Chemical management procedure

Audience

Department-wide

Purpose

This procedure describes the process to manage health and safety risks associated with chemicals across their lifecycle at Department of Education (department) workplaces.

Overview

Effective chemical management is necessary to ensure the safety of people, property and the environment, as well as to comply with the Work Health and Safety (WHS) Regulation 2011 (Qld) (Part 7.1 – Hazardous Chemicals). The department adopts a lifecycle management approach to chemical safety, which includes pre-purchase hazard management, stock and risk management, safe use, disposal and review. A chemical management plan (CMP) and Chemwatch are used to support the lifecycle process, ensuring safe work practices, effective chemical management, and compliance with regulations.

Responsibilities

Employees

• participate in annual local chemical hazard induction (induction) and complete required role-specific training as identified by this procedure
• select the least hazardous chemical for the job and adhere to purchasing restrictions on prohibited chemicals, carcinogens, and substances requiring health monitoring
• manage the risks of harm to people, property and the environment throughout all stages of the chemical lifecycle
• report hazards, incidents and near misses to their supervisor, and record and manage them in line with the Health, Safety and Wellbeing (HSW) incident management procedure.

Employees with assigned chemical management plan (CMP) roles

• complete and record assigned CMP actions
• communicate relevant outcomes as required by the workplace/this procedure.

All contractors including public-private partnership (PPP) schools

• provide their nominated workplace contact with a hazardous chemical register for chemicals stored on site for more than five days and advise when these are removed, ensuring only operational quantities are stored
• report hazards, incidents, near misses or concerns immediately to your nominated workplace contact.

P&Cs, volunteers and pre-service teachers

• obtain written approval from the Principal/Manager to bring chemicals onsite
• follow local workplace safety and emergency procedures and instructions
• report hazards and incidents immediately to the nominated workplace contact.

Supervisors/Line managers

In their area of responsibility ensure:

• employees using or managing chemicals receive local induction, training and information (DoE employees only) that addresses specific chemical hazard, emergency management and local processes used to comply with this procedure
• CMP actions are completed annually
• appropriate chemical storage, handling and emergency equipment is available, accessible and maintained
• access to chemical delivery, storage and work areas is restricted to authorised employees only.

Principals/Managers of business units

• collaborate with staff to review and renew the annual workplace CMP (DoE employees only) to ensure the effective ongoing management of chemical risks on site
• provide adequate resources to support the lifecycle management of chemicals in the workplace e.g. time, budget, preventative/corrective controls, training and information
• ensure an up-to-date site hazardous chemical register is readily accessible and that leadership teams have the capability to access SDS electronically e.g. via Chemwatch or by hard copy for compliance and emergency response
• verify emergency systems and equipment, first aid and incident reporting and response processes are in place and are maintained, and that employees know how to implement them
• make contractors and others aware of any chemical hazards and required management practices in line with the site-specific induction process described in the HSWMS Leadership manual (DoE employees only)
• select and use an environmentally sensitive pest management approach that presents the least hazard to people, property and the environment including consideration of the engagement of licenced contractors for advice and/or pest management services or activities
• ensure records required by this procedure are maintained, kept current and accessible in line with local departmental and/or legislated record keeping processes.

Health and Safety Advisors/Workplace Health and Safety Coordinators (where appointed)

• support the Principal/Manager to verify implementation of this procedure
• support employees to manage the risks of harm to people, property and the environment across the lifecycle management of chemicals.

Local Health, safety and wellbeing (HSW) Committee/Forum

• monitor and support continuous chemical management improvement through quarterly CMP review and progress tracking.

School Supervisors

• support the Principal/Manager to make performance improvement when needed.

Directors, Regional Directors

• ensure principals and managers identify chemical hazards and manage risks in line with department's procedures and legislation.

Process

Process tasks may be undertaken by a variety of roles in school and corporate environments depending on the size of the workplace, the local division of tasks and the type and quantity of chemicals held on site. Workplaces are to determine the most appropriate person to conduct tasks in the process. Use the chemical management plan to identify and document this. Refer to Chemical management system flowchart for an overview of the chemical management system.

Training

Annual chemical hazard induction

All employees are to complete a local induction on commencement of duties and annual refresher thereafter in locations where workplace chemicals are present. Local induction is to include:

• hazard identification and management strategies
• work processes used to complete chemical management actions.

Role specific training

Employees in specific roles must complete additional training to ensure safe chemical use and management. Mandatory training applies to employees who:

• use workplace chemicals in the course of their work, or
• are assigned a role on the site's chemical management plan (CMP), or
• supervise/line manage those who use and/or manage workplace chemicals.

These specified employees are to complete:

• the chemical management online course (DoE employees only):
  • within 3 months of commencement (and prior to first use or management of chemicals), and
  • with every 3 years thereafter as refresher training.
• additional role-specific training including but not limited to:
  • obtaining any required regulatory permits, authorities and licences (legal authorities) before purchasing and/or using regulated chemicals
  • Chemwatch eLearning as relevant to assigned CMP role
  • any chemical training identified in their annual performance and development plan as necessary for safe chemical use and management.

Supervisors/line managers are to support employees to identify and complete required and role-specific chemical training as part of the employees annual performance and development (DoE employees only) process.

It is recommended Principals/Managers complete the chemical management online course to enhance their understanding of chemical management practices and support fulfilment of their duties to manage chemical risk.

Principals/managers are to ensure:

• all persons in the workplace receive annual induction where workplace chemicals are present on site
• all employees have completed relevant role specific training:
  • where training records are not maintained within the department's training completion SharePoint, ensure digital records of training are maintained locally:
    • Content Manager (for all central office and regional office employees)
    • the school's G:\Data\Admin folder (for all school-based employees).

Implement the chemical management system

1. Chemical management plan (CMP)

Principals/managers of business units are to prepare and maintain an annual chemical management plan for the workplace to coordinate chemical management activities for the site and is to include:

• assigning CMP roles in consultation with employees and communicating CMP requirements
• reviewing and renewing the CMP at the start of each year
• sharing the approved CMP with assigned CMP roles
• making the CMP readily available in the workplace, for example, via the HSW noticeboard/committee minutes and through local induction
• retaining a record of the CMP, for example in MyHR WHS with HSW committee minutes.

The local HSW Committee/Forum is to review CMP progress as a standing agenda item at each quarterly HSW Committee/forum. This is to include:

• ensuring assigned roles remain current and associated tasks are progressing
• recording the review and required actions in the HSW Committee meeting minutes actions register.

Safety Data Sheets (SDS) and hazardous chemical register

All workplaces are required under WHS Regulations (2011) to maintain a current and accessible hazardous chemical register that includes manufacturer (vendor) SDS:

• SDS and the hazardous chemical register are to be maintained in Chemwatch. Use of Chemwatch is mandatory
• SDS must be Australian vendor SDS, less than 5 years old and be in Globally Harmonised System (GHS) format.

Principals/managers of business units:

• determine, in consultation with relevant employees, if SDS and the hazardous chemical register are to be made available and readily accessible in Chemwatch and/or as hard copies (exported from Chemwatch). Record this mode of access on your site's CMP
• ensure a local system is in place to update and maintain currency of SDS and registers where records are exported from Chemwatch and/or held in hard copy
• ensure:
  • employees know how to access SDS and the register in the workplace via local induction
  • leadership teams have the capability to access Chemwatch/hard copy SDS for compliance and emergency response e.g. for the location of stored chemicals, to access SDS for first aid response
• verify annual stocktake is completed and the information used to update the Chemwatch manifest to maintain the accuracy, currency and availability of SDS and the register.

2. Pre-purchase hazard management

Pre-purchase risk assessment

Employees, P&Cs, volunteers and pre-service teachers:

• obtain the vendor SDS from the supplier/Chemwatch before purchase of chemicals and review the hazards and recommended controls associated with the chemical(s)
• complete the pre-purchase chemical risk assessment template using the SDS information. Apply the hierarchy of controls to:
  • confirm the need for the chemical (elimination)
  • assess whether a less hazardous alternative chemical is available and can be used instead (substitution)
  • determine whether employees can store, handle, use and dispose of the chemical safely (isolation, engineering, administration)
  • ensure proper storage facilities and disposal processes are available for the chemical
• do not purchase, introduce, store or use a chemical if:
  • a current vendor SDS cannot been obtained
  • the hazards cannot be safely managed
  • it is prohibited, a carcinogen, or is a WHS Regulation 2011 (Qld), Schedule 14 substance that is used in a way that requires health surveillance e.g. in a process that generates risk of exposure to dust, fumes or contamination, or a legislated process for example, lead risk work, respirable silica exposure.
• record outcomes in the template and submit the pre-purchase chemical risk assessment to the assigned CMP role for approval.

Pre-purchase chemical risk assessment approval

The assigned CMP role must approve or reject the pre-purchase chemical risk assessment as per the template. Approval requires confirmation the chemical is required, and its hazards can be safely managed in the workplace:

• record and make the approved risk assessment readily accessible as a file attachment to the chemical in the Chemwatch manifest.

Where approved, identified employees must obtain any required legal authorities prior to purchase for example, end user declarations for chemicals of security concern (CSC), security permits and training for security sensitive ammonium nitrate (SSAN), occupational verification for Schedule 7 (S7) poisons, radiation sources, regulated agricultural chemical distribution (ACDC) licencing and pest management competencies.

Re-purchase of chemicals

Employees using chemicals:

• access, review and update (where necessary) the corresponding pre-purchase chemical risk assessment to verify its continued safe management and use
• are not required to seek reapproval if an existing assessment remains in date and chemical hazards can continue to be managed safely
• formally review pre-purchase chemical risk assessments every 5 years, or sooner if the hazards change, the way the chemical is used changes, the SDS is reissued or if an incident occurs.

3. Stock management

Receiving chemicals and safe storage

Assigned CMP roles:

• receive, store and manage chemicals:
  • record date of receipt on the chemical container (do not obscure label information)
  • store in the location(s) specified in the pre-purchase risk assessment.
    • store all chemicals according to incompatibility requirements in the product's vendor SDS
    • apply separation and segregation distances to dangerous goods
    • consider the use of secondary containment and/or bunding to manage spill risks.
• update the Chemwatch manifest:
  • add the current vendor SDS, current and maximum stock volumes
  • record a copy of any required legal authorities as a file attachment to the chemical
  • ensure any corresponding hard copy documents are updated and readily accessible across the workplace.

Supervisors/managers are to ensure storage of chemicals is minimised to meet operational needs to reduce risks associated with excessive and/or long-term storage and disposal costs.

Consumer (domestic) chemicals

Employees are to purchase commercial chemicals for work purposes wherever practicable. Where not practicable and consumer chemicals are required:

• obtain the SDS (where available), complete a pre-purchase risk assessment, obtain approval for purchase and manage according to the pre-purchase chemical risk assessment and label
• store in original container and use only according to label directions
• use in quantities and manner consistent with normal household/office use and in a way that is incidental to the nature of the work carried out (i.e. use occurs in a minor or occasional way)
• when used beyond normal household/office use, or in a way that is not incidental to work, or if transferred to other containers, manage the chemical in Chemwatch as a workplace chemical as prescribed by this procedure.

Hazardous chemical register currency and safe storage

Assigned CMP roles are to use the Chemwatch manifest (stock list) to:

• verify the hazardous chemical register is accurate, updated and maintained through annual stocktake
• confirm chemicals are stored according to their SDS incompatibility requirements using the Chemwatch incompatibility report function
• conduct, review and action Chemwatch placard information in collaboration with their supervisor/line manager, including to:
  • install inner and outer placards where dangerous goods exceed minor storage quantities
  • remove placarding when it is no longer required.
• display safety signage on all designated chemical stores to notify of specific chemical hazards
• advise principals/managers when manifest quantities approach or exceed prescribed manifest quantity workplace (MQW) limits.

Principals/managers of business units:

• ensure employees know how to locate, access and interpret the hazardous chemical register
• provide information to the Health and Safety Regulator where dangerous goods exceed prescribed MQW limits and ensure MQW information is maintained or removed if no longer applicable.

Chemicals requiring legal authority

Employees:

• comply with SDS and legal authorities when using regulated chemicals including required record keeping
• access current information on the safe, responsible and effective use of registered agricultural and veterinary (AgVet) chemicals 
• supervise students directly when chemicals requiring legal authority are used during curriculum activities, and adhere to any authority conditions for example, age restrictions for use
• where undertaking operational pest management or commercial activities under legislation, or teaching pest management skills in the curriculum, obtain a pest management competency as required by the Medicines and Poisons (Pest Management Regulation) 2021 (Qld).

Supervisors/line managers are to ensure authority requirements are implemented and maintain record keeping conditions specified by legal authorities including registers, training records, secure storage, records of use/application, authorised access and document retention.

Principals/managers of business units:

• monitor regulated chemical storage, use, security and management practices to ensure compliance with licensing requirements
• consult with relevant employees to establish and document local measures to prevent diversion of CSC, S7 poisons, radiation sources and SSAN for illicit purposes
• review regulated chemical security controls annually or following an incident. Report theft of:
  • CSC and SSAN to the Queensland Police Service
  • radiation sources and S7 poisons to Queensland Health.

4. Risk assessment

Supervisors/line managers are to ensure employees receive instruction about conducting and interpreting chemical risk assessments through local annual induction.

Assigned CMP roles in consultation with employees are to review the Chemwatch manifest and identify Chemwatch hazard categories to determine risk assessment requirements and implement the following minimum risk management practices in consultation with other chemical users:

• grey (0), blue (1) or yellow (2) manifest hazard category chemicals and consumer chemicals:
  • manage according to the pre-purchase chemical risk assessment, label directions, SDS and any additional supporting information for example, SOPs, storage guidance, experimental methods, or laboratory reference manuals
  • manage as for ‘orange (3)’ and ‘red (4)’ chemicals where there is uncertainty about the degree of risk, or the chemical is held in placard or MQW quantities.
• Orange (3) and red (4) manifest hazard category chemicals:
  • complete Chemwatch risk assessments in both ‘health exposure’ and ‘storage’ assessment tabs by reviewing, selecting or adding controls in line with the scale and type of use, engineering controls available in the workplace and available personal protective equipment
    • document site/activity specific hazards, student considerations, training requirements and physical hazards not addressed by Chemwatch i.e. ensure safe work practices or existing risk management processes are recorded or referenced in the 'safe operating procedure' field on the assessment.
  • reconsider controls for activities where the post-assessment risk level is rated extreme (level 4) or high (level 3):
    • where extreme (level 4) risks are present, do not proceed until higher order controls or process modifications have been adopted to reduce the risk level
    • where the risk level on the approved assessment is high (level 3), complete and make readily available a safe operating procedure for the activity.
  • where these chemicals are used in curriculum activities, reference the health exposure chemical risk assessment and manage risks as per the Managing risks in school curriculum activities procedure
  • print the assessments and make them available near where chemicals are used (health exposure) or stored (storage)
  • review and revise control measures when circumstances change, controls are ineffective, or an incident occurs, and formally at least every five (5) years.

Supervisors/line managers/assigned CMP roles:

• review and approve risk assessments
• ensure all staff are aware of storage risk assessments for placarded/MQW storage.

Principals/managers of business units are to ensure all control measures identified by risk assessment, installed as part of the built environment or required by manufacturer specifications are resourced and maintained including for example:

• safe operation and servicing of local exhaust ventilation, emergency eye wash/showers and gas supply systems in line with the Service Maintenance Program (DoE employees only), Australian Standards (DoE employees only) and/or manufacturer instructions
• dedicated chemical stores and associated passive or mechanical ventilation
• the provision and safe use of personal protective equipment (PPE).

Emergency management and response

Supervisors/Line managers are to ensure the provision of relevant instruction, information and training to employees regarding the availability, use, storage and maintenance of:

• first aid, fire and emergency equipment
• secondary containment (spill trays) and bunded storage systems
• spill kits appropriate to the chemicals stored and used
• spill, fire and emergency response
• safe disposal practices including isolation of hazardous chemicals from stormwater systems
• emergency preparedness and safety signage required by legislation or risk assessment
• personal protective equipment (PPE).

Principals/managers of business units:

• use risk assessment outcomes to determine chemical emergency response requirements and document them in the workplace’s Emergency Response Plan (DoE employees only)
• communicate emergency response requirements to employees and others at the workplace and to people in control of adjacent premises where there is potential exposure during an emergency.

5. Safe chemical use

Implement identified risk controls

Employees:

• complete identified role-specific training before working with chemicals
• review the SDS, approved chemical risk assessments and safe work procedures before use
• implement identified control measures and apply safe work practices
• monitor the effectiveness of controls during use and update risk assessments where required
• visually inspect storage areas, chemical labels, containers and emergency equipment as part of daily activities and manage/report issues immediately when identified
  • record hazards, incidents and near misses as per the HSW Incident management procedure.
• replenish first aid and spill kit contents a soon as possible after use.

Assigned CMP roles are to conduct documented safety inspections of chemical stores, work areas and emergency equipment every three to six months (frequency determined on assessment of risk) to maintain a safe workplace.

Supervisors/line managers are to ensure hazards are remediated, safety inspection outcomes are actioned and incidents managed in line with the HSW Incident management procedure.

Principals/Managers of business units:

• ensure all non-departmental entities including Public-Private Partnerships (PPP) apply the following risk controls when using chemicals on department sites:
  • provide a complete list of chemicals used for contracted works, their SDS and associated risk management information when stored on site for more than 5 days for inclusion in the workplace hazardous chemical register and advise the workplace when listed chemicals are removed from site
  • store minimal operational quantities of chemicals in agreed secure storage locations according to their SDS
  • report chemical hazards and incidents immediately to their nominated workplace contact.

Health and Safety Advisors/Workplace Health and Safety Coordinators are to support safe work practices by:

• liaising with assigned CMP roles to facilitate, enable or note completion of CMP tasks
• ensuring completion of the 'specific risks - chemicals section' in the annual safety assessment (ASA) and supporting completion of any actions noted in the ASA action plan
• supporting safety inspections of chemical stores, work areas and emergency equipment.

Chemical labelling

Employees, contractors, P&Cs, volunteers and pre-service teachers are to comply with labelling requirements for all chemical containers as specified in Schedule 9 (Part 3) of the WHS Regulation 2011 (Qld):

• label all chemical containers (including waste) with compliant GHS labels for example, generated from Chemwatch
  • ensure label integrity is maintained, with all text in English, legible and clearly visible so their hazards are identifiable.
• retain chemicals in original containers where possible to ensure accurate labelling. Where chemicals are decanted, diluted or transferred compatible containers must be used (refer to SDS) and have compliant GHS labels.

Supervisors/line managers are to ensure pipework containing hazardous chemicals is appropriately labelled or signed. 

Safe storage

Employees using chemicals are to ensure that:

• chemicals are always stored according to incompatibility requirements in the vendor SDS
• the Chemwatch incompatibility report is used to verify storage in an area is compatible.

Whenever practicable, store chemicals:

• in dedicated/purpose built, secure, ventilated chemical stores away from high traffic areas and ignition sources
• in areas that do not share air systems with occupied spaces
• in a way that will not impede safe transit, safe work or emergency access or egress.

6. Disposal and review

Disposal

Employees/assigned CMP roles:

• package, label and store chemical waste in a suitable compatible container in accordance with the SDS:
  • clearly identify the contents and date, and mark as ‘waste for disposal’
  • store waste according to its hazardous nature pending collection or in house disposal
  • label unknown substance as "UNKNOWN - for disposal only’ and arrange priority licenced disposal
  • where chemicals are managed under legal authorities, dispose of the chemical as per the conditions of the authority.
• refer to the chemical's pre-purchase risk assessment for the required disposal method. Continue to manage chemicals for disposal in line with this procedure until disposal is complete
• maintain disposal records as required by legislation, legal authorities and/or the department's record retention and disposal requirements (DoE employees only), whichever is the longer.

Supervisors/Line managers and assigned CMP roles are to ensure timely and appropriate in-house or licenced disposal of chemical waste occurs in accordance with SDS, labelling and risk assessment requirements.

Principals/managers of business units are to ensure disposal is fully resourced and waste chemicals do not accumulate in the workplace.

Review – Annual stocktake

Principals/managers of business units/supervisors/line managers are to allocate sufficient time and resources to ensure annual chemical stocktake is completed and Chemwatch manifest updates for the workplace occur.

Employees/assigned CMP roles:

• conduct an annual chemical stocktake of all chemicals on site. Where required, conduct stocktake more frequently for example for security sensitive chemicals or when high volume purchasing occurs
• use the stocktake information to update the Chemwatch manifest to ensure the hazardous chemical register remains current. This includes verifying vendor SDS are available and current and maximum volumes are accurate to enable Chemwatch placard calculations.

Supervisors/line managers:

• verify annual stocktakes are completed and the Chemwatch manifest is updated annually in their area of responsibility
• review the manifest annually to confirm chemical types, quantities, and usage remain appropriate, and that overall chemical storage risk is minimised as low as reasonably practicable
• check placard and MQW signage and update/remove signage where applicable.

Review – Governance and compliance monitoring

Monitoring and review of chemical safety management is to occur to ensure chemical risk is managed and this procedure is fully embedded in practice. The responsible roles and methods of assurance are outlined in the table below.

Record management

Employees are to keep and maintain records relating to chemical management on site, including but not limited to:

• chemical management plan
• pre-purchase chemical and Chemwatch health exposure and storage risk assessments
• hazardous chemical register including vendor SDS
• safe operating procedures
• disposal of regulated waste
• records as required by legal authorities
• training records
• ASA and action plan
• HSW Committee minutes.

Definitions

Legislation

• Work Health and Safety Act 2011 (Qld) 
• Work Health and Safety Regulation 2011 (Qld) 
• Environmental Protection Regulation 2008 (Qld) 
• Medicines and Poisons (Poisons and Prohibited Substances) Regulation 2021 
• Medicines and Poisons (Pest Management Activities) Regulation 2021 
• Agricultural Chemicals Distribution Control Act 1966 (Qld) 
• Biosecurity Act 2014 (Qld) 
• Radiation Safety Act 1999 (Qld) 

Delegations/Authorisations

• Nil

Other resources

• Health, safety and wellbeing incident management procedure 
• Managing first aid in the workplace procedure 
• Managing risks in school curriculum activities procedure 
• Disaster and emergency management procedure 
• Chemical management guideline (DoE employees only) 
• Key messages for Principals - Chemical management  (DoE employees only) 
• Chemical management plan  
• Pre-purchase chemical risk assessment 
• Prohibited and high risk chemicals in departmental workplaces 
• Chemical safe operating procedure template 
• Chemwatch modules (DoE employees only) 
• Chemical management online course (DoE employees only) 
• HSW Committee agenda and minutes (DoE employees only) 

Superseded versions

Previous seven years shown. Minor version updates not included.

1.0 Chemical management procedure