In response to the demand created by COVID-19, some Queensland businesses are manufacturing alcohol-based hand sanitisers, or the alcohol (ethanol) used in hand sanitisers. Many of these are doing so for the first time.
Manufacturers must understand their duties under work health and safety laws including:
- those associated with manufacturing flammable liquids
- the safety data sheets (SDS) and labelling requirements for manufacturers of hazardous chemicals.
All risks associated with manufacturing and distilling ethanol or blending alcohol-based hand sanitisers must be managed. Ethanol and isopropanol have fire and explosion risks.
Manufacturer duties include:
- control of vapours and ventilation
- control of potential ignition sources both fixed and portable
- spill containment for containers and manufacturing areas
- fire protection
- signage and placarding
- manifests and emergency planning.
All equipment used to manufacture ethanol or blend alcohol-based hand sanitisers must be fit-for-purpose. AS1940 The storage and handling of flammable and combustible liquids provides ways to control the risks associated with storing and handling flammable liquids including:
- Section 2 - Minor Storage
- Section 4 - Package Storage and Handling Areas
- Section 5 - Storage in tanks (including isotainers used for storage)
- Section 10 - Emergency Planning
- Section 11 - Fire Protection
- Appendix B - Recommendations for the Design and Construction of Blending Plants.
Activities and equipment associated with distilling ethanol or blending, mixing, decanting or bottling alcohol-based hand sanitisers risk generating an explosive (flammable) gas atmosphere. A hazardous area classification must be carried out on any installation or equipment used for these purposes (e.g. distillation vessels, mixing tanks, bottling lines, bulk storage tanks).
A hazardous area classification:
- identifies any areas where an explosive gas atmosphere is expected to exist during foreseeable operations
- categorises any areas identified as hazardous in terms of their ignition characteristics to allow for ignition source isolation or engineering protection.
The classification of hazardous areas should be carried out by a competent person and in accordance with the methodologies in AS/NZS 60079.10.1: The classification of hazardous areas- Explosive gas atmospheres. For workplaces without in-house expertise, view the list of Hazardous Area Classification Specialists.
Hazardous areas require strict control over ignition sources. Non-rated electrical equipment can act as an ignition source so you must ensure electrical installations within hazardous areas are hazardous area-compatible (EEHA requirements under electrical safety laws).
Compiling a 'verification dossier' (the design, installation and testing information and conformity certificates for electrical items installed within the hazardous area) is part of this process. Electrical installations within hazardous areas must be inspected by an accredited auditor before being energised. View the list of accredited auditors.
Workplaces with ethanol, isopropanol or any other category 2 (PGII) flammable liquid in quantities greater than 250 litres must have placarding, including:
- outer-warning 'HAZCHEM' placards at vehicle entrance points
- internal placards for areas where flammable liquids in quantities greater than 250 litres are stored
- tank placards for storage tanks.
Read more information on Placarding for Hazardous Chemicals (PDF, 0.89 MB).
Workplaces with ethanol, isopropanol or any other category 2 (PGII) flammable liquid in quantities greater than 2500 litres must meet manifest quantity workplace requirements, including:
- compiling a manifest of hazardous chemicals that complies with Schedule 12 of the WHS Regulation
- storing a manifest in a red weather-proof container adjacent to the main entrance of the workplace so that it is available to emergency services
- notifying and supplying a copy of the manifest to Workplace Health and Safety Queensland (WHSQ) using Form 73 – Notification of a manifest quantity workplace (PDF, 2.51 MB).
- sending a copy of an emergency plan to QFES at QFES.EMPlanning@psba.qld.gov.au.
Classification and packing duties
Manufacturers of ethanol to be used as an ingredient in hand sanitisers or alcohol-based hand sanitisers must meet the requirements for manufacturers of hazardous chemicals (sections 329–335 of the WHS Regulation) including:
- using the globally harmonised system of classification and labelling (GHS) to determine hazard classes and categories
- producing an SDS
- packing hazchems into suitable containers.
This includes ensuring that hazardous chemicals are packed into containers that do not usually contain food or beverages and cannot be mistakenly identified as containing food or beverages.
For more information about SDS's and GHS classification see the Preparation of safety data sheets for hazardous chemicals code of practice 2021 (PDF, 1.05 MB) and general advice about the Globally Harmonised System.
GHS classification and SDS production are the first and most important steps for ethanol and alcohol-based hand sanitiser manufacturers. For manufacturers without in-house expertise, there are consultants who can provide this. View the list of Industry Consultants for SDSs and Storage and Handling Systems.
Labelling duties for manufacturers and suppliers of ethanol and isopropanol
GHS labelling in accordance with Schedule 9, Part 3 of the WHS Regulation is required for ethanol and isopropanol that is packaged into containers to be used in the manufacture of hand sanitisers. The Labelling of workplace hazardous chemicals code of practice 2021 (PDF, 1.26 MB) provides more information.
Labelling duties for manufacturers and suppliers of hand sanitisers
GHS labelling is not required for hand sanitisers that have a cosmetics or therapeutic goods exemption under section 335 of the WHS Regulation. Hand sanitisers packed into larger containers (e.g. 5 L) intended to be decanted into a dispenser or dispensing container at a workplace do require GHS labelling in accordance with Schedule 9, Part 3 of the WHS Regulation.
The Therapeutic Goods Administration (TGA) advises that hand sanitisers are regulated as either cosmetics or a therapeutic goods depending on extent of their health claims. Read information from TGA about the manufacture of hand sanitisers.
On 28 March 2020, the TGA issued a therapeutics goods exemption for two hand sanitiser formulations published by the World Health Organization. The exemption applies to TGA licensing and includes safety and labelling requirements for the exempted formulations. For these labelling requirements see Schedule 2 of the Therapeutic Goods (Excluded Goods- Hand Sanitisers) Determination 2020.
Read Labelling advice for cosmetics and the Supplier Guide for Ingredients Labelling on Cosmetics by Australian Competition and Consumer Commission.
Transporting flammable liquids
Section 14 of an SDS provides transport information for the hazardous chemical. The transport of dangerous goods such as Class 3 flammable liquids is not regulated by WHSQ. Read information about the laws for transporting Dangerous Goods in Queensland.
- Hazardous chemicals
- Fire and explosion risks
- Manifest quantity workplaces
- Hazardous chemical notifications
- Industry consultant for hazardous chemicals
- Emergency Planning (QFES)
- Hand sanitisers and COVID-19 (TGA)
- Australian Competition and Consumer Commission's Supplier Guide: Ingredients Labelling on Cosmetics
- Transporting Dangerous Goods
- SAI Global Info Store - AS1940:2017
- SAI Global Info Store - AS/NZS60079.10.1:2009
- SAI Global Info Store
For more information, please contact our Hazardous Chemicals Unit on 07 3738 5010 or contact an industry consultant for hazardous chemicals.