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New legislation?. Hazardous Substances and New Organisms Act. Hazardous Substances section coming into enforcement (GMO’s already in place) Restates and reforms the law relating to: Management of hazardous substances Deciding on and control of new organisms
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Hazardous Substances and New Organisms Act • Hazardous Substances section coming into enforcement (GMO’s already in place) • Restates and reforms the law relating to: • Management of hazardous substances • Deciding on and control of new organisms • Establishes ERMA- Environmental Risk Management Authority www.ermanz.govt.nz
Key Aspects • Environmental legislation • Hazardous substances only • Approval system for hazardous substances • Containment principles • Cradle to grave approach - setting controls for the lifecycle of substances
Legislation being replaced • Repeals: • Dangerous Goods Act 1974 • Toxic Substances Act 1979 • Explosives Act 1957 • Repeals remaining parts of : • Animals Act 1967 • Plants Act 1970 • Pesticides Act 1979 • Fertiliser Act
Classifications under HSNO • Class 1 - explosiveness • Class 2 - flammability, gases • Class 3 - flammability, liquids • Class 4 - flammability, solids • Class 5 - capacity to oxidise • Class 6 - toxicity • Class 8 - corrosiveness • Class 9 - ecotoxicity (Class 7 unallocated)
Approving Substances • Import or manufacture a hazardous substance for release • Containment principle • Process managed by ERMA
Exemptions • Medicines • in finished form • Foods (Food Act 1981) • HS used in research and development and teaching (section 33) • Manufactured articles • Non-hazardous substances
Changes • Existing substances will transfer to HSNO regime block by block • Transfer timeframe 3 - 5 years • Ensure compliance with current legislation • Toxic Substances and Dangerous Goods legislation
Transfer Lists • http://www.ermanz.govt.nz/index.asp • http://www.ermanz.govt.nz/hs/transfer-sing-complist2.asp • http://www.ermanz.govt.nz/hs/dangerous-goods/dg-class345-report.pdf • http://www.ermanz.govt.nz/hs/dangerous-goods/dg-class2-report.pdf
Identification Minimum degrees of hazard Disposal Classification Tracking Personnel Qualifications Exempt Laboratories Emergency Management Classes 1 to 5 Controls Classes 6,8, and 9 Controls HSNO Regulations 2001
Section 33 Exemption • Labs for research and development using hazardous substances if: • laboratory meets prescribed standards • does not involve a substance that has been declined under the Act • Importation, storage and transport meets prescribed requirements • Does not involve the sale of any such substance
Exempt Labs • Lab defined as: vehicle, room, building or other structure for scientific experiments or research, teaching, or development of chemical or medicinal products
Exempt Labs • Prescribed requirements: • lab design • record keeping • handling and storage • personnel requirements • emergency planning
Code of Practice • NZ Universities and CRI developing code to assist with compliance of section 33 • Completion date February 2004 • Covers the following substances - • ERMA approved hazardous substances • unapproved hazardous substances • de novo synthesis of hazardous substances
Otago Compliance Manual • Currently in draft format • Based on HSNO Exempt Lab COP • Management structure and responsibilities • Operational guidelines • Design requirements • Emergency planning • DG Stores • Auditing and monitoring
VC University Lab Manager - Wayne Temple Dept Lab Managers Laboratory Supervisors Authorised Users Ultimate responsibility Primary Compliance role Implementation in Depts. Implementation in labs Able to use substances Management Structure
HSNO Lab Management • University Laboratory Manager • Dr Wayne Temple • Haz Sub and Radiation Advisory Group • Radiation Safety Officer - Keith Hunter • Departmental Laboratory Managers • Each defined laboratory area to have Laboratory Supervisor, and deputy • Someone clearly in charge at any time.
Responsibilities • Approved users for each laboratory • Students - mix of supervision and approval - undergraduates always supervised, post-grads can be approved as authorised users • Project by project basis - may restrict after-hours work
Authorised Users • Assessed as competent by Lab Supervisor to work in the laboratory. • Must be documented. • Post-Docs, 1st and 2nd year masters, 4th year honours students may be Authorised • Staff - those required to work in the lab must be assessed by Lab Supervisor - may be by class/process/materials
Laboratory Rules • Laboratory coats to be worn at all times in HSNO exempt laboratories • Safe Methods of Use • specify requirements for use • special precautions • done by class or specific high risk substances
Labelling requirements • By HSNO class • Category A, B and 6.1C are high risk • Must be able to recognise the hazards from the pictograms • Tracked substances labelled • UN pictograms • A, B, C, and T labels • on trial in Chemistry
Working Containers • Labelled when held 48 hours or more • If container too small, then secondary container and label • Concentration of substances marked on containers - permanent marker • Reaction vessels - id contents and who to contact • Check containers regularly
Equipment • Can also contain hazardous substances • Clean up! • Let repair persons know what has been in it if unable to remove all • Maintenance • SMOU for use for some, training • Fume cupboards
Storage in labs • Flammable and corrosive cabinets • Segregate - store by class! • Minimum levels in labs • 1 litre max for category A substances • 2.5 litres all other categories • Secondary containment
Waste Disposal • Must consider prior to commencing work, particularly if category A, B or 6.1C • University collections • Labelling • Store by class • 5 litres category A, 20 litres all others. • Storage containers • Secondary containment
Tracked Substances • Explosiveness - all class 1 substances with some exemptions • Flammability - 3.1A and 3.2A, 4.1.2A and 4.1.2B, 4.1.3A, 4.2A, 4.3A • Oxidisers - 5.1.1A, 5.2A and 5.2B • Toxicity - 6.1A, 6.1B, and 6.1C • Ecotoxic - 9.1A, 9.2A, 9.3A, 9.4A • List of substances within Uni. available
Chemical Inventory • University system being built - web based • Information and HSNO classes available • Tracked substances to be labelled • Info can be viewed, limited administrators • Recording when a container of tracked substance is used, or brought into the lab
Design Requirements • Signage • PC1,2, & 3 will meet requirements • Auditing and upgrades through statutory budget with Property Services/HSRAG • New substances, new equipment - application to HSRAG
Emergency Planning • Same as before - know what to do if a haz sub emergency occurs • Spills - if can manage, clean up with spill kit • Spill training • Evacuations • Closing doors, windows, info on substances available