For businesses in the Work Health and Safety jurisdictions that adopted the Global Harmonised System of Classification and Labelling of Chemicals (GHS) for determining placard and manifest levels, the change from using Dangerous Goods Packing Groups to the GHS hazard categories has been a confusing shift.
Previously, the system of record for classification of dangerous goods was the Australian Code for the Transport of Dangerous Goods by Road & Rail (ADG). The ADG provided clear guidance in Part 3.2.3 as to the Class or Division of a dangerous good, and its Packing Group. An occupier then only had to identify the threshold in the appropriate schedule, within their Dangerous Goods Regulations, to determine whether they required placards for buildings or storage areas, or were required for the development of a manifest.
With the introduction of GHS classifications and the alignment of these to placard/manifest quantity thresholds in the various Schedules, there have been changes, especially for some very common dangerous goods. For example, Caustic Soda 46% solution is a Class 8, Packing Group II in the ADG. However, if one uses the Hazardous Chemical Information System's (HCIS) GHS classification, it is classified as a Skin Corrosion - Category 1A or an equivalent to Packing Group I. The same shift of hazard applies to higher concentrations of Sulphuric Acid and Nitric Acid. For a business that stores 1000L of Caustic Soda at its premises, they are now required to not only install placards, but also create a manifest, as the manifest threshold for Category 1A corrosives is 500L, not 2500L, when the chemical was a Packing Group II.
It is also important to note that the HCIS is regularly updated and a chemical's classifications can change. An unusual chemical, Acrolein, was originally classified in the HCIS issued in December 2015, as an Acute Toxicity (Inhalation) Category 2. In the most current online HCIS, it is now an Acute Toxicity (Inhalation) Category 1, which aligns with the Packing Group I listed in the ADG.
One hopes the chemical management systems that businesses utilise have incorporated these changes.
Ian Good - COHSProf
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