Safeguarding Your Well-Being and Compensation: Understanding Hazardous Chemicals and Dangerous Goods

Hazardous Chemicals and Dangerous Goods

In the work environment, the regulation concerning hazardous substances and dangerous goods is encompassed by the Work Health and Safety Regulation 2011, providing a unified framework for hazardous chemicals.

According to the Work Health and Safety Regulation 2011 (WHS Regulation), all hazardous chemicals (manufactured or imported after 31 December 2016) must undergo classification and labeling in alignment with the globally harmonized system for the classification and labeling of chemicals (GHS).

Hazardous chemicals, often referred to as hazchem, are a category of chemicals classified as hazardous for workplace use under the GHS. The GHS system primarily focuses on chemicals presenting acute and chronic hazards to health and safety in the workplace.

Prior to the GHS, health hazards in chemicals were identified using NOHSC-approved criteria, while physical hazards were classified following the Australian Dangerous Goods (ADG) Code for transport. The GHS essentially merges these two classification systems and provides a corresponding labeling system for workplaces.

Dangerous goods (DG) refer to chemicals and articles classified as dangerous for transport via road, rail, air, or sea. DG classification systems concentrate on goods with predominantly acute hazards to safety, the environment, or transport vehicles.

DGs transported by sea adhere to the International Maritime Dangerous Goods Code (IMDG) Code, and those transported by air follow the International Air Transport Association (IATA) DG Regulations. These DG classification systems also feature their own labeling (and marking) systems for use in transportation settings.

Interactions between hazchems and DGs are common, especially for chemicals with acute physical hazards. Compliance with both GHS labeling requirements (WHS) and ADG Code (transport) labeling and marking requirements is necessary for such chemicals.

To determine whether a chemical has been classified as a hazchem and/or a DG, consult the chemical's safety data sheet (SDS):

  • Refer to section 2 for hazchems
  • Refer to section 14 for DGs

(Note: SDSs are mandatory only for hazchems under the WHS Regulation). In the absence of an SDS, always seek information from the manufacturer or importer. Due to the overlap between hazchems and DGs, and considering that hazchems are often transported between workplaces, interactions between the two labeling systems may occur, especially for larger containers such as 200 L drums and IBCs. The WHS Regulation and the Labelling of Workplace Hazardous Chemicals Code of Practice 2011 (hazchems) provide exemptions and guidance on handling these interactions.

  • Section 335(4) of the WHS Regulation states that whilst hazchems are in transit they do not require hazchem (GHS) labelling, e.g. hazchems imported into Australia do not need GHS labels whilst they are in transit from an import terminal to their importer's storage warehouse. However, once a hazchem arrives at a workplace and is no longer in transit, a GHS label is required on the hazchem container at this point in accordance with section 335 of the WHS Regulation. In transit at a workplace means a hazchem in a container that is not opened, used or kept at the workplace for more than five consecutive days. Hazchems in transit that are also DGs shall comply with any labelling and marking requirements required under the ADG Code and will require information such as the proper shipping name (PSN), UN number and dangerous goods class label (i.e. diamond).
  • Section 3.7 of the Labelling of workplace hazardous chemicals code of practice 2011 states that hazchems that are also DGs and transported by road or rail must comply with the labelling or marking requirements that are specified in the ADG Code.
  • Section 2.4 of the Labelling of workplace hazardous chemicals code of practice 2011 states that GHS hazard pictograms (red, white and black diamonds) may be substituted by the equivalent ADG Code class labels (coloured diamonds) however, never use both in the same label. A comparison of the GHS hazard pictograms and the ADG Code are shown in Appendix G. (Note: not all GHS hazard classes have an equivalent ADG Code class label.)
  • Section 3.7 of the Labelling of workplace hazardous chemicals code of practice 2011 states that the ADG Code recognises the GHS labelling system as an appropriate labelling system for inner packages, e.g. smaller containers that are packed into an outer cardboard box, of DGs during transport. This is reinforced by section 5.2.2.1.13 of the ADG Code.
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