National Code of Practice for Chemicals of Security Concern
1. Introduction and General Response
The University of South Australia Context
The University of South Australia has more than 35, 000 student spread across 6 campuses
located in Adelaide and other South Australian regional centres. The University has 6
flagship research institutes and 17 research centres undertaking both fundamental and
applied research in a range of research areas.
With an extensive research and academic concentration, the introduction of the National
Code of Practice for Chemicals of Security Concern may potentially impact on the research
and teaching undertaken at the University, particularly in regards to requirements for detailed
monitoring of usage and education of the University end-users of precursor chemicals.
Use of Chemicals of Security Concern within the University of South Australia
Scale of chemical use at the University of South Australia.
The 11 chemical precursors to homemade explosives identified in the National Code of
Practice are used throughout the University of South of Australia for both teaching and
research purposes. However, due to teaching and research requirements, only small
quantities of the chemicals are generally stored within individual laboratories on-site for
immediate access by researchers or laboratory staff.
The Code of Practice does not differentiate between volume of the chemicals utilised by
end-users and security risk. The Code of Practice implies that the security risk is similar
irrespective of the volume of precursor chemicals used by an end-user. We ask that the
Code of Practice includes guidance to security measures that should be considered
based on the volume of precursor chemicals used by the end-users in individual
laboratories or work areas.
Procurement of chemicals at the University of South Australia
All precursor chemicals outlined in the Code of Practice are purchased through the
University preferred supplier list. As outlined above, many University staff purchase small
quantities of precursor chemicals for their own laboratory use. Tracking this purchase is
difficult as there is little centralisation of chemicals purchased. It would therefore be
advantageous that the chemical suppliers record these purchases as part of the
supply of precursor chemicals. The current Code of Practice appears to be primarily
targeting production, supply and transport industries where large volumes of precursor
chemicals may be at elevated security risk of being removed.
Management of security and access to chemicals
The University of South Australia employs both research and academic staff whom manage
their chemical requirements in conjunction with OHS&W staff. The exceptions are for staff
utilising hazardous (acute toxic, carcinogenic) chemicals and ammonium nitrate where
University policy and National security policy control the storage and handling of these
chemicals. However, to ensure best risk management practice, chemicals, such as the 11
precursor chemicals identified in the Code of Practice have restricted access. To date, this
level of security has proved to be adequate for the volume of chemicals stored in any
one laboratory within research or teaching facilities.
2. Specific Responses
General
 Will the code enhance your business’s ability to identify and manage security
risks?
The University of South Australia already has procedures in place addressing the storage
and management of chemicals within the University. From a current University chemical
database the storage of many of the 11 precursor chemicals is already known and the
stored chemical quantities are low. Considering the low quantities of the 11 precursor
chemicals stored and restricted access to the storage areas, the introduction of the
Code of Practice is not likely to require significant changes to the current security
practices within the University of South Australia.

Will the code help businesses reduce the risk of terrorists or criminals stealing
or diverting chemicals from the premises?
The use of the chemicals at the University of South Australia is distributed among
campuses and schools, research Centres or Institutes within the university. Importantly,
the quantity of precursor chemical stored at any one laboratory is extremely small
(probably less than 500g) and the code does little to advise the University on potential
security measures that may be implemented at very low security risk organisations. The
Code of Practice could be improved if it detailed examples of minimum practices that
need to be implemented to reduce the risk of terrorists or criminals stealing or diverting
chemicals from the premises with low security risks. At the moment the Code is targeting
businesses which potentially sell or distribute large volumes of precursor chemicals.
 Will the code raise awareness of the national security risks associated with
chemicals among businesses that deal with chemicals of security concern?
The code will raise University employees’ awareness of the security risks associated with
using the 11 precursor chemicals. However, many staff consider the security concerns
are excessive considering the quantity of chemicals actually stored and used in various
laboratories.