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Chemical Manifest Procedure

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Section 1 - Purpose and Scope

(1) This Procedure outlines the requirements at The University of Queensland (UQ) to maintain a manifest of all hazardous chemicals and/or dangerous goods held on its sites and campuses, as per the s346, s347 and s348 of the Work Health and Safety Regulation 2011 (the Regulation). This manifest must be available to Queensland Fire and Emergency Services (QFES), as per s96 of the Fire and Emergency Services Act 1990.

(2) UQ must comply with the requirement to have a current manifest under the Regulation as UQ uses, handles or stores hazardous chemicals in quantities greater than that listed in column 5, Schedule 11 in the Regulation. UQ must also notify the regulator when there is a significant change in the amount held.

(3) The primary purpose of a chemical manifest is to provide information on the quantity, type, and location of hazardous chemicals and/or dangerous goods stored and handled on each campus or site, enabling first responders to respond appropriately if called to an incident.

(4) The manifest is a compilation of the Schedule 11 hazardous chemicals from the local chemical registers or inventories within Chemwatch. The manifest also provides necessary information to determine the placarding of a site, building and/or area (Placarding of Chemical Storage Areas Guideline) which also informs the first responders.

(5) This Procedure must be followed on all UQ campuses and sites and by all UQ workers. The definition of UQ workers is provided in the Appendix.

(6) This Procedure is to be read in conjunction with other related information such as the UQ procedures and guidelines related to occupational hygiene and chemical safety and the information found on the hazardous chemicals and controlled substances webpage.

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Section 2 - Process and Key Controls

(7) All areas and Organisational Units that buy (includes acquisitions and donations), possess, use, store and/or dispose of chemicals must have a register of these substances. The register is mandated for all hazardous chemicals and/or dangerous goods held by an area and/or Organisational Unit.

(8) An Organisational Unit must:

  1. complete and maintain a chemical register in Chemwatch if they hold hazardous chemicals and/or dangerous goods; and
  2. select and appoint a trained worker to complete and/or update the registers.
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Section 3 - Key Requirements

(9) UQ workers must be aware of the need for local chemical registers, to inform the UQ manifest, and must:

  1. plan ahead when working with hazardous chemicals;
  2. risk assess the need to procure a hazardous chemical;
  3. complete a chemical register for their area; or
  4. update a chemical register for their area; or
  5. notify the authorised personnel in charge of the area’s register of their chemical acquisition (preferred option).

(10) Organisational Units that use hazardous chemicals must:

  1. provide UQ workers with suitable induction, information, training and supervision to complete and/or update chemical registers;
  2. have current and accurate chemical registers in their area of responsibility; and
  3. appoint authorised personnel selected and trained to complete and/or update the registers.

Planning to Use a Hazardous Chemical

(11) Where it has been determined that a hazardous chemical will be used, and prior to work commencing, UQ workers must have a clear plan to determine:

  1. the work to be undertaken;
  2. who will undertake the work; and
  3. where and how the hazardous chemicals will be used, stored and disposed.

(12) Current chemical registers must be consulted to avoid duplication, wastage, and excessive chemical holdings.

Risk Assessment - Procuring and Existing Stocks

(13) Prior to commencing work with the hazardous chemical, a risk assessment must be undertaken in UQSafe, to not only assess the overall work task and proposed use, but also the hazards and associated risks in relation to the use, storage and disposal of the hazardous chemical. Refer to the Health and Safety Risk Management Procedure.

(14) Elimination or substitution of a hazardous chemical is the preferred control measure, by using existing chemical stocks of a less hazardous chemical instead of acquiring new stock and increase holdings.

Completion of Registers

(15) Organisational Units that use hazardous chemicals are responsible for ensuring that UQ workers are provided with suitable induction, information, training (including refresher training) and supervision that allows all workers, or an appointed worker within the local area (as the preferred option), to complete, update or maintain the local chemical register.

(16) Organisational Units’ Health, Safety and Wellness Managers (HSW Managers) can facilitate the access to the relevant register (folder/space) within Chemwatch by contacting the administrators (hsw@uq.edu.au) to request the appropriate access for the designated UQ worker within the local area. A username, email and a password must be provided to the administrators to set up access in Chemwatch and it is strongly recommended UQ passwords are not used.

Updating Registers

(17) Trained and appointed UQ workers by the relevant Organisational Unit, will update the register in Chemwatch with the assistance of their HSW Manager and/or Work Health and Safety Coordinator (WHSC), if required. UQ workers granted access to their registers must update local chemical registers as soon as practicable when holdings change or at regular intervals. Influencing factors that determine the frequency for an update include the current holdings of chemicals, requirements of other procedures (e.g. Chemicals of Security Concern Procedure), and legislation. The minimum frequency required at UQ for updates is a biannual update if no other procedure requires a higher frequency, and it should be reflected in a risk assessment after considering all influencing factors.

(18) The update must reflect:

  1. hazard or dangerous goods class for existing and new stock holdings
  2. quantities
  3. missing or used stocks
  4. movements or different storage location of existing holdings.

(19) Complete instructions on how to update in Chemwatch are available online.

Manifest Report

(20) First responders or Regulators may request an up-to-date manifest in the response to an emergency. Chemwatch can generate the appropriate report classed as manifest for the local area.

(21) HSW Managers will be able to produce a manifest (report) within Chemwatch for their area of responsibility. UQ Security and the HSW Division will be able to produce a manifest (report) within Chemwatch for any UQ site.

(22) Only accurate chemical registers will produce an accurate and useful manifest for first responders.

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Section 4 - Roles, Responsibilities and Accountabilities

Heads of Organisational Units

(23) Heads of Organisational Units are responsible for managing work with hazardous chemicals in their area of responsibility. They must work with Managers and Supervisors, academic or professional, to ensure:

  1. there are current and accurate chemical registers in their area of responsibility;
  2. and there are authorised personnel selected and trained to complete, maintain and/or update the registers.

Supervisors, Managers, and Chief Investigators (CI)

(24) Supervisors, Managers and CIs are also responsible for current and accurate chemical registers in their area of responsibility or groups. They are also responsible for:

  1. monitoring Managers and Supervisors’ compliance with this Procedure;
  2. working with the HSW Manager to identify missing substances; and
  3. encouraging persons working with substances to periodically remove unused or waste substances from the location and from the register.

(25) Specific responsibilities in relation to registers include:

  1. maintaining a register of all hazardous chemicals in the work area and ensure Safety Data Sheets (SDS’s) are available;
  2. selecting and appointing the worker and training them to complete, maintain and/or update the register; and
  3. reporting any significant and/or unexplained changes to chemicals holdings and registers to HSW Manager and/or WHSC so they can alert the HSW Division of these significant changes.

Appointed UQ Workers

(26) The following responsibilities are a requirement of the appointed UQ worker selected to complete, maintain and/or update the local registers:

  1. complete prescribed training and/or instruction selected by their Manager or Supervisor to perform the task
  2. complete, maintain and/or update local registers
  3. comply with the requirements of this Procedure.

Health, Safety and Wellness Managers

(27) HSW Managers are responsible for:

  1. facilitating the access to the relevant register (folder/space) within Chemwatch by contacting the administrators (Chemwatch) at hsw@uq.edu.au to request the appropriate access for the designated worker within the local area to maintain the chemical register;
  2. providing Organisational Units or local areas with support and instruction regarding completion of the chemical register, including when they must be completed and how they must be maintained;
  3. provide their area of responsibilities with a copy of their register or manifest if requested;
  4. assessing whether Organisational Units and UQ workers are able to demonstrate compliance with this Procedure and that any compliance issues that are identified are rectified in a timely manner through periodic auditing; and
  5. reporting any significant and/or unexplained changes to chemicals holdings and registers to the HSW Division (hsw@uq.edu.au).

Health, Safety and Wellness Division (HSW Division)

(28) HSW Division is responsible for:

  1. maintaining this Procedure;
  2. maintaining and producing the manifest of UQ sites; and
  3. reporting to the Regulator when there is a significant change in UQ holdings’ amount.
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Section 5 - Monitoring, Review and Assurance

(29) HSW Managers are responsible for monitoring the completion and maintenance of registers in their areas.

(30) The HSW Division is responsible for:

  1. monitoring the maintenance of UQ’s manifest; and
  2. reviewing this Procedure to ensure that it remains accurate and relevant to the needs of UQ.
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Section 6 - Recording and Reporting

(31) Local chemical registers must be recorded within Chemwatch. The UQ manifest is a compilation of the local chemical registers within Chemwatch, as this database is set up to produce it.

(32) Because UQ stores, handles or uses hazardous chemicals in quantities that exceed or are likely to exceed the prescribed manifest quantities in column 5, Schedule 11 in the Regulation, it is classed as a manifest quantity workplace (MQW) under the Regulation. Under s348 of the Regulation, UQ must submit a notification to Workplace Health and Safety Queensland (WHSQ) for a MQW. This notification requires a copy of the manifest and site plan to be included with the notification.

(33) Any significant change to the quantity of hazardous chemicals stored at UQ may require further notification to WHSQ. Therefore, UQ workers are responsible for reporting any significant and/or unexplained changes, to chemicals holdings and registers to their manager or Supervisor or the authorised personnel in charge of the area’s register. Then Managers and Supervisors, either academic or professional, or the authorised personnel in charge of the area’s register are responsible for reporting any significant changes to their HSW Manager. The HSW Managers must report in turn to the HSW Division (hsw@uq.edu.au), as an update of the manifest and/or placarding might be necessary. A notification to the Regulator might also then be necessary.

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Section 7 - Appendix

Definitions

Term Definition
Chemwatch Database used by UQ to access safety data sheets and other information to control chemical risks.
Chief Investigator UQ worker that directs and/or supervises a group or holds research funding or a combination of both (e.g., Group Leaders, Research Leaders, Professors and all academic appointments, and any relevant Senior Managers).
Dangerous Goods (DG) Dangerous goods are substances that are corrosive, flammable, combustible, explosive, oxidising or water-reactive or have other hazardous properties. Dangerous goods can cause explosions or fires, serious injury, death and large-scale damage. Dangerous goods are substances that when transported are a risk to health, safety, property or the environment.
First Responders People with specialised training who are among the first to arrive and provide assistance at the scene of an emergency e.g., firefighters, paramedics, police officers.
Hazardous Chemicals Hazardous chemicals are substances, mixtures and articles that can pose a significant risk to health and safety if not managed correctly. They may have health hazards, physical hazards or both. Examples of chemicals that can cause adverse health effects include toxic chemicals, chemicals that cause skin damage and carcinogens. Examples of chemicals that can immediately injure people or damage property include flammable liquids, compressed gases, and explosives. Infectious substances, radioactive sources and chemicals that are only hazardous to the environment are not considered hazardous chemicals under the model WHS Regulations.
Local Area The local area could be a research or operational group, a laboratory, a floor, a building or a site/campus. Preferably a space that can appropriately hold chemicals (e.g., chemical store, laboratory, floor, building, etc).
Manifest A written summary of specific types of hazardous chemicals with physicochemical hazards and acute toxicity that are used, handled or stored at a workplace. It contains more detailed information than a register of hazardous chemicals as its primary purpose is to provide emergency services organisations with information on the quantity, classification and location of hazardous chemicals at the workplace. It also contains information such as site plans and emergency contact details. It is required for a workplace which stores, handles or uses hazardous chemicals in quantities that exceed or are likely to exceed the prescribed manifest quantities in column 5, Schedule 11 in the Work Health and Safety Regulation 2011.
Organisational Unit A Division, Faculty, Institute, School, Centre, etc.
Register A register is a list of the hazardous chemicals used, handled or stored at the workplace including the safety data sheet (SDS) for each. The register must be made readily accessible to workers or others in a work area who may be affected by the hazardous chemicals at the workplace. The purpose of the register is to provide workers and others access to information about a hazardous chemical used in a work activity including hazards, first aid actions, storage conditions and appropriate personal protective equipment for the safe management of the product.
Safety Data Sheet (SDS) Document containing information on the health, safety and environmental aspects of a material or chemical for the purposes of storing, using and disposing of the substance in a safe way.
UQSafe UQ online system for recording risk assessments, injuries/illness, near miss and hazard reporting and certifications.
UQ workers For the purposes of this Procedure includes:

• staff - continuing, fixed-term, research (contingent funded) and casual staff;
• contractors, subcontractors and consultants;
• visiting academics and researchers;
• academic title-holders, visiting academics, emeritus professors, adjunct and honorary title‚Ä'holders, industry fellows and conjoint appointments;
• higher degree by research students; and volunteers; and
• students undertaking work experience.