Chemical Management

Policy

This policy outlines the requirements for managing chemicals in schools. It provides guidance on identifying hazards linked with chemical use, and on effective risk management.

Summary

• The principal or their delegate must:
  • ensure that all chemicals, dangerous goods and hazardous substances stored at the school are identified, and appropriate controls (including training) are put in place for their storage, use and disposal
  • acquire and maintain safety data sheets for all dangerous goods and hazardous substances stored at the school
  • maintain a chemical register that lists all dangerous goods and hazardous substances that are stored at the school.
• All schools have free access to Chemwatch GoldFFX (staff login required) which is the department’s chemical management platform. Schools can:
  • create and maintain a digital chemical register
  • access and store up to date Safety Data Sheets (SDS)
  • find information that supports risk assessment and hazard identification.
• Small quantities of consumer items brought to school by staff for personal use do not need listing on the chemical register. Such items may include:
  • aerosol deodorant
  • hand sanitiser
  • cosmetics
  • medications
  • food (unless a dangerous good and used for work purposes)
  • most common stationery items. These products still need to be stored appropriately and managed to ensure they are not accessible to students.
• The Statewide OHS Services Team and the OHS Advisory Service can provide free advice on managing risks related to chemicals in schools, including creating a chemical register and accessing Safety Data Sheets.
• The Chemical Management Procedure (in the Procedure tab) must be followed, which sets out the practical step-by-step instructions for implementing this policy.

Details

Chemicals are widely used across schools. When working with chemicals, it is important that considerations are made and steps are taken to ensure safety and compliance. Some products and chemicals, such as PVA glue, playdough and 'education safe' paint, may be low risk. Other products and chemicals may be hazardous substances (dishwashing tablets, bleach), dangerous goods (hand sanitiser, fly spray), or both (methylated spirits), requiring specific management by schools.

Severe injury or damage to property can occur if dangerous goods and hazardous substances are procured and used without understanding and managing their risks. It is important to identify and understand these products so they can be stored, used and disposed of safely.

Common locations where dangerous goods and hazardous substances may be found in schools include:

• art, technology, science classrooms and laboratories
• kitchens and canteens
• cleaners' cupboards and storage areas
• facilities, maintenance, and garden sheds
• photographic dark rooms
• miscellaneous storage areas
• swimming pool, plant, and storage rooms.

This policy does not cover fireworks. For more information, please refer to the Amusement Rides, Attractions and Fireworks policy.

Roles and responsibilities for managing chemicals

Under the Occupational Health and Safety (OHS) Act 2004 (Vic), Occupational Health and Safety Regulations 2017 and The Dangerous Goods Act 1985, managing the risks related to the use of chemicals is a shared responsibility between the department, the principal or their delegate, and school staff.

Department roles and responsibilities

The department must maintain, as much as is reasonably practicable, a safe and healthy working environment for school staff to avoid injuries and prevent environmental harm associated with chemical use.

Principal or delegate roles and responsibilities

The principal or their delegate must identify, assess, control and monitor the risks and hazards associated with chemicals in schools. This includes the procurement, use, storage and disposal of chemicals, including dangerous goods and hazardous substances. This must be done in consultation with school staff who are or are likely to be affected, and the health and safety representative (HSR), where elected.

School staff roles and responsibilities

School staff must take reasonable care for their own health, safety and wellbeing, and that of others who may be affected by their actions or omissions while at work. This includes safely procuring, storing, using and disposing of chemicals, including dangerous goods and hazardous substances.

Any school staff member who identifies or observes a hazard in the workplace must notify the principal or their delegate using the most appropriate method based on current risk and report it in eduSafe Plus (staff login required). Where an unacceptable risk is identified, cease the associated activity and isolate the hazard (where possible and safe to do so).

Key requirements for schools to manage chemicals

The principal or delegate must:

• ensure that all new chemicals and materials introduced into the workplace are safe for use
• assess any new dangerous goods and hazardous substances before they are purchased by completing the OHS pre-purchasing checklist available on the OHS Purchasing policy
• not purchase, store or use any chemicals on the prohibited list found in Guidance sheet 3: Prohibited and restricted chemicals (DOCX)
• follow the advice on restricted chemicals found in Guidance sheet 3
• identify, assess and control the risks for all dangerous goods (see Guidance sheet 2: Dangerous goods classification system (DOCX)) and hazardous substances in consultation with school staff who are likely to be affected and health and safety representatives (HSR), where elected
• maintain a chemical register listing all dangerous goods and hazardous substances present in the school, accessible by all school staff who may be exposed to those substances or goods
• acquire and maintain Safety Data Sheets (SDSs) for dangerous goods and hazardous substances (issued within 5 years) and provide access to staff and other relevant people such as contractors and volunteers
• engage in a process of understanding and rating the risk of all dangerous goods and hazardous substances listed in the chemical register, or equivalent template
• complete a risk assessment for any dangerous good or hazardous substance rated high (3) or above in Chemwatch GoldFFX or high or extreme using the Risk assessment template (DOCX)
• develop safe work procedures (SWPs) which include use, storage and disposal using Safe work procedure templates, when a dangerous good or hazardous substance is assessed as being high or extreme risk (as identified in the chemical register)
• ensure that school staff are not exposed to atmospheric concentrations of hazardous substances that are above the exposure standard. Refer to Chapter 8 – Health monitoring and exposure standards
• correctly store and label all dangerous goods and hazardous substances, including any containers, mixtures of chemicals, decanted chemicals and chemical waste
• provide appropriate storage areas and ventilation for chemicals, which may include flame-proof or corrosion-resistant dangerous goods storage cabinets, fume cupboards, exhaust fans or door relief grills. Refer to Guidance sheet 1: Chemical storage (DOCX) for additional information
• review chemical stores annually and identify chemical waste, expired chemicals and chemicals no longer in use, for collection and disposal. These checks must be scheduled in the school’s OHS activities calendar (XLSX)
• correctly dispose of chemical waste, expired chemicals and chemicals no longer in use. For additional guidance refer to Chapter 12 – Hazardous waste disposal and Guidance sheet 6: Hazardous waste disposal (DOCX)
• ensure dangerous goods or hazardous substances are not disposed of in drains or storm water systems, refer to Guidance sheet 4: Chemical spill management
• have appropriate emergency management equipment and plans in place to effectively manage and respond to chemical emergencies. Refer to Chapter 11: Emergency management on the Guidance tab and Guidance sheet 4, Guidance sheet 5 and Guidance sheet 1 for details on fire extinguisher requirements
• develop and maintain a chemical manifest if dangerous goods on site exceed threshold quantities. Refer to Guidance sheet 1: Chemical storage for additional information
• include placard quantities of dangerous goods stored and used on site in the school’s emergency management procedures as per Guidance sheet 1: Chemical storage
• provide spill kits and containment equipment that is easily accessible. Refer to Chapter 11: Emergency management on the Guidance tab and Guidance sheets 4 and 5
• provide personal protective equipment (PPE) for individuals who use hazardous substances and dangerous goods as required by the relevant safety data sheets
• provide information and access to training for school staff who use hazardous substances and dangerous goods
• include ‘dangerous goods and hazardous substances’ as a hazard in the OHS risk register and review the register annually. Refer to the OHS Risk Planning and Management policy for additional guidance
• report incidents involving chemicals as required in the Managing and Reporting School Incidents (Including Emergencies) policy.

Note - Food or drink containers, such as tomato sauce or milk bottles, must never be used to decant, mix, or store chemicals.

Supports for schools

All schools have free access to build and maintain a chemical register using the Chemwatch GoldFFX chemical management system (staff login required).

Chemwatch can be contacted by:

• Phone: 03 8820 5110
• Email: schoolsupport@Chemwatch.net
• Chat: use the live chat on the Chemwatch website for 24/7 support from a real person
• Emergency Response Hotline: available 24/7 for any staff member while on site in case of an emergency
  • Toll free number: 1800 951 288
  • Alternative number: 03 9573 3188

The Statewide OHS Services Team and the OHS Advisory Service provide a range of OHS supports and can assist with access and the use of Chemwatch GoldFFX, including the build of school chemical registers.

Definitions

Chemical manifest
A list of dangerous goods and quantities stored onsite. This document can be generated from a chemical register and can be used by emergency services in the event of an emergency. It provides emergency services information about the hazards posed by dangerous goods stored onsite. Guidance sheet 1: Chemical storage (DOCX) includes a table with dangerous goods amounts that, when reached, will require a chemical manifest to be generated.

Chemical register
A register that lists all hazardous substances and dangerous goods. It is a legislative requirement that all hazardous substances and dangerous goods are included. It is optional for schools to include non-hazardous chemicals in the register.

Note: ChemWatch training material refers to chemical registers as manifests. Manifest quantities and placarding quantity reports can be generated through the Chemwatch platform.

Dangerous goods
Dangerous goods are substances that may present an immediate safety hazard through exposure to their corrosive, flammable, combustible, explosive, oxidising or other hazardous properties. Dangerous goods can cause explosions or fires, serious injury, death and large-scale damage.

The Dangerous Goods Act 1985 (Vic) defines which substances are dangerous goods.

Below are the 9 classifications with common dangerous examples listed:

1. explosives
2. flammable gases (LP Gas, aerosol cans) and non-flammable, non-toxic gases (CO2)
3. flammable liquids (hand sanitiser, petrol, kerosene, turpentine, flammable paints and so on)
4. flammable and self-reactive solids (sodium, potassium)
5. oxidising substances (bromine, hydrogen peroxide)
6. toxic and infectious substance (bacterial cultures)
7. radioactive material
8. corrosives (hydrochloric acid, citric acid, sodium carbonate)
9. miscellaneous dangerous substance (asbestos, lithium-ion batteries).

For further information, refer to Guidance sheet 2: Dangerous goods classification system (DOCX). The Chemwatch GoldFFX chemical management system (staff login required) hosts videos on how to use filters and run reports for hazardous substances, dangerous goods storage incompatibilities and manifest quantities.

Dangerous goods cabinets (chemical storage cabinets)
Dangerous goods cabinets are manufactured and installed in accordance with Australian Standards. They are specialised, durable storage units designed to securely house hazardous substances, such as flammable liquids and corrosives (acids, alkalis). These cabinets prevent spills, contain fumes, and prevent dangerous chemical reactions.

Emergency management plan (EMP)
A school's documented plan to effectively respond to emergencies and incidents. Schools must have a current EMP, signed off by the principal, reviewed by 1 September each year or following an emergency or critical incident. More information can be found in the Emergency and Critical Incident Management Planning policy.

Essential safety measures (ESM)
Essential safety measures are building safety features such as fire detection and alarm systems, fire doors, emergency lighting and fire hydrants. When maintained correctly, ESMs protect students, staff and visitors in the event of a fire or other emergency. More information can be found in the Buildings and Grounds Maintenance and Compliance – Essential Safety Measures topic on PAL.

Hazardous substances
Hazardous substances are substances that affect a person’s health. This can occur in the moment, such as a burn to the skin or eye, or result from cumulative, long-term exposure, such as skin sensitivity, endocrine disruption, or even cancer.

Hazardous substances are classified based on their health effects, both immediate and long term. They can enter the human body through inhalation, ingestion, or contact through the skin and mucous membranes, such as the eyes. The level of risk depends on the substance, its concentration, toxicity, health effects, and how it is used and handled.

Examples of types of hazardous substances (depending on their concentration) include:

• acute toxins, such as cyanide
• substances harmful after repeated or prolonged exposure, such as mercury and silica
• corrosives, such as sulphuric acid and caustic soda
• irritants, such as ammonia
• sensitising agents, such as isocyanates
• cancer-causing substances (carcinogens), such as benzene and vinyl chloride.

Hazardous substance under the Occupational Health and Safety Regulations 2017, Part 4.1—Hazardous substance, do not included the following if the use of the substance is not related to a work activity:

• food (any substance that is intended for human consumption included beverages, ingredients
• medications
• cosmetics
• tobacco or products made of tobacco
• toiletries and toilet products.

Hazardous waste
The by-product or result of using chemicals. Hazardous waste has the potential to harm humans or the environment, either now or in the future. The requirements for waste chemicals are identical to the chemicals that create them.

Personal protective equipment (PPE)
Items and clothing that are intended to provide individuals with some protection from hazards. Examples of PPE include protective clothing and footwear, eyewear, gloves, masks, or respirators.

Placard
Visual warning (signage) of the hazards associated with the dangerous goods stored on site.

Placarding quantity
Once a certain threshold of a dangerous good is reached, schools will need to display signage (placards). The amount of dangerous goods stored on site must not exceed the limits set out in Schedule 2 of the Dangerous Goods (Storage and Handling) Regulations 2022 (Vic). Schools can also refer to Table 2 (Statutory Quantities) in Guidance sheet 1: Chemical storage (DOCX) for a list of these limits.

Note: Chemwatch training material refers to chemical registers as manifests. Manifest quantities and placarding quantity reports can be generated through the Chemwatch platform.

Safety data sheet (SDS)
A document prepared by the manufacturer, importer or supplier of a dangerous good, hazardous substance or other chemical. A SDS describes the properties and uses of a particular substance, including details about substance identity, chemical and physical properties, health hazard information and precautions for storage, use and safe handling.

Safe work procedure (SWP)
A step-by-step documented procedure on how to safely conduct a task or operation on an item or piece of equipment. See the Resources tab for department templates available.

Risk assessment
The process used to identify hazards, assess the level of risk and put in place effective controls associated with a task or activity.

Related policies

• Amusement Rides, Attractions and Fireworks
• Buildings and Grounds Maintenance and Compliance
• Contractor OHS Management
• Emergency and Critical Incident Management Planning
• Mosquito Risk Management
• OHS Induction and Training
• Occupational Health, Safety and Wellbeing Management in Schools
• OHS Purchasing
• OHS Risk Planning and Management
• Records Management
• Swimming Pools on School Grounds
• Workplace Safety Inspections

Related legislation

• Dangerous Goods Act 1985 (Vic)
• Dangerous Goods (Storage and Handling) Regulations 2022 (Vic)
• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)