The Work Health and Safety Regulation 2011 covers workplace hazardous substances and dangerous goods under a single framework for hazardous chemicals.
Under the Work Health and Safety Regulation 2011 (WHS Regulation), all hazardous chemicals (manufactured or imported after 31 December 2016) must be classified and labelled in accordance with the globally harmonised system for the classification and labelling of chemicals (GHS).
Hazardous chemicals (hazchem) is the name given to the group of chemicals classified as hazardous for use at workplaces according to the GHS. The GHS classification system focuses on chemicals with acute and chronic hazards to health and safety in the workplace.
Before the GHS, chemicals that had health hazards were determined using the NOHSC approved criteria for classifying hazardous substances and chemicals that had physical hazards were identified according to the Australian Dangerous Goods (ADG) Code. The ADG Code is the system for classifying goods that are dangerous for transport. The GHS essentially combines the two chemical classification systems and provides a corresponding labelling system for use in a workplace setting.
Dangerous goods (DG) is the name given to the group of chemicals and articles (i.e. goods) classified as dangerous for transport by road, rail, air or sea. The DG classification systems focus on goods with predominately acute hazards to safety, the environment or the road and rail transport vehicle.
DGs transported by sea are classified according to the International Maritime Dangerous Goods Code (IMDG) Code and DGs transported by air are classified according to the International Air Transport Association (IATA) DG Regulations. The DG classification systems also have their own labelling (and marking) systems for use in a transport setting.
Interactions between hazchems and DGs
Many chemicals are both hazchems under the WHS regulations and DGs under the transport regulations, particularly those with acute physical hazards. Such chemicals need to comply with the GHS labelling requirements (WHS) and the ADG Code (transport) labelling and marking requirements..
To find out whether a chemical has been classified as a hazchem and/or a DG, refer to the chemical's safety data sheet (SDS):
- section 2 for hazchems
- section 14 for DGs.
(Note: under the WHS Regulation SDSs are only mandatory for hazchems). Where an SDS is not available, always refer to the manufacturer or importer for further information.
Because many hazchems are also DGs and because most hazchems will need to be transported from one workplace to another workplace throughout their lifecycle, there are times when the two labelling systems interact, particularly for larger containers such as 200 L drums and IBCs. The WHS Regulation and Labelling of workplace hazardous chemicals code of practice 2011 (hazchems) have included the following exemptions and advice about how to handle these interactions:
- Section 335(4) of the WHS Regulation states that whilst hazchems are in transit they do not require hazchem (GHS) labelling, e.g. hazchems imported into Australia do not need GHS labels whilst they are in transit from an import terminal to their importer's storage warehouse. However, once a hazchem arrives at a workplace and is no longer in transit, a GHS label is required on the hazchem container at this point in accordance with section 335 of the WHS Regulation. In transit at a workplace means a hazchem in a container that is not opened, used or kept at the workplace for more than five consecutive days. Hazchems in transit that are also DGs shall comply with any labelling and marking requirements required under the ADG Code and will require information such as the proper shipping name (PSN), UN number and dangerous goods class label (i.e. diamond).
- Section 3.7 of the Labelling of workplace hazardous chemicals code of practice 2011 states that hazchems that are also DGs and transported by road or rail must comply with the labelling or marking requirements that are specified in the ADG Code.
- Section 2.4 of the Labelling of workplace hazardous chemicals code of practice 2011 states that GHS hazard pictograms (red, white and black diamonds) may be substituted by the equivalent ADG Code class labels (coloured diamonds) however, never use both in the same label. A comparison of the GHS hazard pictograms and the ADG Code are shown in Appendix G. (Note: not all GHS hazard classes have an equivalent ADG Code class label.)
- Section 3.7 of the Labelling of workplace hazardous chemicals code of practice 2011 states that the ADG Code recognises the GHS labelling system as an appropriate labelling system for inner packages, e.g. smaller containers that are packed into an outer cardboard box, of DGs during transport. This is reinforced by section 126.96.36.199.13 of the ADG Code.
Transport of dangerous goods by road or rail must be done in compliance with the ADG Code and relevant transport laws.
The Queensland Department of Transport and Main Roads and the Commonwealth Department of Infrastructure and Regional Development provide information on the transport of dangerous goods.