The control of hazardous chemicals in today's society is controlled by 3 major pieces of legislation:

• The ACT Dangerous Goods Act, which regulates transport and storage,
• The Hazardous Substances Regulation, which is part of the Occupational Health and Safety (Commonwealth Employment) Act. Control of Carcinogens is now under this regulation. See Comcare website at http://www.comcare.gov.au/publications/publications-ohs.html#ohs
• The ACT Poisons Act, which controls access to scheduled drugs and poisons.

The legislation places certain obligations on ANU management in regard to chemical handling. The obligations are no more onerous than the procedures that would generally be in place through good technical risk management. Thus, it is disappointing to report that compliance with these pieces of legislation within the ANU has been less than ideal in a sample of Areas reviewed recently by the OHS Unit. The University has already been issued with two Improvement Notices under the OHS Act back in late 1997. The University-wide education campaign undertaken in early 1998, and on-going Chemical Safety Courses have indicated the legislative and risk management expectations and how to fulfil these at the local level.

A full audit by the OHS Unit of Hazardous Substance compliance, promised in 1998, was delayed in 1998-99 due to the late release of the Carcinogen regulations which are now part of the Hazardous Substances Regulations. This audit is now scheduled for 2000 and will incorporate relevant aspects of Poisons Act compliance. Dangerous goods storage has been audited in previous years and is considered complete.

As we approach the end of year many Areas conduct laboratory clean-ups and inventories, and this will provide a good opportunity for relevant Areas to upgrade their performance with respect to the following key legislative requirements:

1. Information - The provision and access to Material Safety Data Sheets. It is encouraging that the majority of Areas are aware of MSDSs and have easy access to them. Computer databases, ordering requests and the web are the main sources.
2. Register - A chemical inventory (incorporating a hazardous substances register) must be kept. Ideally this should include all information for hazardous substances, scheduled poisons/drugs and carcinogens, dangerous goods, and research substances used or produced. An inventory can also act as acontents list of MSDSs. A chemical inventory is a source of information and a tool to manage substances at work.
3. Procedures - A documented risk assessment of the chemical handling procedure. There are several options available tocomply with this requirement:
   • Chemical handling protocols, which are experimental methods with the hazard and risk assessment incorporated. This system is the preferred method and ideal for experimental procedures that are repeated regularly or by many people.
   • The risk classification system. As given at http://info.anu.edu.au/Policies/Procedures/Human_Resources/ohs/Risk_Management_for_Chemicals.asp
     This system is ideal for experimental procedures that are unlikely to be repeated.
   • The hazard assessment procedures given in the Hazardous Substances Regulation and Worksafe Australia documentation on hazardous substances.
4. Chemical handling protocol - A chemical handling protocol is particularly important and must be available when the following chemicals are to be used. Note that the chemical handling protocol should also include details on waste disposaland emergency precautions and procedures.
   1. Chemicals listed under the Hazardous Substances Regulations as possibly requiring health surveillance or workplacemonitoring during use -
      • 4,4 Methylene bis (2-chloroaniline) (MOCA)
      • Acrylonitrile
      • Asbestos
      • Cadmium (& its compounds)
      • Crystalline silica (silica flour, quartz dust, fine sand ...
      • Inorganic arsenic
      • Inorganic mercury
      • Isocyanates
      • Organophosphate pesticides
      • Polycyclic Aromatic Hydrocarbons (PAHs)
      • Thallium
      • Vinyl chloride
      • Pentachlorophenol
      • Benzene
      • Creosote
      • Inorganic chromium
   2. Restricted carcinogens under the regulations -
      • 2-Acetylaminofluorene
      • Aflatoxins
      • 4-Aminodiphenyl
      • Amosite (brown asbestos)
      • Benzidine and its salts, including benzidine dihydrochloride
      • bis(Chloromethyl) ether
      • Chloromethyl methyl ether (technical grade containing bis(chloromethyl) ether)
      • Crocidolite (blue asbestos)
      • 4-Dimethylaminoazo-benzene
      • 2-Naphthylamine and its salts
      • 4-Nitrodiphenyl
      • Acrylonitrile
      • Benzene
      • Chrysotile (white asbestos)
      • Cyclophosphamide (cytotoxic drug)
      • 3,3-Dichlorobenzidine and its salts
      • 3,3-Dichlorobenzidine dihydrochloride
      • Diethyl sulfate
      • Dimethyl sulfate
      • Ethylene dibromide
      • 4,4-Methylene bis(2-chloroaniline) known as MOCA
      • 2-Propiolactone
      • ortho-Toluidine
      • ortho-Toluidine hydrochloride
      • Vinyl chloride monomer
5. Storage and Usage Register - Chemicals listed above, Scheduled 4, 7, 8, and 9 poisons, and carcinogens must be safelyand securely stored and a register of usage kept. This may or may not be part of your chemical inventory- but should be linked to it.