section 5 of this Policy); and
7. ensure that each hazardous substance is appropriately labelled.

5.7 Staff/Students

Staff/students must ensure that they:

1. read the label of a container that holds any hazardous substance and take note of the 'risk phrase(s)' and 'safety phrase(s)' thereon;
2. do not adversely expose themselves or other staff/students to any hazardous substance; and
3. assist in the day-to-day management of hazardous substances in their workplace.

5.8 Contractors

Contractors must ensure that:

1. all workers in their employment abide by Section 5.7 of this procedural guideline; and;
2. the supervisor, in whose area the work is undertaken, is advised of all hazardous substances brought onto the premises in the course of carrying out the contract.

6.

Labelling

All hazardous substances must be labelled in accordance with the Approved Code of Practice for Labelling of Workplace Substances.

In the following cases labelling should be according to the guidelines detailed below:

6.1 Where a hazardous substance is transferred or decanted from the Supplier’s container and not used immediately the recipient container must be labelled with:

1. the name of the product;
2. the appropriate 'risk phrase(s)' (see definitions); and
3. the appropriate 'safety phrase(s)' (see definitions).

NOTE: Appropriate 'risk phrase(s)' and 'safety phrase(s)' are set out against each hazardous substance in the List of Designated Hazardous Substances (NOHSC), or may be copied from the Supplier’s label.
.
NOTE: Items 6.2 and 6.3 must be read in conjunction with Appendix 2 which specifies labelling required for containers of different capacities.

6.2 Where a hazardous substance is diluted or mixed with another substance (hazardous or otherwise) in transferring to a separate container, the labelling information requirement will depend on the 'concentration cut off level' which is set out in the List of Designated Hazardous Substances.

1. Where the 'concentration cut-off level' is exceeded, the label affixed to the container must show:

(a) the name of the product;

(b) the appropriate "risk phrase(s)"; and

(c) the appropriate "safety phrase(s)".

2. Where the 'concentration cut-off level' is not exceeded, the labelling requirement is for the product name only. Further information is available in the Approved Code of Practice for Labelling of Workplace Substances.

6.3 Where a hazardous substance is manufactured, synthesised or produced as a by-product within the premises of the University, a label must be affixed as described in the Approved Code of Practice for Labelling of Workplace Substances and reproduced in Appendix 2.

All other containers of the same hazardous substance must be labelled with:

1. the name of the product;
2. the appropriate 'risk phrase(s)'; and
3. the appropriate 'safety phrase(s)'.

7.

Induction and Training

The University will provide induction and training for use of hazardous substances (as required).

Items to be covered include provision of information (MSDS), rights and responsibilities, assessment of risk of exposure and, where required, monitoring exposure and control measures for minimising exposure to hazardous substances.

Any staff or student who:

1. uses a hazardous substance or is likely to be exposed to a hazardous substance during the course of their work; or
2. supervises staff or students handling hazardous substances
   must be appropriately trained.

8.

Identification of Risk

The health risk in handling any particular hazardous substance will vary with each substance and the way in which the substance is used. The supervisor is responsible for conducting health risk assessments for each hazardous substance used locally (refer section 5.6)

Factors such as route of exposure, type of disease or injury and the relative toxicity of the hazardous substance need to be considered for assessment of risk to health. Information about all of these factors can be found in the MSDS for each hazardous substance and the suppliers label on the container holding a hazardous substance.

9.

Risk Assessment

Risk assessment is the process of measuring the health risk associated with the use of a hazardous substance. This can be determined by:

1. a review of the MSDS;
2. review of the Supplier’s label on the consumer package;
3. identification of risks to health.

Notification must be made on the register if there is NOT a significant risk to health.

Task-based Assessment

• A task-based assessment is preferred when a particular hazardous substance is used repetitively under the same circumstances in a particular area within the work place.

Generic Assessment

• A generic assessment is preferred when a particular hazardous substance is used in the same or similar circumstances in a number of different areas within the workplace.

See Appendix 3 for the Risk Assessment Table.

10.

Risk Control

If there is a significant risk to health:

1. record details of the risk assessment on the register;
2. review current measures for control of exposure;
3. the procedure for the control of hazardous substance exposure risks depends on the level of risk.

Consideration should be given to the following hierarchy of control measures:

1. elimination of the hazardous substance;
2. substitution of a less hazardous substance;
3. isolation of the process in which the hazardous substance is used;
4. engineering control to reduce the hazardous substance in the work environment;
5. safe work practice to reduce the person's exposure to the hazardous substance;
6. provision of personal protective equipment as a barrier against exposure to the hazardous substance.

The assessment for the hazardous substance should be reviewed in 5 years, or when there is a change in the circumstances of use of the particular substance.

11.

Records of Exposure

Monitoring may be required as part of the assessment of risk to determine the adequacy of current control measures and/or introduced control measures. If exposure routinely approaches standards set out in Exposure Standard for Atmospheric Contaminants in the Occupational Environment, contact the OH&S Unit for advice.

12.

Health Surveillance

Health surveillance may be required for staff and students who are at a significant risk of ill health effects from a hazardous substances. Consult the OH&S Unit for advice.

The determination of health status and health surveillance of staff or students who use a hazardous substance listed in Schedule 6 of the Occupational Health Safety and Welfare Regulations, 1995, must be performed by a registered Medical Practitioner.

13.

Disposal

Disposal of hazardous substances must be carried out in accordance with the Flinders University Waste Disposal policy taking into account the provisions of the Environment Protection
Act (1993).

14.

Emergencies

In situations where a spilled hazardous substance results in a significant risk of exposure to staff and students, the Emergency Control Policy should be followed, and the OH&S Unit notified

Appendices

1. Background
2. Requirements for the Labelling of Hazardous Substances.
3. Risk Assessment Table
4. Assessment Record
5. Legislative Framework

APPENDIX 1

Background

Pure chemicals and composite substances used in the workplace have the potential to cause sickness or other adverse biological effects in an individual. Short term or long term exposure to a hazardous substance can lead to both acute and chronic adverse effects. Effects such as allergies and acute illness can usually be identified and dealt with within minutes (or days) of exposure to a hazardous substance. Situations in which the effects of exposure are delayed or gradual, while no less important, are more difficult to address because there is often a lack of obvious causality.

Substances that cause cancer (carcinogens) commonly have a latency period of 20-30 years and other hazardous substances are poorly disposed-of through excretory pathways, leading to an accumulation of the substance within the body and gradual ill health. This is exemplified by the industrial uses of lead compounds, which have been proven to affect blood forming, nervous and kidney systems upon long term exposure. It is clear that minimisation of exposure to such compounds is highly desirable to avert long term health effects.

Section 4 of the Occupational Health, Safety and Welfare Regulations, 1995, pursuant to the Occupational Health, Safety and Welfare Act (1986) is devoted to the use of hazardous substances in the workplace. The main focus of this section is on identification of hazardous substances, and the assessment and control of exposure to substances that have adverse health effects on persons at work in all workplaces throughout South Australia.

All known hazardous substances must be labelled in accordance with the Approved Code of Practice for Labelling of Workplace Substances.

The information required on labels fixed to containers of capacity greater (or equal to) 500 g or 500 ml is:

1. Signal word(s) and dangerous goods class (where applicable);
2. Product name, chemical name, United Nations (UN) number and ingredients;
3. Risk phrase(s);
4. Safety phrase(s);
5. First aid procedure(s);
6. Emergency procedure(s);
7. Details of manufacturer/supplier;
8. Directions for use (where appropriate);
9. Expiry date (where applicable);
10. Reference to MSDS.

The information required on labels fixed to containers of capacity less than 500 g or 500 ml is:

1. Signal word(s) and dangerous goods class (where applicable);
2. Product name, chemical name;
3. Risk phrase(s) (at least the most significant);
4. Safety phrase(s) (at least the most significant);
5. First aid procedure(s);
6. Details of manufacturer/supplier;
7. Reference to MSDS.

Where the container is too small to accommodate the above information, then the minimum requirement is:

1. Signal word(s) and dangerous goods class (where applicable);
2. Product name;
3. Details of manufacturer/supplier.

APPENDIX 3

Assessment reports should reflect the detail of the assessment. They should record sufficient information to show why decisions about risks and precautions were made.

Assessments which identify that there is not a significant risk to health do not need to be recorded in full. It is sufficient to include a notation in the register to indicate that each step of the assessment has been done. This should include the date, the MSDS or equivalent information that was reviewed and a notation that controls are in place.

Where the assessment indicates that there is a significant risk to health, an assessment report shall be made and kept as a record.

1. Occupational Health, Safety and Welfare Regulations, 1995 (referred to as the Consolidated Regulations), in particular, Part 4: Hazardous Substances.
   (http://scaleplus.law.gov.au/html/sasreg/0/207/top.htm)
   
2. Approved Code of Practice for the Preparation of Material Safety Data Sheets.
   (http://www.workcover.com/documents/COPMSDS.pdf)
   
3. Approved Code of Practice for the Control of Workplace Hazardous Substances.
   (http://www.workcover.com/documents/COPHazSub.pdf)
   
4. Approved Code of Practice for the Labelling of Workplace Hazardous Substances. (http://www.workcover.com/documents/COPLabel.pdf)

Draft revision compiled in consultation between staff listed below:

J Cumming, Head, Occupational Health and Safety Unit
K Jaunutis, Occupational Health Nurse
A Walker, Technical Assistant, Occupational Health and Safety Unit
A Claridge, Library
P Douglas, Faculty of Social Sciences
T Benson, School of Nursing/Midwifery, Education Sturt Buildings
M Schlitz, Faculty of EHLT
R DiGiusto, Faculty of Science and Engineering
T MacKenzie, Informatics and Engineering
G Solly, SoCPES
L Spencer, Biological Sciences
M Froscio, School of Medicine
J Marshall, Biological Sciences