The COVID-19 pandemic may force shutdown or reduced operations at workplaces where there are hazardous chemicals. This safety alert is about planning to manage the risks from hazardous chemicals when temporarily shutting down or reducing the extent of your operations due to the coronavirus (COVID-19) pandemic.
Note: A ‘person conducting a business or undertaking’ (PCBU) is a broad term used throughout work health and safety legislation to describe all forms of modern working arrangements, which we commonly refer to as businesses.
PCBUs that store or handle hazardous chemicals may need to temporarily shut down or significantly reduce their operations as a result of the coronavirus (COVID-19) pandemic, including in response to public health directions.
When ceasing or significantly reducing operations, and when resuming normal operations, PCBUs must continue to safely store and handle hazardous chemicals.
Significant risks arise from the presence of hazardous chemicals, especially when temporarily ceasing or significantly reducing operations including:
- fires and explosions associated with flammable gas systems, for example gas fired heaters
- fires, explosions and leakages associated with flammable liquids, for example petrol, kerosene, turpentine, flammable paints
- exposure to corrosive material, for example acids, alkalis
- materials with the potential to degrade or which are incompatible with other materials
- accumulation of non-flammable non-toxic gases that are asphyxiant, for example carbon dioxide and nitrogen
- the presence of asbestos or asbestos-containing materials
- ‘benign’ materials that, when degraded or contaminated, become hazardous, for example batteries, garden or agricultural chemicals such as ammonium nitrate.
PCBUs must identify the hazards related to hazardous chemicals that are present at their premises, assess the risks, and implement risk controls. The Code of practice for Managing risks of hazardous chemicals in the workplace provides practical guidance on how to comply with obligations for the safe storage and handling of hazardous chemicals.
Prior to shutting down or significantly reducing operations, PCBUs storing or handling hazardous chemicals should eliminate risks by removing or consuming hazardous chemicals where practicable.
If this is not practicable, PCBUs should:
- consider the minimum staffing requirements to ensure the continued safe management of materials on the premises and operations of the plant including safe shutdown and start up if required depending on the situation
- manage workload of workers to allow breaks and timely shift changeovers to keep workers at ease and reduce the perception that abnormal situations require extra focus, extra working hours and field presence but this is not the case for all workers at all levels of organisation
- defer plant modifications and / or management of change processes and limit them only to routine calibrations, inspections necessary to maintain safe plant operation
- make sure all staff on site are fully informed of the risks associated with the dangerous goods and the risk controls implemented during reduced operations
- make sure safety data sheets (SDS) are available for all dangerous goods on the premises
- make sure package markings are clearly visible, including to emergency services
- make sure buildings subject to shutdown are adequately ventilated so that flammable or toxic materials cannot accumulate
- make sure processes that rely upon a regular rate of consumption (for example LNG, cryogenic ammonia) do not heat up to a hazardous degree as a result of reduced operations
- make sure the safety aspects of security inspections are sustained (for example physical inspections, CCTV, thermal imaging)
- consider reviewing storage locations
- make sure isolations are completed (for example, valves are closed)
- make sure pipework is flushed as required
- confirm that fire systems are functional
- make sure that the premises have outer warning placards, as required, that are in good condition and visible to emergency services
- maintain the site manifest up to date and in a location accessible to emergency services.
Further guidance is provided below regarding the safe storage of hazardous chemicals during a shutdown or reduced operation.
PCBUs should also plan to manage risks that will arise when returning to normal operations following reduced operations or shutdown. Both shutdown and start-up are process conditions, which need special attention to prevent the occurrence of chemical incidents. Recent severe incidents in India (Visakhapatnam) and Italy (Ottaviano) were caused by failures to make sure robust controls were implemented prior to restarting a process after shutdown.
Under the Work Health and Safety Act 2011, PCBUs must, so far as is reasonably practicable, ensure the health and safety of workers and others.
Chapter 7 of the Work Health and Safety Regulation 2017 sets out legal duties for PCBUs at a workplace as well as manufacturers and suppliers of hazardous chemicals. The Code of practice for Managing risk of hazardous chemicals provides practical information on how to comply.
Further guidance regarding the safe storage of hazardous chemicals during a shutdown or reduced operations
General hazard controls
- stored in approved cabinets or dedicated packaged goods stores when above minor quantities: refer to relevant Australian Standard
- arrangements for spill containment are in place when above minor quantities storage
- appropriate firefighting equipment is available
- appropriate PPE is available and in good condition
- appropriate first aid (and emergency eye wash if Class 8) is nearby
- user/employee training and procedures
- signage and placarding is present
- manifest requirements are checked
- notification requirements checked
Specific hazard controls for classes of dangerous goods (hazardouschemicals)
Class 1: Explosives
- all explosives are stored in compliant receptacles or licenced magazines
- explosives are adequately segregated from flammables
- security plan is fully operational
Class 2: Compressed gases
- all control valves are shut tight
- gas cylinders are secured to prevent them falling over
- gases are stored in well ventilated areas
- flammable and toxic gases are adequately segregated
- flammable gas is adequately segregated from oxidizing agents
Class 3: Flammable liquids
- stored in cabinets approved for use with class 3 dangerous goods or dedicated packaged goods stores
- stored away from ignition sources
- adequately segregated from oxidizing agents, toxics and corrosives
- if stored in cold room below flash point, systems are in place to respond to faults in ventilation/cooling or to de-energise all electrics within the cold-room
- adequate spill containment
Class 4: Flammable solids
- all spills are cleaned up to prevent spontaneous combustion
- packages are well sealed/airtight
- stored in area where they cannot get wet
- adequately segregated from oxidizing agents, toxics and corrosives
Class 5: Oxidizing agents
- adequately segregated from flammable liquids, toxics and corrosives
- temperature controls and monitoring are in place to ensure organic peroxides are stored well below their self-accelerating decomposition temperature (SADT)
- class 5.1 agents are stored in a dry and well-ventilated area, away from ignition sources and spill equipment
Class 6.1: Toxics
- adequately segregated from flammables and corrosives
- spills are cleaned up and open packages are sealed
Class 8: Corrosives
- adequately segregated from flammable liquids and toxics, and stored in approved cabinet or packaged goods store when above minor quantities
Class 9: Miscellaneous
- goods packages/containers are sealed in areas that cannot enter stormwater systems
Note: The Code of practice for managing risks of hazardous chemicals in the workplace provides additional detail regarding these hazard controls.
Code of practice for Managing risks of hazardous chemicals in the workplaceBack to top