Regulatory Obligations

The Hazardous Substances Regulations under the Occupational Health and Safety (Commonwealth Employment) Act 1991 require employers to establish systems of work that minimise, as far as is reasonably practicable, the risk to health from exposure to hazardous substances.  The Regulations define 'hazardous substances' as chemical materials that are listed [1] or that have intrinsic toxic, corrosive, irritant, sensitising, mutagenic, teratogenic, or carcinogenic properties.  The risks from safety hazards also need to be managed by the University, including hazards from explosion, flammability, compressed gases and cryogenic liquids.

Responsibility for risk assessment

The University's recommended hazard identification and risk assessment processes for hazardous chemicals are documented in our Chemical Safety manual [2].

The risk assessment (included in the protocol development) is the responsibility of the supervisor of the research or laboratory work, or the academic responsible for a teaching program.  They can delegate the risk assessment to competent post-doctoral staff, post-graduate students or trained laboratory technicians.  However, it remains the responsibility of the academic leader (or an appropriately experienced nominee), to ensure that risk assessments are carried out and that the resulting control measures are appropriate and implemented.

Risk management

The risk management process involves  -

• Identification of the hazards associated with the materials and process.  Hazards associated with waste disposal, spill and other emergency procedures should also be considered.
• Assessment of the risks from those hazards in context of the process and potential exposure.
• Controlling/reducing those risks to an acceptable level.
• A feedback/checking stage to monitor effectiveness over time.

Chemical risk management

The risks associated with use of chemicals must be managed through the following strategies:

1. The use of dedicated laboratories and appropriate facilities, including fume cupboards and support service.

2. Adherence to University chemical OHS guidelines on hazardous chemicals :

•   general chemicals
•   flammable liquids
•   corrosive substances
•   compressed gases
•   cryogenic liquids
•   painting code of practice
•   pesticides.

3. For hazardous chemicals, the use of :  

• a chemical register,
•  the CHEMWATCH® Database,
•  Material Safety Data Sheets, and
•  the labelling of containers.

Comcare Scheduled Carcinogens should be labelled with the ANU Carcinogen symbol (print on Avery labels L7063, L7163, J8563). Waste material containers should be labelled as per the Hazardous Waste Disposal guidelines .

Other containers should be labelled according to the National Health and Safety Commission guidelines.

(additional practical guidelines can be found at http://info.anu.edu.au/Policies/_DHR/Procedures/Chemical_Hazard_Procedures.asp)

4. Maintenance of Chemical Inventories containing chemicals that are stored and produced in the workplace, including information relating research substances, hazardous substances, scheduled poisons/drugs, and dangerous goods.  A chemical inventory or register is an important source of information and a tool to manage substances at work.

5. Use of appropriate controls (including equipment) to minimise exposure to hazardous chemicals,

6. Employment of technically-trained persons,

7. Design, development and provision by experienced scientists of protocols for laboratory work, including the undertaking of a risk assessment,

8. Supervision of laboratory work,

9. Audit activities to ensure adequate storage and minimal stocks of hazardous chemicals,

10. In-house staff training on hazardous chemicals and risk minimisation provided through the

• induction by the appropriate Budget Unit,
• chemical safety training courses run by the OHS Unit, see http://info.anu.edu.au/hr/Training_and_Development/OHS_Training/Advanced_Courses/index.asp

Risk Control Guidelines for the Use of Chemicals at ANU

Risk control guidelines for hazardous chemicals which determine procedures to the assessed risk  are to be applied to all facilities / laboratories where experimentation with chemicals may be undertaken [4] and especially in the Research School of Chemistry (who designed and tested the guidelines). 

Several risk management protocols are possible within the scope of the policy to assist in compliance with the relevant legislation.  Some other examples, in addition to that described below, may be found in the ANU's Chemical Safety Manual.  However, whichever risk management procedure is adopted, it must have the fundamental hazard identification and risk assessment and control elements -
1. The identification of hazards associated with the chemicals (reactants, intermediates, and products) and the process,
2. Assessment of the risks associated with those hazards, including the physical properties of the chemicals and the routes of exposure,
3. Practices for controlling those risks to a level that is acceptable, and
4. A feedback, monitoring, or review process to ensure the effectiveness of the assessment and controls.

A written step-by-step guide to working with hazardous substances and developing Chemical Handling Protocols  is available via the link.

Alternate methods to that detailed below, should be approved by the relevant Designated Work Group (DWG) OHS Committee and lodged with the OHS Unit. 

Risk control guidelines using categories

For research and teaching work, these guidelines shall be attached to the beginning of an individual's workbook.

Specific work protocol and risk assessment

The specific work protocol must be documented and a risk assessment undertaken (see ANU's Chemical Safety manual) and the links below.

A chemical handling protocol including risk assessment, safety instructions and approval, may apply to a range of procedural variations, providing this range is clearly defined and does not alter the controls required.

The risk assessment will allocate one of four increasing levels (with sub-levels) of risk to the work  protocol, as follows:

Simplified methods for approximating the ANU Chemical Risk Category can be found by following the process:

1. starting the process
2. filling in the worksheet
3. the risk assessment process using one of two determination methods :

• method A - the health and safety hazards and consequences method
  • inhalation consequences chart
  • skin contact consequences chart
  • eye and mucous membrane consequences chart
• method B - using the CHEMWATCH hazard ratings
  • keyword:  consequence chart

• The assignment of a risk category will be influenced by the nature of the work, the quantities involved, the laboratory facilities available, and the training and experience of both the individuals undertaking the work and their supervisors.
• For risk assignments of category A, category B1, and category B2, the risk assessment category shall be entered into the individual's workbook.  As a minimum the control requirements given below for the relevant category must then be used when undertaking the work.
• For risk assignments of category C1 and category C2, a brief description of the special control procedures, precautions, locations, etc. used to control the specific hazard(s) shall be recorded in the protocol and attached to the individual's workbook before the work commences.  It is mandatory that the proposed system of work be approved by the research group leader or equivalent before work commences.

Risk control procedures 

Category A (low risk) control procedures

Examples of category A (low risk) work -  the use of non-hazardous chemicals, the undertaking of spectroscopic or other physical measurements on small volumes of chemicals, preparation of non-hazardous biological buffers.

• EYE PROTECTION MUST BE WORN AT ALL TIMES where chemicals are being used.
• A laboratory coat or gown must be worn.
• Suitable footwear must be worn.
• Gloves are routinely recommended.
• Appropriate general ventilation or a fume cupboard (or other local exhaust ventilation) is considered beneficial in reducing exposure to gases, vapours and aerosols.
• Mouth pipetting is prohibited.
• Good housekeeping is critical.
• Consumption or storage of food and/or beverages in the laboratory is forbidden.
• ANU staff and post-graduate students must have a competent understanding of the relevant sections of ANU's Chemical Safety series of manuals (http://info.anu.edu.au/Policies/_DHR/Procedures/Chemical_Hazard_Procedures.asp) and any laboratory safety regulations of their Budget Unit before commencing laboratory work.

Category B1 (lower moderate risk) control procedures

Examples of category B1 (lower moderate risk) work -  the small-scale use of low-risk chemicals in solvent transfers, storage, drying, extraction, chromatography, cleaning, and small-scale non-hazardous reactions.

• Category A requirements MUST BE IN PLACE AT ALL TIMES.
• Use work practices that minimise the generation of gases, vapours and aerosols.
• Use of a fume cupboard is advisable.
• Use of gloves is advisable.

Category B2 (higher moderate risk) control procedures

Examples of category B2 (higher moderate risk) work -  the small-scale use of chemicals that are known to be mildly toxic, irritant, or corrosive, the use of chemicals where no toxicological data are available but which are judged to be of low risk on the basis of a generic assessment.

• Category A requirements MUST BE IN PLACE AT ALL TIMES.
• Fume cupboard or Schlenk line must be used.
• Gloves of appropriate chemical resistance (and other physical attributes) must be worn.
• Goggles or face shield may need to be worn to provide improved eye or face protection.

Category C1 (lower significant risk) control procedures

Examples of category C1 (lower significant risk) work -  the use of chemicals known to be significantly oxidising, pyrophoric, flammable, corrosive, toxic, irritant, pungent, sensitising, mutagenic, teratogenic, carcinogenic, violently reactive with water or chemicals, or where no toxicological data are available but which are judged to be of moderate risk on the basis of a generic or comparative assessment.

• Category A and category B2 requirements MUST BE IN PLACE AT ALL TIMES.
• Special personal protection such as goggles, face shield, respirator or clothing may be required.
• Safety shield may be required.
• Special fume cupboard with appropriate scrubber may be required.
• Appropriate administrative restrictions must be put in place including such things as work to be done during standard hours, experienced colleague to be in attendance.
• Other health and safety aspects may need to be considered.
• Specific waste disposal methods must be documented.
• Protocols must be approved by the supervisor or delegate.

Examples of category C2 (higher significant risk) work -  chemicals and procedures that require a special facility or location, such as some potential explosives (including sealed tubes), high pressure reactions, some large scale reactions, and category C1 chemicals considered of higher significant risk. The category would also include chemicals where no toxicological data are available but which are judged to be of significant risk on the basis of a generic or comparative assessment.

• Category A, category B2 and category C1 requirements MUST BE IN PLACE AT ALL TIMES.
• Appropriate special facilities or locations must be provided.
• Other health and safety aspects may need to be considered.
• Specific waste disposal methods must be documented.
• Protocols must be approved by the supervisor or delegate. 

Category D (high risk) control procedures

Category D is judged as high or extreme risk, and requires detailed research and planning.  Category D work must not be undertaken without OHS Unit input and explicit senior management approval.  Examples include - some large scale extremely dangerous reactions, work involving or synthesising explosives, larger scale super-toxic materials/reactions.

[1] Worksafe Australia, List of designated hazardous substances - http://www.ascc.gov.au/
[2] The Australian National University,   General Chemical Safety, OHS Unit, 6th edition 2001.
http://info.anu.edu.au/hr/Training_and_Development/OHS_Training/Advanced_Courses/index.asp
[3] L. Mander,  Laboratory Safety in Chemistry Research Schools.
 Chemistry in Australia  66 (3), 37 – 40 (1999).
[4] Comcare, Letter from M. le Dieu, ACT Manager, 21 July 1998.