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HSNO Management, the persons in charge, and training.

SDS, MSDS, PPE, and HASW all sound like the acronym STD and in many ways, they are, as they can also have a nasty impact on the mental, physical implications on an individual, a business and the environment.

All four are acronyms that are applicable to the subject of health and safety in the workplace, and the SDS (or Safety Data Sheets) are too often the least understood and least used by employers and their employees.

The HSNO Act 1996

The introduction of the Hazardous Substances and New Organisms Act (HSNO) in 1996 required that any business using chemicals in its operation must manage this responsibility from:

design;
development and testing;
manufacturing;
packaging;
delivery;
storage;
application; to
the safe and responsible disposal of unwanted chemicals, containers and packaging.

Effective HSNO management is now one of the focal points of Worksafe NZ, who are developing strategies to ensure that this is being achieved by businesses.

Hazardous Substances and Storage

If your business uses chemicals in its operations, you have a responsibility to store the chemicals so that they are secured, controlled, managed and do not impact on the environment.

Has your business carried out an audit of your chemical storage facilities in the last twelve months?

If not, I recommend you obtain a checklist and do this.

The following are several points to consider:

Has the storage facility been approved by a competent person or local body?
Is the signage correct and legible?
Is the storage facility adequate and can be locked and secured?
Is it adequately bunded?
Is there an inventory of what chemicals are stored?
Are copies of the applicable SDS available?
Are powder and liquid chemicals separated, and powders stored on the higher shelves?
Is the labelling correctly attached to containers and easily read?
Is the storage facility clean and tidy?
Has a spill kit been made available and selected employees been trained in its use?
Have approved handlers been appointed and been trained?

The person in charge

Who oversees the management of your chemicals?

All businesses need to identify a person in charge to manage the hazardous substances stored and used at the workplace. The person in charge is responsible for ensuring that the hazardous substances under their control are correctly managed and do not adversely affect the environment or the health and safety of people.

Who is the person in charge?
The person in charge could be the owner, lessee, sub-lessee or occupier of the place. In effect, it is the person who is in control of the relevant part of the site.

Duties of the person in charge.
The specific duties of the person in charge are set down throughout the hazardous substances regulations. For example, the person in charge must:

Identify all hazardous substances present and maintain a hazardous substances inventory;
Make certain that people handling the substances are trained or supervised;
Ensure information is readily available to the people handling the substance in the form of labels, safety data sheets and signs;
Ensure that emergency arrangements are in place to deal with any potential emergency; and
Obtain and keep up to date all necessary test certificates.

Safety Data Sheets (SDS)

A key part of chemical management, especially the use of the chemical by employees, are the safety data sheets (SDS). These 6-10 page documents are required to be provided by the chemical supplier and they do contain information about:

The makeup of the chemical;
The safe storage of the chemical;
The safe use of the product and application;
What personal protective equipment (PPE) is required; and
What to do in an emergency.

Availability
Too often, SDS sheets are either held in a manager's office, a dusty manual, a cupboard, or another location, and are not readily available in the case of an emergency. These sheets must be current and/or no older than 5 years.

Safe Use and Training

The Health and Safety at Work Act 2015 Section 36 (Primary duty of care) sets out the responsibilities of the PCBU and officers to inform employees of the safe use of materials and substances.

This should be carried out prior to the employee using or being exposed to the chemical or substance.

Without limiting subsection (1) or (2), a PCBU must ensure, so far as is reasonably practicable, —

the provision and maintenance of a work environment that is without risks to health and safety; and
the provision and maintenance of safe plant and structures; and
the provision and maintenance of safe systems of work; and
the safe use, handling, and storage of plant, substances, and structures; and
the provision of adequate facilities for the welfare at work of workers in carrying out work for the business or undertaking, including ensuring access to those facilities; and
the provision of any information, training, instruction, or supervision that is necessary to protect all persons from risks to their health and safety arising from work carried out as part of the conduct of the business or undertaking; and
that the health of workers and the conditions at the workplace are monitored for preventing injury or illness of workers arising from the conduct of the business or undertaking.

This clause is all encompassing and employers should take heed of what this requires of them for the safety of their employees and their businesses.

Using the SDS as a training tool

Too often, the importance of SDS is missed as a training tool for their employees by managers and supervisors. Why? Because they don't understand their importance, they are not accessible, out of date or too difficult to use and read. If an employee has been delegated the responsibility to manage the company's chemicals, then this should not be a problem.

An issue that too often arises is that the safety data sheets are too complex (6-10 pages) and the employee is expected to read and understand them. When one considers that NZ has a 40% numeracy and literacy problem in its workforce, it is irresponsible to do this.

The key safety issues that the employee needs to know about when using any chemicals are:

What PPE must be worn;
Where the chemical is stored;
How to use and apply it safely;
What the emergency procedures are and where to go for help;
The safe storage of the chemical; and
The safe disposal of packaging and containers.

To achieve this, I suggest that you highlight the relative sections on the SDS and place this information at the front of the SDS and make it available at the worksite. Another solution is to use a proven and cost effective software product like Hasmate. This web based compliance management program has now made it easier for all businesses to manage the sometimescomplex issue of chemical management. This will now provide any business with a management tool to provide current chemical information, a training process and amongst other things, the ability to provide instant reports and a quick filtering ability for future HSNO auditing purposes.