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| NewsBrief | ||
No.51 - April 2006 |
TM |
As you read this, a key compliance requirement is only a few weeks away. The Dangerous Goods (DG) Licence, covering the UN Dangerous Goods present on site, is a long-standing, widely recognised “Operating Licence” issued to approximately 15,000 businesses.
The Hazardous Substances Regulations require DG Licences to be replaced with Location Test Certificates by 30 June 2006. Businesses have had up to two years’ notice of the need to progressively replace their DG Licence. Despite this generous lead time, it appears only 25% of the approximately 12,000 valid DG Licences have been replaced to date.
Un-licenced sites not only face prosecution under long-standing workplace health and safety regulations, but also receive greatly increased penalties under the Hazardous Substances Regulations. There is also the very real prospect of not receiving product as chemical suppliers do not intend to break the law by knowingly delivering supplies to non-compliant sites.
Four earlier compliance requirements fell due on 01 April 2005. Enhanced performance requirements affecting Labelling, Safety Data Sheets (SDS), 24/7 Emergency Contact Numbers, and Packaging specifications are now a reality.
The latest four requirements falling due on 30 June 2006 are:
Much of the practical “How To” advice needed to comply with the new and upgraded performance standards, including SDS, Labelling, Emergency Management, and 24/7 Contact Number requirements described in NZCIC draft Codes of Practice, still await ERMA approval. Nevertheless, these compliance obligations are (or should be) no surprise to conscientious employers already fully aware of their responsibilities, and who are managing compliant sites.
There is to be a concerted push in the next couple of months to identify and upgrade non-compliant sites. Let’s each do our best to ensure NZCIC Members and their customers are on the right side of compliance and continue to lead!
A word of caution: before picking up the phone and booking a Test Certifier, ensure you have an accurate list of the maximum quantities of the Hazardous Substances and their HSNO Classification you have on site, together with a description of whether you store, manufacture, or retail them. Brief the Test Certifier on your inventory prior to the visit.
This will ensure you get a Test Certifier who is qualified to deal with your particular activities and chemical inventory.
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