What is HSNO?
- HSNO, or the Hazardous Substances and New Organisms Act 1996, was the legislation that governed the safe use, storage, and disposal of any substance that posed a significant hazard to people, property, and/or the environment. Since December 1st 2017, the controls and regulations that related to workplaces were shifted to the Health and Safety at Work Act 2015 (HSWA), while environmental controls and non-workplace controls continue to be governed by HSNO. HSNO also relates to Hazardous substance approval, which is required before any product can be sold or used within NZ.
Hazardous Substances? Don’t you mean ‘Dangerous Goods’?
- Not at all. HSNO is aligned with the UN Regulations for Transporting Dangerous Goods (UNRTDG) but Hazardous Substances extend a little further beyond those parameters. It’s possible to have a hazardous substance that isn’t considered DG. For example, a skin irritant is not a Dangerous Good, but it is a Hazardous Substance under HSNO.
What does a Hazardous Substance Site Assessment entail?
- The assessment involves coming to your site, looking over appropriate documentation, talking with people in charge of or involved with the hazardous substances, walking through the site, and making note of any gaps in compliance. Then we can compile a report which will inform you about what needs to be replaced or implemented like signs, certification, documentation, segregation, etc.
How do I know if my product needs EPA/ACVM approval?
- Easy: If it’s being imported or is being manufactured in New Zealand and is classified as hazardous, it needs EPA approval, either as an individual approval assigned by EPA or allocation to a Group Standard. The EPA Approval and ACVM Registration processes can be a bit difficult to navigate or understand, but our consultants are well versed in the details and are ready to help.
Why do I need an SDS? Is that the same as an MSDS?
- Yes, a Safety Data Sheet (SDS) is the same as a Material Safety Data Sheet (MSDS). If you have any Hazardous Substances on your work site (including retail), then you are required to give your employees access to the substances’ SDS. They must be NZ compliant. Electronic copies are fine, but it’s even better to have hard copies available. Alternatively, you can supply your workers with one page Condensed SDSs, but a copy of the SDS must remain on site for reference.
What’s so different about NZ compliant SDS’s?
- NZ compliant SDS’s have information that is relevant to NZ regulations: HSNO codes, contact details for suppliers/importers/manufacturers, emergency numbers, and appropriate regulatory information. A foreign SDS may still be useful but without the NZ information, safety and accountability are impaired. It’s a simple process to update them and we can help with that.
What’s a ‘Location Compliance Certificate’ and where do I get one?
- A Location Compliance Certificate certifies that the company it’s issued to is abiding by all the controls set in place for the quantity and types of hazardous substances they’re storing and using. This is normally for Classes 1-5 as the location itself needs to be considered when storing hazardous substances that can affect property. However, in 2019, Classes 6 and 8 will also need to be considered for Location certification.
- TCC (NZ) Ltd doesn’t certify locations currently. Instead, we work with other Compliance Certifiers who are capable of issuing Location Compliance Certificates and prefer others to concentrate on the Certified Handler and basic chemical training work. Drop us a line and we can get you in contact with someone local who is willing to help you.
What’s a Hazardous Substance Inventory and why do I need it?
- Simply, it is a list of all Hazardous Substances on the worksite, regardless of their use (or lack thereof), and must include several qualities, such as maximum quantities, location, storage conditions, etc. We also recommend adding the substances HSNO code string, but this is not a hard requirement. The Inventory informs Health and Safety enforcement officers of the hazards present on the site and allows the Compliance Certifier to make sure every control is being accounted for.
I need a Dangerous Goods Licence. Do you do those?
- No, a Dangerous Goods licence is specifically for transport and we do not deal with transport training. Sometimes people say “Dangerous Goods licence” when they mean “Certified Handler Certificate”, so you may want to double check to ensure you (and whoever gave you the idea) are looking for the right certification.
Do I need a Certified Handler for LPG Swap-A-Bottle?
- No, since the Approved Handler scheme was dropped on December 1st, 2017 all you need is demonstrable proof that you have been trained in the hazards and appropriate emergency responses regarding LPG as per HSW (Hazardous Substances) Regulations Part 4 Section 4.5.
I was a Certified Handler for my old job. Do I need to re-sit the CH course for my new job?
- No, as long as you are not dealing with any new hazardous substances and your certificate has not expired, your old Approved Handler certificate counts as a Certified Handler certificate for those 6.1A and 6.1B substances. The certificate is yours, not the company’s, and goes where you go. Note that the details on the certificate are based on the time when you underwent the certification and any changes (like employer or home address) are best made when you get it renewed.
We’re a small company of less than 10 people. Do we really need to do all this?
- Yes. Whether it’s 1 person or 1000, any company that stores, uses, or disposes of any hazardous substance must be compliant with the HSWA Act and HSW (HS) Regulations. We understand that smaller companies don’t necessarily have the funds to get everything fixed immediately, but with our help we can get you started with the most important issues and come up with an action plan to get you on the road to compliance without breaking the bank.
Are there any online tools available to get our compliance started?
- Yes, EPA created a multi-media package to assist companies in getting their compliance on track and WorkSafe NZ have updated it to align it with the new Hazardous Substances regulations. It is designed with smaller companies in mind, but companies of every size will find something of use within the Hazardous Substances Toolbox. Best of all, it’s free!
- Click here to find out more about the Hazardous Substances Toolbox.
Got a question not answered above? Want some clarification? Ask us!