Hazardous Substances

14 December 2017

The new Health and Safety at Work (Hazardous Substances) Regulations 2017 are now in effect and business are expected to be compliant. The changes for some maybe minor and may not take much to become compliant.

According to WorkSafe, some 150, 000 businesses in some way handle hazardous substance as part of their business and they expected to know what substances they are working with, the risks they pose, and how to manage those risks.


Some of the key changes include:

Inventory:

Create and maintain an inventory of all hazardous substances and hazardous waste used, handled, manufactured or stored in the workplace, including hazardous waste.

This excludes substances used as a consumer would in quantities, and a manner, consistent with domestic use.

Also Transit Depots and Laboratories are exempt but are bound by other requirements to manage these substances.

Safety Data Sheets:

Safety Data Sheets (SDS) contain important information that workers need to know when working with hazardous substances regardless of the quantities. However there are exceptions.

The supplier must provide a HSNO compliant SDS and the PCBU also has a duty to ensure that one is supplied and that they are readily accessible.

Readily accessible means, accessible without difficulty. So how difficult would it be to obtain an SDS in an emergency. Consider

• distance,

• time,

• if it is electronic what happens with power failure,

• how the documents are ordered or filed

Risk Management:

Hazardous substance are a risk and like any risk they need to be managed.

First you need to identify what substance you have, use and in what quantities, by creating an inventory.

Secondly, you will need to assess the risks taking into account, but not limited to:

• The hazardous substance. The SDS will be an important document to consult,

• Quantities,

• Storage,

• Compatibility with other substances,

• How the substance is used,

• The people using the substance (Training, information and supervision),

• Exposure,

• The environment it is used in,

• Waste and disposal

Thirdly, once the risks have been assessed, implement controls.

Use the hierarchy of controls:

• Eliminate

• Substitute

• Isolate

• Engineering

• Administration and training,

• Personal Protective Equipment

Other than elimination, it may take a combination of different control methods to reduce the risks.

Once the controls have been implemented, you should monitor and review the risks to ensure that the controls remain effective and other risks have not developed.

Information, instruction, training and supervision:

Workers need to know what hazardous substances they are handling or using and they must demonstrate knowledge of safe handling and use through knowledge and practical experience.

Workers also require supervision to ensure that correct processes are used.

This is like any information and training in the workplace, you need to assure yourself that workers know and not assume that they do.

Emergency preparation:

You should already have emergency response processes in place for dealing with hazardous substances, if not it is essential that this a priority.

Emergency response should also be considered in your risk assessment.

You need to ensure that:

• Workers are informed and trained and understand the emergency response

• Workers know where to find, access and interpret the SDS,

• All storage containers are appropriately labelled and can be read,

• Have appropriate spill kits accessible and stocked. There are specific spill kits for different types of substances as some of the materials in the kits may react with the spilled substance,

• Test your emergency response

• If have large quantities of hazardous substances will be required to have an Emergency Reponses Plan. Use the MBIE Hazardous Substances Calculator

Labelling containers of hazardous substances (including hazardous waste):

Manufacturers and suppliers are required to correctly label the hazardous substance they sell or supply. The purchaser or recipient must maintain that label.

A common practice of decanting or transferring a hazardous substance from larger container to a smaller one or one that is easier to use now required to have a legible label affixed to the new container.

There are also new requirements for making sure that hazardous substance in transportable containers, stationary tanks and process containers are appropriately labelled, including hazardous waste.

Signs:

Signage is an important method of communicating that hazardous substances are on site. Though there are specific requirement of when signage is mandatory it is good practice.

The MBIE Hazardous Substances Calculator can assist to determine whether you have a mandatory requirement to erect signage.

Storage:

Storage of hazardous substance would have been considered in your risk assessment. Some substance cannot be stored with or near other substances as they may react with each other or an ignition source. The SDS will provide this information.

Some hazardous substances require specific storage requirements such as flammable substance may be kept in a metal cabinet. If there are large quantities they may require a dangerous good store.

There may be requirements for a location compliance certification. Again depending on quantities.

Storage should secure hazardous substances from incidental use, especially if a certified hander is required.


Tracking:

Some hazardous substances require tracking. The MBIE Hazardous Substances Calculator can assist to determine these requirements.

The PCBU who controls or manages a site where a tracked substance is used or stored is required to keep a record and it is to be included in any transfer or disposal of such substance.

This is just an overview of some of the changes in effect.

The WorkSafe website is a great source of information regarding the new regulations visit https://worksafe.govt.nz/topic-and-industry/hazardous-substances/


THE WORKBOOK- WORKING SAFELY WITH HAZARDOUS SUBSTANCES


Chris Webb, Health and Safety Manager 03 456 1808 021 225 8408 chris@osea.org.nz