OCCUPATIONAL HEALTH & SAFETY MANUAL
13.
Section 13 – Hazardous Substances Policy
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Issue Date:
24 July 2001
Authorised by: Marjorie Dickenson
HAZARDOUS SUBSTANCES POLICY
Many chemical substances are used on-site at SimuLab, but not all of these can be classified as
hazardous substances. This policy only applies to hazardous substances, but in a case of best
practice all chemicals may be treated in a similar fashion.
Legally a chemical is classified as a hazardous substance if it is listed in Worksafe Australia's List of
Designated Hazardous Substances [NOHSC: 10005 (1999)], or if it fits the criteria for hazardous
substances set out in the document “Approved Criteria for Classifying Hazardous Substances
[NOHSC:1008(1999)]. In simpler terms it is probably easier to think of hazardous substances as
those that have the potential to cause harm to workers health and safety.
As SimuLab's core business involves the use of hazardous chemicals it is impossible for employees
to avoid at least some contact with them. Hence a management system for hazardous chemicals is
required in order to maintain a safe workplace. This system must incorporate a number of key
elements in order to be successful. These include:

A sound risk assessment procedure for actual and potential hazards.

Effective communication and labeling.
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Effective education and training.
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Appropriate control of exposure in all areas of the workplace.
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Appropriate disposal of waste materials.
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Effective emergency procedures.

Ongoing monitoring and review of all procedures and processes.
Documentation on how to implement the SimuLab management system for hazardous chemicals is
listed on the following pages. This document has been developed with reference to the New South
Wales Occupational Health and Safety Regulation 2001 chapter 6 - Hazardous Substances, and in
consultation with WorkCover New South Wales. For further information on hazardous substances at
SimuLab, the Laboratory Manager should be contacted.
13.1.
Hazard identification
There are more than 1,000 chemical substances in use at the SimuLab site at any point in
time. Because these substances have great variation in properties and characteristics when
they are used it is essential that all employees have suitable information on use and handling
requirements. To facilitate this SimuLab will ensure that all workers have access to the
following:

Correct chemical labelling.

Material safety data sheets.

Hazardous substances register.
13.1.1. Chemical labelling
Chemical labels ensure that the contents of a container can be readily identified, and also
draw the attention of the user to any significant hazards involved with their use. Government
authorities have recognised the dangers associated with poor or inconsistent labelling of
chemical substances, and have designated legislation and the code of practice for consistent
and safe labelling. SimuLab will follow all details of this code of practice for workplace
labelling of chemical substances. Key elements of this are listed below.
13.1.2. What Information Should I Find on the Label?
Labelling requirements vary for different types of chemical substances 1 (hazardous or nonhazardous).
1
Fullick, G., Krajniak, E. and Barker, D., Occupational Health & Safety in the Laboratory, Nelson Thompson Learning,
Sydney, 1996.
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Section 13 – Hazardous Substances Policy
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If the label contains any of the signal words POISON, DANGEROUS POISON, CAUTION,
WARNING or HAZARDOUS then the substance is hazardous. These are normally found at
the top of the label in a box with bold red or black writing.
Suppliers are responsible for the correct labelling of hazardous substances, which they
supply to others.
Employers are responsible for ensuring containers in the workplace are correctly labelled.
13.1.3. Substances that are Not Classified as Hazardous
When a chemical is not hazardous, then the labelling requirements are minimal and
include:

The product name or identity (chemical names are not essential although desirable).

The manufacturer or suppliers details.

A statement that the substance is not hazardous.

Dangerous goods warnings and subsidiary risk labels if appropriate.
13.1.4. Hazardous Substances
Containers of hazardous substances must be labelled to allow safe use of their contents.
The minimum requirements for this are determined by:

The size of the container.

The type of substance.

The concentration of the substance (if it is in a mixture).

The time for which the substance is stored in the container.
A large container used for dispensing (e.g. a 2.5L bottle) requires more extensive labelling
than a small reagent bottle or test tube.
A substance which is initially classified as hazardous, may after dilution become nonhazardous and therefore will have totally different labelling requirements.
For example a solution containing 12.5% phenylethene (common name styrene) is classified
as irritant and harmful (and therefore is listed as a hazardous substance), but below this
concentration it is not a hazardous substance and therefore only requires to be labelled as
per non-hazardous substances. A summary of requirements from the relevant legislation is
given in Table 1.
13.1.5. Labelling of Decanted Substances
Labelling of decanted substances depends on whether the substance is consumed
immediately or over a longer period of time. When a decanted substance is not consumed
immediately (within the work shift), the employer must ensure that the container into which
the substance is decanted is labelled with the product name and appropriate risk and safety
phrases. Where labelling is required but the container into which the substance is decanted
is very small (e.g. a test tube), the label must be attached using a tag.
Where a decanted substance is consumed immediately, no labelling is required
provided that the container is cleaned and no longer contains the substance.
Temporary labelling must remain on the container until the substance is used and the
container cleaned.
13.1.6. Unlabelled Containers
Any container that is unlabelled or incorrectly labelled must be immediately given a correct
label. Containers whose contents are not known, should be clearly marked, 'Caution do not
use: unknown substance'. They should be stored safely until identified, and, if hazardous,
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then appropriately labelled. If not identifiable, they should be disposed of as described by the
SimuLab waste management contractor. The Laboratory Manager should be notified if
unlabelled substances are found.
Table 1 – Container Labelling for Hazardous Substance Compliance (from WorkCover NSW and Occupational
Health & Safety in the Laboratory1)
Label Entry
Product name
Chemical name
UN number
Ingredients or formulation
Dangerous goods information
Subsidiary risk labels
Signal words
Risk phrases
Safety phrases
Directions for use
First aid procedures
Emergency services info.
Manufacturers details
Reference to MSDS
13.2.
Larger than
500mL or 500g
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Container Size
Smaller than
Very small
500mL or 500g
Yes
Yes
Yes
No
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
Yes
Yes
No
Decanted
and stored
Yes
No
No
No
No
No
No
Yes
Yes
No
Yes
No
No
No
Material Safety Data Sheets
Material safety data sheets (MSDS) provide information to allow the safe use and handling of
hazardous substances. They must provide at least the following minimum information:

Manufacturer or suppliers details.

Product identification.

Health hazard information.

Safe handling information.

Precautions for use.

First aid treatment.
No material safety data sheet may be more than five years old. Under legislation a
current manufacturer's or suppliers material safety data sheet must be readily
available to those handling hazardous substances. For more information on material
safety data sheets contact the Laboratory Manager.
13.2.1. Obtaining Material Safety Data Sheets
No hazardous substance may be brought onto the SimuLab site unless accompanied
by a MSDS. Those purchasing hazardous substances MUST ensure that the supplier
provides a current MSDS to accompany the hazardous substance upon delivery. By law,
suppliers must provide a current MSDS for all hazardous substances upon request or first
supply.
All requests for MSDS’s must be made in writing, and any purchase of a hazardous
substance must be authorised by the Laboratory Manager.
Once a copy of an MSDS is obtained it must be placed in the Hazardous Substances
Register, and a copy placed in a chemical register of the area in which it is to be used.
13.2.2. Availability and Access to MSDSs
MSDSs must be utilised by, and available to:
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Those persons using the substance.
Those people who may be potentially exposed to the substance.
Occupational health and safety committee members.
First-aid officers.
Emergency personnel.
This requires that the MSDS be kept near where product is being used and be readily
available. In SimuLab laboratories MSDSs will be maintained in the chemical register, which
is placed on the reference shelf just inside the entry to each laboratory. Additionally copies
are available online in the hazardous substances register of the company intranet.
If any person is unsure about information contained in an MSDS they should communicate
with the laboratory manager or their immediate supervisor as soon as possible for
clarification.
13.2.3. When to use an MSDS
MSDSs should be used in the following situations:

Whenever a person uses a substance for the first time.

To obtain hazardous substances information.

To obtain information on emergency equipment or procedures.

To determine if a suitable alternative substance may be used.

When choosing personal protective equipment.

When storing the substance.
13.2.4. Modification of MSDSs
It is illegal to modify a manufacturer's MSDS in any way. If information needs to be provided
in addition to the MSDS it should be attached to the MSDS on a separate sheet.
13.2.5. Hazardous Substances Registers
These are indexed and catalogued collections of material safety data sheets and other
safety information. At the minimum they must contain a list of all hazardous substances used
in the workplace, and their material safety data sheets.
The laboratory manager must hold a central Hazardous Substances Register. This MUST
contain a list of all hazardous substances available on the site. Any worker may access this
upon request.
Individual work areas should also have available a list of hazardous substances used in, and
specific to that area. This is a subset of the Hazardous Substances Register and will be
referred to as the chemical register for that area.
13.3.
Emergency Services Manifest
The central Hazardous Substances Register and a copy of the Dangerous Goods Licence
must be available to emergency services upon request.
13.4.
Placarding of Bulk Stores and Storage Tanks
All bulk stores and storage tanks must be placarded according to current legislation.
13.5.
Risk Assessment for Hazardous Substances
It is company policy and a legislative requirement that risk assessments be performed on all
hazardous substances in the workplace. A risk assessment MUST be performed on any
hazardous substance BEFORE it is used in the workplace. When performing the risk
assessment the following must be considered:

The age and sex of those exposed (some substances affect one sex more than the
other, or are worse for specific age groups).
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How many persons are exposed.
How they are exposed (inhalation, absorption, or ingestion?).
The frequency of exposure (continuous, sporadic, single-dose, accidental).
When are persons exposed (workplace operations, transport, disposal).
What control measures are in place (use hierarchy of control).
The consequences of exposure.
The manager or supervisor of each area is responsible for ensuring that risk assessments
are undertaken for all hazardous substances used in their workplace. Once completed, a
copy of the risk assessment must be maintained in the chemical register and another copy
forwarded to the laboratory manager for submission into the Hazardous Substances
Register.
13.6.
Disposal of Hazardous Substances
SimuLab’s risk assessment policy requires that a risk assessment approach be utilised for all
operations on site. The Hierarchy of Hazard Control requires substitution of hazardous
materials with less hazardous materials whenever possible. Hence hazardous substances
may in some circumstances become obsolete or superfluous and disposal may be required.
If this occurs the hazardous substance and all hazardous waste must be disposed of as per
the chemical label or MSDS. SimuLab employs a contract waste collector to dispose of any
chemical waste which must be removed from the site. In order to facilitate this process the
laboratory manager should be contacted.
13.7.
Forms

Risk assessment form.
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