In the past managers have relied on ‘gut feeling’ and ‘intuition’, usually based on their experience and training, to make decisions related to workplace hazardous substances. Typically problems were addressed on an ad hoc basis, and ‘crisis management’ prevailed.

In many instances major incidents have resulted from the lack of systematic approach, to problem solving and implementation of improved methods of use of these materials.

When a manager makes a decision based on ‘gut feeling’ or ‘intuition’, there is an emotional component involved, related to apprehension. I suggest that this apprehension, is often derived from some appreciation of the risks arising from exposure to a hazard. It is useful to appreciate that risk is based on the likelihood of an incident occurring involving loss, and the consequences (severity) of the incident.

Some managers are aware that National Codes exist for the purpose of managing hazardous substances, and even refer to these codes when making their decisions. Those who don’t take this approach, run the risk of having the content of the code revealed to them in court, when a fatality occurs due to their decision, or lack of decisiveness.

Compliance with legal regulations is an issue, which managers do not address well. The regulations have varied from state to state in Australia. The National Codes provide a basis for ‘harmonisation’ of legislational codes. State Government officials often participate on Standardisation Committees, and the regulations in each state are generally written to implement the National Code. Variations from the National Code, which exist in State Legislation, can create problems for managers.

It is useful for organisations to have reasonably generic, documented policies for management of hazardous substances, and in particular ‘Dangerous Goods’, as part of their management system. These policies demonstrate that the organisation has vision, and give guidance relevant to the Chief Executive Officer’s requirements on these issues.

A normal policy for a group of workplace hazardous substances, such as Dangerous Goods Class3 subrisk 6 (solvents), should include reference to the applicable or preferred National (or International) or industry Code (e.g. Australian Standard AS1940 – The storage and handling of flammable and combustible liquids). It should require risk assessments and proactive implementation of the ‘Hierarchy of Controls’ based on the Code, where practicable.

It should also require ‘Cost/Benefit’ analyses, and risk prioritisation, so that resources are used efficiently. A requirement, should be included for implementation of the policy in operating procedures where appropriate, and continuous improvement of such policy and procedures. This requirement should nominate responsible (and accountable) personnel.

There should also be a policy requirement for compliance with local laws, this should state that compliance is a minimum requirement.

The absence of a relevant National Code for a particular type of hazard, presents a particular problem, which results in ‘writing the code backwards’. Legislative requirements can form the basis of policy in this situation, which may result in the use of a large amount of imagination (on the part of the manager), to anticipate the intent of the legislator. (Most legislation is written to cope with particular types of risk.)

It is impossible to manage hazardous substances safely, solely on the basis of the old prescriptive Dangerous Goods legislation. The impending performance based Dangerous Goods legislation (which will require risk assessments and maintenance of registers) should change this beneficially.

The development of well considered, and documented (internal) organisational policies, will provide the guidance required to improve safety and productivity, to an acceptable level, while promoting compliance with the new laws.

Alan Cotterell

6^th August 1999