Managing the risks of storing and handling dangerous goods at the snowfields
Guidance for duty holders on how to identify hazards and control the risks associated with storing and handling dangerous goods at snowfields.
What are dangerous goods?
Dangerous goods are substances capable of causing harm to people and property because of their hazardous properties. They may be corrosive, flammable, combustible, explosive, oxidising or water reactive, or have other hazardous properties.
Dangerous goods can cause explosions or fires, serious injury, death and large-scale damage.
Dangerous goods at the snowfields
Dangerous goods found at the snowfields include:
- unleaded petrol (ULP) and diesel used as fuel for plant and vehicles
- liquefied petroleum gas (LPG) used for heating
- anhydrous ammonia used for snowmaking
- sodium hypochlorite used for water treatment
These dangerous goods are commonly stored in bulk in above or below ground tanks.
Duties of occupiers
The Dangerous Goods (Storage and Handling) Regulations 2022 (DG (S&H) Regulations) set out the legal duties for occupiers of premises where dangerous goods are stored or handled.
Under the Dangerous Goods Act 1985 (DG Act), an occupier is a person who:
- is the owner of the premises
- exercises control at the premises under a mortgage, lease or franchise, or
- is normally or occasionally in charge of the premises or exercises control or supervision at the premises as a manager or employee or in any other capacity
Occupiers of premises where dangerous goods are stored and handled have a range of duties, including duties in relation to consultation, information and training, hazard identification and risk control.
The unique environment and manner in which snowfields are organised and operated may result in there being several occupiers with duties under the DG (S&H) Regulations. The relationships between these duty holders may be complex and interconnected, involving leases and contracting agreements. The snow season management plan should clearly identify all occupiers of premises where dangerous goods are stored or handled and outline their roles and responsibilities. This will ensure a systematic and holistic risk management approach.
If a duty under the DG (S&H) Regulations is placed on more than one person or class of person, the duty must be undertaken by each person or each person in that class only in relation to those matters in respect of which the person has management or control, whether or not any other person is also responsible for undertaking the duty. At the snowfields, resort management, ski lift operators and suppliers of LPG will all have duties under the DG (S&H) Regulations. A clear snow season management plan and ongoing communication between duty holders will help to ensure dangerous goods are stored and handled appropriately.
The Code of practice for storage and handling of dangerous goods provides practical information on how to control the risk from storing and handling dangerous goods.
Consultation, information and training
Occupiers of premises where dangerous goods are stored and handled must, so far is a reasonably practicable, consult with their workers whose health and safety is likely to be affected by the dangerous goods, and with any health and safety representatives (HSRs) regarding:
- induction, training, information provision, hazard identification and risk control, and
- any proposed alteration to structures, plant, processes or systems of work that are likely to increase the risk to the workers
Occupiers must also ensure that all persons, including HSRs, involved in the storage and handling of dangerous goods are provided with induction, information, training and supervision that is:
- delivered in a language or manner all workers can understand; and
- relevant to the tasks undertaken by the workers and the risks associated with those tasks
The induction, information and training must include instruction about the:
- hazards posed by the dangerous goods, the properties of the dangerous goods, and the processes used for the identification and control of the risks associated with the tasks workers will be doing
- purpose, use and maintenance of the control measures for those risks
- systems of work in place and the ways in which workers must conduct themselves to ensure safe storage and handling of dangerous goods
- operation of the emergency plan for the premises and any procedures and equipment that may be required for use in the event of an emergency
- proper use and fitting of personal protective equipment (PPE)
Hazard identification
Occupiers must identify any hazards associated with storing and handling dangerous goods at the premises, having regard to what the occupier knows or ought reasonably to know about the hazard.
When identifying hazards, occupiers must have regard to:
- the inherent hazardous properties of the dangerous goods being stored and handled
- the chemical and physical properties of the dangerous goods
- any manufacturing and transport processes at the premises involving dangerous goods, such as snowmaking with anhydrous ammonia
- the temperatures and pressures the dangerous goods are subjected to during manufacturing and transport processes
- any structures, plant, systems of work and activities used in the storage and handling of dangerous goods at the premises
- the physical location and arrangement of areas, structures and plant used for the storage and handling of dangerous goods at the premises
- structures, plant, systems of work and activities not used in the storage and handling of dangerous goods, but that could interact with the dangerous goods
- the chemical and physical reaction between dangerous goods and other substances and articles the dangerous goods may come into contact with
- types and characteristics of incidents associated with dangerous goods
The Dangerous goods in the snowfields risk control checklist can assist occupiers to ensure appropriate hazard identification and risk control activities have been undertaken in both the green and white seasons.
More information on hazard identification can be found in the Code of practice for the storage and handling of dangerous goods.
Controlling risks
Once the hazards associated with the storage and handling of dangerous goods have been identified, occupiers must implement control measures to manage those risks. Control measures for dangerous goods commonly found at the snowfields may include:
- displaying appropriate placards and signage
- ensuring manifests and registers are kept and maintained
- ensuring segregation of different types of dangerous goods
- developing and maintaining an emergency plan
- ensuring appropriate equipment is in place in case of spills
- ensuring appropriate fire protection systems and impact protection devices are installed
- Placards and signage
Occupiers must display 'HAZCHEM' outer warning placards at premises if the quantities of dangerous goods stored and handled exceed the 'Placarding Quantity' in Schedule 2 of the DG (S&H) Regulations.
If dangerous goods are stored in bulk containers, placards must be located on or adjacent to each container.
Placards are also required for packaged dangerous goods if the amount being stored exceeds the 'Placarding Quantity' in Schedule 2 of the DG (S&H) Regulations. Placards for packaged dangerous goods must be clearly legible and displayed:
- at the entrance of any building where the dangerous goods are stored; and
- at the entrance to each room where the dangerous goods are stored; and
- adjacent to any storage area that is external to a building
Placards may be displayed in different locations if an agreement is reached with the relevant fire authority (Fire Rescue Victoria (FRV) or Country Fire Authority (CFA)). This agreement must be recorded in writing and kept by the occupier.
Additional warning signs may also be required, depending on the type of dangerous goods being stored. Further information on warning signs required when storing flammable and combustible liquids can be found in AS 1940:2017 The storage and handling of flammable and combustible liquids.
- Manifests
A manifest provides information about the quantity, type and location of dangerous goods stored and handled at the premises.
A manifest must be prepared if the quantity of dangerous goods stored or handled exceeds the ‘Manifest Quantity’ in Schedule 2 of the DG (S&H) Regulations. The manifest must be located near the outer warning placard at the front of the premises that is easily accessible by emergency services authority. The manifest should be kept in a weatherproof holder. If required, the manifest can be placed in a different location with the agreement of relevant fire authority (FRV/CFA).
The occupier must also notify WorkSafe that dangerous goods in excess of the manifest quantity are being stored and handled at the premises by completing a Dangerous goods storage and handling notification.
- Dangerous goods register
Occupiers are required to keep a register for dangerous goods stored and handled at the premises. A register is a list of the product names, locations and quantities of all dangerous goods being stored and handled, accompanied where required by the current Safety Data Sheet. The register must be located in an easily accessible location and kept up to date.
- Segregation of dangerous goods
Different types of dangerous goods may be incompatible with each other. Where incompatible dangerous goods are stored at the same premises, they need to be separated by distance and/or barriers.
More information on segregation of dangerous goods can be found in Code of practice for the storage and handling of dangerous goods.
- Emergency plans
Occupiers must develop, implement and maintain a written emergency plan if the quantity of dangerous goods stored or handled exceeds the 'Manifest Quantity' in Schedule 2 of the DG (S&H) Regs. The plan must reduce the risks associated with the emergency, so far as reasonably practicable.
The emergency plan must describe the location of the manifest and should clearly outline:
- the types of dangerous goods stored at the premises
- the activities being undertaken at the premises
- the areas where the activities involving dangerous goods are undertaken
- prohibited activities in the dangerous goods storage and handling area
Emergency plans must be reviewed by the relevant fire authority (FRV/CFA) and should be tested regularly, reviewed and revised prior to the start of each snow season. Occupiers must also communicate the emergency plan to workers, resort management, ski lift operators and any other persons who have management and control of adjacent premises, if they may be exposed to a risk as a result of a dangerous goods emergency.
- Fire protection
Fire protection must be provided for any site or building where flammable or combustible liquids are stored or handled in quantities over minor storage. Fire protection may include portable or fixed fire extinguishers. Minor storage is defined in table 2.1 of AS 1940-2017 The storage and handling of flammable and combustible liquids.
AS 1940-2017 The storage and handling of flammable and combustible liquids
Where dangerous goods at the premises exceed the relevant ‘Fire Protection Quantity’, fire protection systems must be designed and installed in consultation with the relevant fire authority (FRV/CFA), and firefighting equipment needs to be maintained in accordance with AS 1851-2012 Routine service of fire protections systems and equipment. When installing fire protection systems in the snowfields, consider how to best protect the equipment from corrosion and freezing in extreme weather conditions.
AS 1851-2012 Routine service of fire protections systems and equipment
- Impact Protection
Occupiers must ensure that dangerous goods and any structure and plant associated with their storage and handling (eg bulk tanks) are protected against damage from impact with vehicles and mobile plant such as snow mobiles or over snow vehicles.
The most effective way to protect against damage by impact is to locate the dangerous goods, structures and plant away from high traffic areas and prevent vehicle access to areas where the dangerous goods, structures and plant are located. Where vehicles are required to come close to the dangerous goods, structures or plant, impact protection devices (eg railings, bollards or stanchions) should be installed, where it is reasonably practicable to do so.
- Spill containment
Occupiers must ensure that in each area at the premises where dangerous goods are stored or handled, provision is made for spill containment. Provision for spill containment must seek to eliminate or reduce the risk of a spill and be able to contain, within the premises, the dangerous goods that have been spilled or leaked and any solid or liquid effluent arising from an incident.
In the case of dangerous goods contained in a tank, the spill containment for that tank must not be shared with any other dangerous goods or other substances that are not compatible with the dangerous goods in the tank.
For packaged dangerous goods, spill containment should be provided for the volume of the largest package plus 25 per cent of the storage capacity.
Bunding is a specified system for containing dangerous goods spillages in storage and handling facilities. Bunding is the preferred risk control system for above ground bulk storage installations. Bunds located outdoors should be constructed with additional capacity to deal with rainwater and run off and with a secure system for the removal of that water.
If bulk storage (over 500 litres) in tanks is utilised, these tanks may be self-bunded however if they are not, the bunds are required to contain at least 110% of the largest tank or 25% capacity of all tanks, whichever is greater.
- Personal Protective Equipment
Occupiers have a duty to provide workers who handle and store dangerous goods and hazardous substances with appropriate PPE, such as:
- gloves
- high-visibility clothing
- protective eyewear
- goggles
- respirators
- face masks
- aprons
- safety footwear
- hard hats
- safety harnesses
- body suits
- ear muffs and earplugs
- sunscreen
PPE limits exposure to the harmful effects of a hazard only if workers wear and use the PPE correctly. Occupiers should refer to the Safety Data Sheet for each dangerous good to ensure the recommended PPE is provided to workers. The PPE provided to workers needs to be appropriate for the environmental conditions. Occupiers need to have appropriate PPE available for both the green and white seasons. PPE should be used in combination with, and to increase the effectiveness of, higher level control measures. PPE should not be used in place of safe systems of work or other practical control measures.
Anhydrous ammonia storage and handling
Anhydrous ammonia (UN 1005) is a compressed or liquefied gas classified as a dangerous good Class 2.3 subsidiary hazard Class 8 (toxic gas/ corrosive). In the snowfields anhydrous ammonia is used for artificial snowmaking.
Anhydrous ammonia is a colourless gas that has a strong smell, and is toxic, corrosive and explosive when heated. When stored as a liquid, storage containers exposed to heat may cause the ammonia to rapidly expand and explode.
Occupiers must ensure that plant, such as plant used in artificial snowmaking, is properly installed, fittings and valves are regularly inspected and maintained and that all workers have received training in the appropriate storage and handling of anhydrous ammonia and emergency response procedures.
Occupiers should refer to AS/NZS 2022-2003 Anhydrous ammonia - Storage and handling for specific guidance and requirements related to anhydrous ammonia.
Storage and handling of anhydrous ammonia packages
Anhydrous ammonia is found in the refrigeration systems of artificial snowmaking plant. Additional stores of anhydrous ammonia are typically packaged in 205 litre drums. Package stores such as these drums require impact protection, secure fencing and should be well ventilated to the atmosphere to reduce risk. Packages should be segregated from flammable or oxidising materials or not within 10 metres of a chlorine installation.
Where packages of anhydrous ammonia are opened, occupiers must provide PPE, such as:
- eye protection including face shield and googles
- safety footwear
- protective gloves
- coveralls
- gas filter respirator
- eye wash facilities complying with AS 4775-2007 Emergency eyewash and shower equipment
Occupiers need to ensure safe systems of work are in place for the refilling of anhydrous ammonia in artificial snowmaking plant.
Anhydrous ammonia gas detectors
Occupiers should ensure gas detectors are installed or use portable detectors in areas where anhydrous ammonia is stored and handled. Detectors should be positioned in areas where leaks have been determined as most likely to occur. Detectors should also be positioned outside the anhydrous ammonia plant room. Audible and visual alarms should be in-place to warn persons of a leak before entering the plant room. Alarm settings should be set based on the occupational airborne exposure standard for anhydrous ammonia.
Alarm settings should be set based on the occupational airborne exposure standard for anhydrous ammonia.
Suggested anhydrous ammonia alarm settings and responses
Stage | Concentration (PPM) | Location | Action | PPE |
|---|---|---|---|---|
1 | 25 | Inside plant room/roof space | Investigate leak by trained personnel | Full face mask respirator |
2 | 35 | Inside plant room/roof space | Emergency ventilation of plant room – investigate leak by trained personnel | Splash suit and self-contained breathing apparatus |
3 | 150 | Outside plant room/roof space | Site or Area evacuation – Emergency Services contacted | Fully encapsulated suit and self-contained breathing apparatus |
4 | 30,000 (20% LEL) | Inside plant room/roof space | Plant shutdown (electrical equipment off) | - |
Only trained personnel should investigate anhydrous ammonia leaks, wearing appropriate PPE that has been fit tested. If no trained personnel are on site, emergency services should be contacted.
Diesel and unleaded petrol storage and handling
Diesel and ULP are used at snowfields as fuel for vehicles and plant.
Any dispensing of fuel must occur in well ventilated areas only. Fuel bowsers need to be fitted with emergency shut-off devices which are readily accessible and clearly identified and labelled. Fuel dispensing equipment needs to comply and be tested to show compliance with AS/NZS 2229-2004 Fuel dispensing equipment for explosive atmospheres.
Fuel bowsers require impact protection to reduce the risk of fuel spillage and damage to electrical equipment in the bowser in the case of vehicle impact. The area surrounding fuel bowers need to be kept free of combustible materials and residues.
Fuel storage areas must have spill kits containing enough absorbent material, tools and equipment, including PPE and instructions for correct use of equipment. Spill kits need to be located within 15 metres of the storage area. Used spill kits are classified as dangerous goods and must be disposed appropriately of in accordance with the EPA guidelines.
Workers dispensing fuel must be provided with appropriate PPE, such as gloves and safety glasses, as outlined in the Safety Data Sheet.
Liquefied petroleum gas storage and handling
Liquefied Petroleum Gas (LP Gas) is a flammable gas classified as a dangerous good Class 2. It is commonly used at snowfields for catering and heating purposes. LP Gas can be stored in above ground bulk tanks or smaller portable cylinders. The management and control of bulk LP Gas storage is facilitated through specialist gas supply contractors such as ELGAS.
LP Gas cylinders, such as those used at the snowfields, must be inspected to ensure compliance with AS 2030.1 Gas Cylinders – general requirements and must have regulators and piping that complies with AS/NZS1596:2014 The Storage and handling of LP Gas. Cylinders should be stored upright and outdoors, restrained to prevent falling, protected from impact and at least two metres away from any buildings. If LP gas is required to be used indoors for temporary cooking purposes, only one cylinder of less than 25 litres should be used at a time.
Sodium hypochlorite storage and handling
Sodium hypochlorite, commonly known as bleach, is a liquid that is classified as a dangerous good Class 8 corrosive. In the snowfields, sodium hypochlorite is used in wastewater treatment plans where water for snow making and wastewater from the resort is treated.
Sodium hypochlorite can cause damage to the skin and eyes and upper respiratory tract. It may be stored in bulk tanks or in packages of various sizes.
Occupiers must ensure that plant, including plant used in water treatment, is properly installed, fittings and valves are regularly inspected and maintained and that all workers have received training in the appropriate storage and handling of sodium hypochlorite and emergency response procedures.
Storage and handling of sodium hypochlorite packages
Package stores for sodium hypochlorite require impact protection, secure fencing and should be well ventilated to the atmosphere to reduce risk. Packages must be segregated from incompatible substances such as acids by a distance of not less than 5 metres and in the event of a spill prevented from mixing with incompatible materials such as acids and ammonium salts.
Where packages of sodium hypochlorite are opened, occupiers must provide PPE, such as:
- eye protection including face shield and googles
- safety footwear
- protective gloves
- coveralls
- ventilation
- spill containment
- eye wash facilities complying with AS 4775-2007 Emergency eyewash and shower equipment
Storage of dangerous goods in bulk and underground tanks
Bulk storage of dangerous goods requires a container and pipework that has stable foundations and supports and is protected from corrosion. Any pipework or equipment connected to the container must also be installed so as to prevent excessive stress on the container, pipework and equipment.
The bulk container must be inspected at intervals that are sufficient to ensure the continued integrity and serviceability of the container. The results of the inspection must be recorded and retained, for as long as the container remains in service at the occupier’s premises. If you cease to be the occupier of the premises, the recorded inspection results must be delivered to the person who becomes the occupier.
Further information about inspecting above ground LPG tanks can be found in AS/NZS 3788:2006 Pressure equipment - In-service inspection.
Guidance on the design of different types of bulk tanks and attachments including pipework can be found in AS 3780-2008 The storage and handling of corrosive substances (Clauses 5.5 to 5.7 inclusive).
Guidance on static tank storage Class 3 flammable and combustible liquids can be found in AS 1940-2017 The storage and handling of flammable and combustible liquids (Clause 5.2).
Underground tanks pose risks to people and property due to the risk of:
- failure of the structure, usually due to corrosion, allowing the gradual escape of dangerous goods into the water table and soil, and
- spills from above-ground pipework and filling points. Dangerous goods stored in underground tanks can migrate through the water table and soil to present a risk to people and property a long way from the tanks
For example, flammable liquids and vapours can accumulate in pits or seep into building basements. There are many techniques available to monitor the integrity of underground tanks and detect leaks. They include inventory monitoring, sampling pits and sampling of ground water around the storage tank. Guidance on underground tank installations for petroleum products can be found in AS 4897-2008 The design, installation and operation of underground petroleum storage systems (sections 1 to 6 inclusive).
Emergency response
- Planning and training in dangerous goods emergency response
The occupier must ensure everybody (this includes all operators, contractors, employees of contractors, volunteers) involved with the storage and handling of dangerous goods at the premises has received training in the operation of the emergency plan for the premises and any procedures and equipment that may be required for use in the event of an emergency.
Emergency procedures should be developed as part of preseason (green season) planning in consultation with the relevant fire authority (FRV/CFA) and should include:
- how to identify an emergency associated with dangerous goods
- what to do in a dangerous goods emergency
- emergency communication procedures
- a warden structure defining responsibilities for coordination and implementation of emergency procedures such as evacuation procedures
Emergency practice drills for dangerous goods should be undertaken as required.
The occupier should provide as many people as required to assist in the safe running of the premises and to deal with a dangerous goods emergency situation. The engagement of suitably trained safety officers to be in attendance during the snow season is recommended. Safety officers are responsible for implementing emergency procedures and assurance of the site safety plan.
- Emergency spill procedures for dangerous goods
Systems for the clean-up of spills and disposal of waste or empty containers of dangerous goods should be developed prior to the start of each snow season.
Written procedures should be developed as part of the emergency management plan for handling spilled dangerous goods. These procedures should outline the requirement to clean up spilled liquid immediately using
Empty containers should be considered full and stored appropriately until they are cleaned and/or disposed of. Damaged or leaking containers should be separated and stored in a safe manner.
- Safety showers and eyewash facilities
Occupiers should provide readily accessible safety showers and eye wash facilities in areas where anhydrous ammonia is stored and handled, where ULP and diesel are stored in quantities exceeding 2000 litres, and in areas where packages of dangerous goods are opened.
Safety showers and eyewash facilities should be located on the same level as the hazard and be protected to prevent temperature extremes including freezing in the flushing fluid and the equipment’s operation. Safety showers and eyewashes should be identified with highly visible signage and tested regularly to ensure they deliver the required volume and flow. Consideration should be given to the effluent run off from a safety shower in the event it is used.
Safety showers and eyewash facilities need to comply with AS 4775-2007 Emergency eyewash and shower equipment
Security of dangerous goods
Dangerous goods must be secured against unauthorised access and tampering.
Occupiers must have procedures in place to ensure dangerous goods storage areas can only be accessed by authorised and trained workers.
Incident notification
All accidents involving dangerous goods must be reported to the nearest fire authority or police station, including an implosion, explosion, fire, escape, spillage or leakage or property damage.
Incidents that result in the death or serious injury of a person, or expose a person to a serious risk to their health and safety from imminent or immediate exposure to a hazard must also be reported to WorkSafe.
Occupiers should ensure procedures are in place to notify the appropriate authorities of any accidents or incidents.
Record Keeping
Occupiers should keep records of all activities in relation dangerous goods, including:
- notifications to WorkSafe
- emergency plans
- risk assessments
- staff training
- emergency response drills
- maintenance of plant and storage facilities