The first thing you really ought to know (it made us feel better, anyway!), is that even the experts are acting like headless chooks on this issue. If you think this is a complex moving target, you are right.
Table of Contents
- Previous DG Licences
- Step 1: List the Substances
- Step 2: Classify the Substances
- Step 3: Check Trigger Points
- Step 4: Can you avoid triggering requirements legitimately?
- Further down the track
Your current DG licence (if you have
one) is not a good indicator of what conditions will
apply under the HSNO Act. First, it is probably inaccurate
and out of date. Second, the substances are subject
to new classification criteria. Third, there may be
new substances you have to add. Fourth, by adjusting
your quantities, types of use and locations, you may
not need to get a new certificate.
If you have no previous licence, then, from April 1st
this year, you are simply a new location and where necessary,
will need to establish certificates under the new rules
effective immediately.
Make an inventory of your current
Hazardous Substances. What are they, how do you use
and handle them, what quantities, size of container?
What may have been considered Dangerous Goods under
previous legislation may no longer be under HSNO and
vice versa. Look again at things like flammable liquids,
corrosives, toxics and gases.
A good clue is if your substance has a UN number, or
the data sheets include any risk or caution wording.
Don’t be too concerned at this stage. HSNO requirements
are determined by a combination of risk, quantity and
type of use, so having a hazardous substance doesn’t
automatically mean you will be “captured”
by the rules. [ Get
expert help ]
Step 2: Classify the substances
Classify your substance. You may need
expert help here, because the technicalities are tricky.
For example, Class 3 Flammable liquids will require
Flash Point and Initial Boiling Point information. Generally,
the higher the hazard classification, the smaller the
quantities that will trigger certification requirements.
Step 3: Check trigger points
Check to see if the quantity, classification and type of use triggers the need for certification and special conditions. This is really quite a specialized area, for which you really do need proper advice. [ Click here ]
Step 4: Can you avoid triggering
requirements legitimately?
This is also an opportunity to see if you can reduce stocks below the trigger points. For example: As a rule of thumb, reducing fork lift 19 Kg LPG cylinders to 5 maximum (not including the one on the vehicle) will avoid the need for Approved Handlers and Location Certificate. Reducing solvent thinners to less than 100 litres does the same. Under some circumstances, you may be able to achieve the same result by relocating the substances.
- For substances NOT transferred to ERMA’s list, you will have to roll over your DG licence once or twice more.
- If you have highly hazardous substances or large quantities of flammable liquids, you have until December 31st to fully comply, otherwise, ERMA has probably already given you a compliance date. (As soon as you have your new Location certificate, it replaces your DG Licence).
- Approved Handlers must be established before the Location Certificate. They can be appointed initially on a Transitional Certificate, provided you can vouch for previous and recent experience handling the substances under previous legislation
- Emergency Management will be part of certification by 31 March 2005
- Identification and Packaging requirements will be part of your certification by 31 March 2006.
If this all still looks too difficult, the trick is to take it a step at a time. You can get limited assistance at each step to keep costs down and retain ownership of the solution. We can help to identify key issues and provide implementation information if you wish.
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