SAFETY HEALTH & WELLBEING GUIDELINE FOR CHEMICAL PROCUREMENT CONTENTS Contents ........................................................................................................................................................................ 1 1 Introduction ............................................................................................................................................................ 2 2 Purpose .................................................................................................................................................................. 2 3 Hazard.................................................................................................................................................................... 2 4 Risk Controls .......................................................................................................................................................... 2 4.1 Elimination and substitution ........................................................................................................................... 2 4.2 Engineering and isolation .............................................................................................................................. 3 4.3 Administration and PPE ................................................................................................................................. 3 4.3.1 Regulatory authorisation ............................................................................................................................ 3 4.3.2 Safety data sheets ..................................................................................................................................... 3 4.3.3 First aid, emergency response and PPE ................................................................................................... 4 4.3.4 Training and safe work procedures ........................................................................................................... 4 4.4 Receiving the chemical .................................................................................................................................. 4 4.4.1 Procurement workflow ............................................................................................................................... 4 5 Review and Evaluation .......................................................................................................................................... 6 6 References ............................................................................................................................................................. 6 7 Document control ................................................................................................................................................... 6 Appendix A: Pre-purchase checklist for hazardous material ......................................................................................... 7 Document1 Page 1 of 8 SAFETY HEALTH & WELLBEING 1 INTRODUCTION The procurement of a hazardous chemical is the first point of entry of a hazard into the workplace. Hazardous chemicals in a work area can present risks to those using them. A chemical purchased or procured by other means, e.g. donation or transfer from another area, must have hazards identified and associated risk controls considered prior to introducing the chemical to the workplace. Certain hazardous chemicals are regulated and have specific procurement approval processes for possession and use. 2 PURPOSE This guideline has been developed to support the University’s Chemical Safety Standards. Faculties, schools, research groups and professional services units are encouraged to use this document as a primary reference when developing local procedures to manage the procurement and purchase of chemicals. 3 HAZARD The risk from hazardous chemicals increases if high volumes and high risk chemicals are purchased and stored in the workplace. If large quantities of chemicals are purchased and then not used within a reasonable time-frame, ‘legacy’ chemicals can accumulate. Legacy chemicals increase the ‘hazard load’ in a workplace and also take up valuable storage space. High risk chemicals can act to increase the level of risk in the workspace and are often costly to remove when finally disposed. The University definition for a high risk chemical is one which has the GHS category at the highest hazard level, for example: flammable liquids category 1, reproductive toxicity category 1A or organic peroxide category A. 4 4.1 RISK CONTROLS ELIMINATION AND SUBSTITUTION When sourcing a chemical for a work activity the first considerations should be given to: Finding a safer alternative that is able to be used for the application required. Investigate other chemicals, methods and procedures that may not require the use of a hazardous chemical. The amount and type of waste generated from an activity should also be considered. Substituting the high risk chemical for a chemical that is less hazardous. For example ethidium bromide for nucleic acid staining has been replaced by many commercially available alternatives (e.g. fluorescent stains Nancy-520, GelRed), Ordering the minimum pack size to meet current rate of use. Always purchase minimal volumes for the rate of use that is required. For example if only 100g will be required within a 6 month period, buy only a 100g pack size, even if the 250 g pack may appear less expensive. If large quantities are purchased and then not used, they will require disposal at some point in the future which can be more expensive than the original purchase. Purchasing the lowest concentration to meet activity requirements Always purchase the lowest concentration of a chemical for the activity. For example if 70% ethanol is required, do not purchase 100% and then make up the 70% solution. Directly purchase the 70% solution. Document1 Page 2 of 8 SAFETY HEALTH & WELLBEING 4.2 ENGINEERING AND ISOLATION Access to adequate storage facilities. Always take into consideration chemical incompatibilities, space and stability. For example a 2.5 L bottle of ethanol may need to be placed in the Class 3 dangerous goods cabinet in the laboratory. Is there room in the cabinet? If not, can it be placed in a larger dangerous goods depot? Some chemicals require storage at low temperatures, is refrigeration available? Access to specific facilities required for handling. For example a fume cupboard or local area ventilation is a necessary and common risk control for chemicals that produce corrosive fumes, stench/odour or flammable vapours. 4.3 ADMINISTRATION AND PERSONAL PROTECTIVE EQUIPMENT There are a number of administrative controls which can be applied to the procurement of chemicals, including those requirements which are detailed by regulatory authorities. Implementation of these controls should be completed prior to the chemical arriving in the workplace. 4.3.1 Regulatory authorisation Regulated chemicals include, but are not limited to, Scheduled 4, 7 and 8 poisons, restricted and prohibited carcinogens, drug precursors and chemicals of security concern. There are a range of specific requirements for regulated chemicals. Some chemicals require the approval of the Regulator prior to procurement and may have specific requirements for storage and use. Ensure that the necessary authorisation has been sought prior to ordering the chemical. The procurement of high risk and regulated chemicals must also be approved by the relevant Head of School (or equivalent). The list of restricted and prohibited carcinogens can be found in Schedule 10 of the NSW Work Health and Safety Regulation [1]. Prohibited and restricted carcinogens can be used for ‘genuine research and analysis’ providing there is authorisation from WorkCover NSW. Refer to the Guideline for Working with Carcinogens. Scheduled poisons (S8, S9) for use in research require authorisation from the NSW Ministry of Health. Refer to the Guideline for Working with Scheduled Poisons. For some chemicals the Supplier is required to have an End User Agreement (EUD) completed by the purchaser before they can supply the chemical. A nominated approver from the Faculty or School will be required to sight a completed risk assessment and sign the EUD when the chemical is to be ordered. For example, highly dangerous S7 and restricted S4 scheduled poisons need an approval for purchase from a nominated approver (generally the Head of School or Dean). To facilitate the purchase it is advisable to discuss this requirement with the Supplier and ask for the EUD prior to ordering, then submit the completed EUD with the order. 4.3.2 Safety data sheets It is a requirement to have safety data sheets (SDS) accessible in a workplace where hazardous chemicals are used and stored. Current SDS must be readily available and reviewed prior to procurement to determine what facilities are required for the safe storage and handling of a chemical. It is a regulatory requirement that a manufacturer or supplier of a chemical provide an SDS for the chemical purchased. Hard copy of SDS may be provided with delivery of the chemical or more commonly suppliers will maintain an on-line SDS database. If an on-line system is used to access SDS (e.g. ChemAlert), all workers must know how to use that system. Document1 Page 3 of 8 SAFETY HEALTH & WELLBEING If a hazardous chemical is being supplied from The University of Sydney to another institution, then an SDS must be provided to the recipient. Refer to WorkCover NSW Code of Practice for Preparation of safety data sheets for hazardous materials [2]. If a hazardous chemical is being sourced from another institution, (non-standard chemical supplier) an SDS should be supplied from that institution. 4.3.3 First aid, emergency response and PPE Some chemicals may require specific first aid, spill response, personal protective equipment (PPE) or emergency equipment. For example hydrofluoric acid (HF) requires calcium gluconate gel as first aid for skin exposure and when handling HF neoprene gloves offer better resistivity than the commonly used nitrile gloves. Dry powder fire extinguishers are best to use on small metal fires (e.g. sodium, magnesium, titanium), rather than the more common CO2 fire extinguisher. All safety equipment required that is specific for the hazardous chemical must be in place prior to procurement, use and storage of the chemical. 4.3.4 Training and safe work procedures Appropriate training must have been completed by those workers who are going to use the procured chemical. A safe work procedure must be completed for all high risk activities with workers trained and deemed competent in that procedure (refer to the Guideline for Chemical Risk Assessment). Workers undertaking an activity with a high risk chemical must have experience in handling hazardous chemicals. The generic University training “Working with Chemicals” and an induction to the laboratory or workspace by the lab supervisor / manager or room custodian should also be completed. 4.4 RECEIVING THE CHEMICAL On receipt of the chemical check that: Special requirements of the chemical are met, such as refrigeration, secure or locked storage or receipt only to an authorised person. Delivered chemical is as described when ordered Packaging is free from contamination. Any damaged package should be returned to supplier. Delivered chemical has clear labelling There is knowledge of correct transport procedures and emergency / spill response when the chemical is transported to storage or workspace location ( Refer to Guideline for transporting chemicals) When a chemical arrives into the workspace: 4.4.1 Update the chemical register. A chemical register of all hazardous chemicals within each work area must be maintained and available. At a minimum chemical registers must include name, volume and location of the chemical such as shown in a simple chemical register template. Ensure the current safety data sheet is accessible for those workers who may have the potential to be exposed to the chemical. ChemAlert contains reports and many supplier SDS and there is a requirement to have available the actual Supplier SDS. Write date of receipt on chemical container. Many chemicals can degrade over time. By dating the bottle workers in the laboratory can better manage chemical stocks by identifying older chemicals and dispose when appropriate. Store the chemical correctly and safely. Refer to the guideline for chemical storage Procurement workflow Document1 Page 4 of 8 SAFETY HEALTH & WELLBEING A workflow for the procurement of chemicals is displayed in Figure 1.To facilitate a consistent approach when purchasing hazardous and high risk materials/chemicals a pre- purchasing checklist can be used (Appendix A) Figure 1 Workflow for the procurement of chemicals Document1 Page 5 of 8 SAFETY HEALTH & WELLBEING A laboratory requiring repeat purchases of the same item will not have to submit repeat checklists after the initial purchase has been approved. However a new checklist should be completed if there are new users, or the substance was to be used for a different purpose with a different set of risks. Another option is to create a list of pre-approved chemicals and products. 5 REVIEW AND EVALUATION Guidelines are reviewed by Safety Health & Wellbeing at least once every two years to identify and implement opportunities for improvement. 6 REFERENCES 1. NSW Work Health and Safety Regulation 2011 2. WorkCover NSW Code of practice for Preparation of safety data sheets for hazardous materials 2011 7 DOCUMENT CONTROL Acknowledgements Illustrations Figure 7: SafetyNets3University of California, Davis http://safetyservices.ucdavis.edu/snfn/safetynets/snml/sn60/sn60 [accessed June 2014] Related Documents WHS_CHE_STD_1_Chemical Safety Standards WHS_CHE_GUI_1_Guidelines for chemical risk assessment WHS_CHE_GUI_1_ Guidelines for chemical storage WHS_CHE_GUI_1_Guidelines for working with carcinogens WHS_CHE_GUI_1_Guidelines for working with scheduled poisons WHS_CHE_MTL_1_Pre-purchase checklist for hazardous material Version Control 1.0 Date released Author/s Custodian Approved by Amendment Sandra Chapman, WHS Specialist (Chemical) Manager, Work Health & Safety Services Director, Safety Health & Wellbeing Original Printed copies of this document are uncontrolled. Verify version before using. Document1 Page 6 of 8 SAFETY HEALTH & WELLBEING APPENDIX A: PRE-PROCUREMENT CHECKLIST FOR HAZARDOUS MATERIAL 1. DESCRIPTION Purchase order number Supplier Name of item CAS No. 2. GHS CLASSIFICATIONS GHS Classification ☐ Flammable liquid ☐ Flammable solid ☐ Self-reactive / Organic peroxide ☐ Oxidising liquid or solid ☐ Corrosive to metals ☐ Skin corrosion / irritation ☐ Serious eye damage / eye irritation Category (please circle) ☐1 ☐2 ☐3 ☐4 ☐1 ☐ 2 ☐A ☐B ☐C ☐D ☐E ☐F ☐G ☐1 ☐2 ☐3 ☐1 ☐1A ☐1B ☐1C ☐2 ☐1 ☐2A ☐ Compressed gas ☐ Gas under pressure ☐ Liquefied gas ☐ Dissolved gas ☐ Refrigerated liquefied gas GHS Classification ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ Acute toxicity Reproductive toxicity Carcinogenicity Germ cell mutagen Self-heating Aspiration toxicity Pyrophoric liquids Pyrophoric solid Water reactive giving flammable gases ☐ Specific target organ toxicity ☐ Sensitiser ☐ Flammable gas ☐ Oxidising gas Category (please circle) ☐1 ☐2 ☐3 ☐4 ☐1A ☐1B ☐2 ☐1A ☐1B ☐2 ☐1A ☐1B ☐2 ☐1 ☐2 ☐1 ☐1 ☐1 ☐2 ☐3 ☐1 ☐2 ☐ repeat ☐ single ☐skin ☐respiratory ☐ 1 ☐ 1 3. FOR ALL HAZARDOUS CHEMICALS ☐ A current safety data sheet (SDS) is accessible and has been consulted. ☐ No safer alternative is able to be used for the application required. ☐ The minimum pack size is to be ordered to meet rate of use. ☐ The lowest concentration is to be ordered to meet requirements of the activity. ☐ An appropriate workspace is available for this chemical (ventilation, fume cupboard etc.). ☐ Appropriate storage is available for the chemical (DG cabinet or depot). ☐ PPE specific for the chemical is available. ☐ Appropriate emergency/spill procedures and spill kits for the chemical are accessible. ☐ Disposal processes have been considered and are in place. ☐ Appropriate training has been completed by those who will use handle and store the chemical. Please specify additional training: 4. FOR HIGH RISK OR REGULATED HAZARDOUS CHEMICALS If a high risk chemical or the following regulated chemicals have not been used in the workplace before, a detailed risk assessment for the activity using the chemical must be completed and submitted to the Head of School. Document1 Page 7 of 8 SAFETY HEALTH & WELLBEING Chemical Requirement ☐ Restricted carcinogen ☐ A WorkCover Authorisation has been obtained ☐ Prohibited carcinogen ( listed Schedule 10, NSW WHS Regulation) ☐ An end user agreement has been completed with approval from Head of School or Dean ☐ Restricted S4 poison ☐ Purchase by person who has authority from the Pharmaceutical Services Unit, Ministry of Health ☐ Pentobarbitone ☐ Highly dangerous S7 poison ☐ S8 poison (controlled drug) ☐ An end user agreement has been completed with approval from Head of School or Dean ☐ S9 poison ☐ Drugs register and cabinet is available for use ☐ Arrangements made for immediate and secure receipt of chemicals ☐Other: Click here to enter text. 5. RADIOISOTOPES ☐ Radiation Project Clearance been obtained from the University Radiation Safety Committee? RSC Approval number: Click here to enter text. ☐ Alternative non-radioactive options been considered? ☐ Appropriate storage and handling facilities are present (e.g. shielding, personal monitoring devices)? ☐ Disposal been considered and organized (i.e. short term vs long-term storage due to half-life)? ☐ School’s Radiation Safety Officer (Click here to enter text. ) been consulted? NOTE: Radioisotopes must be ordered by a licensed person and all of the above ticked 6. MICROORGANISM, INFECTIOUS MATERIAL, GENETICALLY MODIFIED ORG ANISM (GMO) OR BIOLOGICAL SAMPLE ☐ Risk Grouping has been determined (e.g. Risk Group 1 or Risk Group 2). Risk Group 3 or above is not permitted. ☐ If material is Risk Group 2, a PC2 compliant facility is available to handle material. ☐ Safe Work Procedures for handling, storage, spills, disposal in place. ☐ Institutional Biosafety Committee (IBC) approval has been obtained for any material that is genetically modified. IBC approval number: Click here to enter text. ☐ The material is not on the list of Security Sensitive Biological Agents (SSBAs). 7. QUARANTINE MATERIAL ☐ A current Department of Agriculture import permit for this work has been obtained. ☐ Material is to be used, handled and stored in QAP (Quarantine Approved Premises) by approved person 8. APPROVAL Note: A laboratory requiring repeat purchases of the same item will not have to submit repeat checklists after the initial purchase checklist has been approved. Exception would be if there were new users, or the substance was to be used for a different purpose with a different set of risks. Purchaser: signature Click here to enter text. print name Enter date date Supervisor / license holder: signature Click here to enter text. print name Enter date date If required: Safety Officer or RSO: signature Click here to enter text. print name Enter date date Document1 Page 8 of 8