Occupiers of premises that store or handle dangerous goods may need to temporarily shut down or significantly restrict their operations as a result of the coronavirus (COVID-19) pandemic, including in response to Chief Health Officer Directions.
When ceasing or significantly restricting operations, and when resuming normal operations, business owners and managers must continue to ensure the safe storage and handling of dangerous goods.
Significant risks arise from the presence of dangerous goods at premises. Risks associated with dangerous goods that need to be managed when temporarily ceasing or significantly restricting operations include:
- fires and explosions associated with flammable gas (LP Gas) systems, for example gas fired heaters
- fires, explosions and leakages associated with flammable liquids, for example petrol, kerosene, turpentine, flammable paints
- exposure to corrosive material, for example acids, alkalis
- materials with the potential to degrade or which are incompatible with other materials
- accumulation of non-flammable non-toxic gases that are asphyxiant, for example carbon dioxide, nitrogen
- the presence of asbestos or asbestos-containing materials
- ‘benign’ materials that, when degraded or contaminated, become hazardous, for example batteries, garden or agricultural chemicals, ammonium nitrate.
Occupiers must identify the hazards related to dangerous goods that are present at their workplace or premises, assess the risks, and implement risk controls. The Code of practice for the storage and handling of dangerous goods provides practical guidance on how to comply with obligations for the safe storage and handling of dangerous goods.
In particular, prior to shutting down or significantly reducing operations, occupiers of premises storing or handling dangerous goods should eliminate risks by removing or consuming dangerous goods where practicable.
If this is not practicable, occupiers should:
- consider the minimum staffing requirements to ensure the continued safe management of materials on the premises
- ensure that all staff on site are fully informed of the risks associated with the dangerous goods and the risk controls implemented during reduced operations
- ensure that safety data sheets (SDS) are available for all dangerous goods on the premises
- ensure that package markings and class or hazard class information are clearly visible, including to emergency services
- ensure that buildings subject to shutdown are adequately ventilated so that flammable or toxic materials cannot accumulate
- ensure that processes that rely upon a regular rate of consumption (for example LNG, cryogenic ammonia) do not heat up to a hazardous degree as a result of reduced operations
- ensure that the safety aspects of security inspections are sustained (for example physical inspections, CCTV, thermal imaging)
- consider storage locations
- ensure isolation (for example, valves are closed)
- ensure flushing of pipework
- confirm that fire systems are functional
- ensure that the premises has outer warning placards (if required) that are in good condition and visible to emergency services
- ensure that the manifest for the site is up to date and placed in a location that is accessible to emergency services
Further guidance is provided below regarding the safe storage of dangerous goods during a shutdown or reduced operations.
Occupiers should also plan to manage risks that will arise when bringing the business back to normal operations following shutdown or reduced operations. Both shut down and start-up are process conditions, which need special attention to prevent the occurrence of chemical accidents. Recent severe incidents in India (Visakhapatnam) and Italy (Ottaviano) were caused by failures to ensure that robust controls were implemented prior to restarting a business after shutdown.
Under the Occupational Health and Safety Act 2004, employers must, so far as is reasonably practicable, provide and maintain a working environment that is safe and without risks to the health of employees and independent contractors. Employers must also ensure, so far as is reasonably practicable, that people other than employees are not exposed to risks to their health or safety arising from the employer's conduct.
The Dangerous Goods (Storage and Handling) Regulations 2012 also sets out legal duties for manufacturers and suppliers, and for occupiers of workplaces where dangerous goods are stored or handled. The Code of practice for storage and handling of dangerous goods provides practical information on how to comply.
Further guidance regarding the safe storage of dangerous goods during a shutdown or reduced operations
General hazard controls
- stored in approved cabinets or dedicated packaged goods stores when above minor quantities: refer to relevant Australian Standard
- arrangements for spill containment are in place when above minor quantities storage
- appropriate firefighting equipment is available
- appropriate PPE is available and in good condition
- appropriate first aid (and emergency eye wash if Class 8) is nearby
- user/employee training and procedures
- signage and placarding is present
- manifest requirements are checked
- notification requirements checked
Specific hazard controls for classes of dangerous goods
Class 1: Explosives
- all explosives are stored in compliant receptacles or licenced magazines
- explosives are adequately segregated from flammables
- security plan is fully operational
Class 2: Compressed gases
- all control valves are shut tight
- gas cylinders are secured to prevent them falling over
- gases are stored in well ventilated areas
- flammable and toxic gases are adequately segregated
- flammable gas is adequately segregated from oxidizing agents
Class 3: Flammable liquids
- stored in cabinets approved for use with class 3 dangerous goods or dedicated packaged goods stores
- stored away from ignition sources
- adequately segregated from oxidizing agents, toxics and corrosives
- if stored in cold room below flash point, systems are in place to respond to faults in ventilation/cooling or to de-energise all electrics within the coldroom
- adequate spill containment
Class 4: Flammable solids
- all spills are cleaned up to prevent spontaneous combustion
- packages are well sealed/air tight
- stored in area where they cannot get wet
- adequately segregated from oxidizing agents, toxics and corrosives
Class 5: Oxidizing agents
- adequately segregated from flammable liquids, toxics and corrosives
- temperature controls and monitoring are in place to ensure organic peroxides are stored well below their self-accelerating decomposition temperature (SADT)
- class 5.1 agents are stored in a dry and well ventilated area, away from ignition sources and spill equipment
Class 6.1: Toxics
- adequately segregated from flammables and corrosives
- spills are cleaned up and open packages are sealed
Class 8: Corrosives
- adequately segregated from flammable liquids and toxics, and stored in approved cabinet or packaged goods store when above minor quantities
Class 9: Miscellaneous
- goods packages/containers are sealed in areas that cannot enter stormwater systems
Note: The Code of practice for the storage and handling of dangerous goods provides additional detail regarding these hazard controls.