Chemical Storage and Handling: Which Victorian Rules Apply to You

DOC-VIC-HSDG-001 · STORAGE & HANDLING

Storing chemicals at work? First, know which set of rules applies to you.

In Victoria, the chemicals on your premises are governed by two separate laws at once — one for the harm they do to health, one for the harm they do through fire, explosion or corrosion. Most employers don’t realise a single drum can sit under both. This is the starting point: what each law asks of you, and where the line for specialist help sits.

QUICK SPEC · CHEMICAL S&H
JurisdictionVictoria
Health-harm lawOHS Regulations 2017 · Ch. 4
Physical-harm lawDG (Storage & Handling) Regs 2022
Applies toAny workplace storing or handling chemicals
First stepIdentify · obtain SDS · register
REF-HSDG-HERO
! One chemical, two laws. Many substances — a flammable solvent, a corrosive cleaner — are both a hazardous substance and a dangerous good. When that happens, both sets of regulations apply together. Complying with one does not discharge the other. REF-HSDG-ALERT
SECTION A · THE TWO-LAW MAP · REF-HSDG-A01

Two laws, sorted by the kind of harm

The fastest way to make sense of chemical compliance in Victoria is to stop thinking about the chemical and start thinking about the harm. The law splits on exactly that line.

HEALTH HARM

Hazardous Substances

Toxic · corrosive to health · carcinogenic · sensitising

Substances that can harm health — classified under the GHS health-hazard criteria. Think solvents, acids, silica, isocyanates. The duties are about exposure: knowing what’s on site, telling your people, controlling the risk.

OHS Act 2004 · OHS Regulations 2017, Chapter 4
PHYSICAL HARM

Dangerous Goods

Fire · explosion · corrosion · oxidising · reactive

Substances and articles that cause immediate physical harm to people, property or the environment — classified under the ADG Code. Think flammable liquids, LPG, oxidisers. The duties are about containment, separation and emergency readiness.

Dangerous Goods Act 1985 · DG (Storage & Handling) Regs 2022
WHERE THEY OVERLAP

A great many chemicals are both — a flammable, toxic solvent is a hazardous substance and a dangerous good. The two frameworks are designed to complement each other, not replace each other. Where a chemical is both, you carry the duties under both at the same time. The good news: the law lets you run them efficiently, which is what the next sections are about.

SECTION B · THE LEGAL STACK · REF-HSDG-B01

What sits on top of what

Five layers. The Acts set the broad duty; the regulations make it specific; the compliance codes show one accepted way to meet it.

  • LAYER 01OHS Act 2004 · s.21The employer’s general duty to provide and maintain a safe working environment, so far as reasonably practicable.
  • LAYER 02OHS Regulations 2017 · Chapter 4The specific hazardous-substance duties: SDS, labelling, register, control of risk.
  • LAYER 03Dangerous Goods Act 1985The parallel duty for goods that harm by fire, explosion or corrosion.
  • LAYER 04DG (Storage & Handling) Regulations 2022The occupier’s duties: hazard ID, risk control, spill containment, placarding, manifest, notification.
  • LAYER 05WorkSafe Compliance CodesPractical guidance — not mandatory, but accepted as evidence of compliance.
THE STARTING POINT · REF-HSDG-B02

Before anything else: identify, get the SDS, register

01

Identify what you hold

Walk the site. List every chemical stored or handled — including anything generated by a process. You can’t control what you haven’t named.

OHS Regs r155 · DG Regs r26
02

Obtain a current SDS

Get the safety data sheet on or before the first time a chemical arrives — regardless of the amount — and keep it readily accessible to anyone who may be exposed.

OHS Regs r155–156 · DG Regs r54
03

Keep a register

A list of every chemical with its SDS, kept where your people can reach it. For hazardous substances this is required whatever the quantity.

OHS Regs r162 · DG Regs r58
04

Control the risk

Work the hierarchy: eliminate, then substitute, isolate or engineer, then administrative controls, then PPE last. PPE is the bottom rung, not the plan.

OHS Regs r163 · DG Regs r27
INSPECTOR LENS · REF-HSDG-B03

If every dangerous good you hold is also a hazardous substance, you don’t need two registers. One combined register, prepared under the OHS Regulations, satisfies both. It’s the first efficiency most sites miss — and the first thing worth getting right.

SECTION C · WHERE QUANTITY CHANGES YOUR DUTIES · REF-HSDG-C01

Hold enough, and new duties switch on

For dangerous goods, the duties step up by quantity. Schedule 2 of the DG Regulations sets three separate thresholds for each class of goods. As you cross each one, another obligation begins. You read your own figures off Schedule 2 against your SDS — the structure is what matters here.

Schedule 2 sets three quantity columns for every class of dangerous good: Column 4 — Placarding Quantity · Column 5 — Manifest Quantity · Column 6 — Fire Protection Quantity. The numbers differ by class; the duties they trigger are the same.
1
COLUMN 4 — PLACARDING QUANTITY

Placards go up

Cross the placarding quantity and you must display HAZCHEM outer warning placards at vehicle and rail entrances, plus class placards on the storage itself — so emergency services know what they’re walking into.

DG Regs r46 · r47
2
COLUMN 5 — MANIFEST QUANTITY

A manifest is required

Cross the higher manifest quantity and you must keep a written manifest — quantities, classes, locations, site plan — in a weatherproof spot accessible to the fire service, usually by the front placard.

DG Regs r44 · r45
3
COLUMN 5 — CONSEQUENCE: NOTIFIABLE GOODS

You notify WorkSafe

Exceeding the manifest quantity also makes your goods “notifiable.” You must notify WorkSafe — within 3 business days — and have a written emergency plan in place.

DG Regs r64
4
COLUMN 6 — FIRE PROTECTION QUANTITY

Fire protection design involves the fire authority

Cross the fire protection quantity and, before you establish or alter a fire protection system, you must request and have regard to the written advice of the fire authority (FRV or CFA) on its design. This is where fire engineering and emergency-services consultation formally enter.

DG Regs r52 · (general fire protection: r51)

Placard relocation is allowed — but only in writing. Placards can sit somewhere other than the default position if you reach a written agreement with FRV or CFA and keep it on file. That agreement is exactly the kind of step worth coordinating early, not after an inspection.

WHERE SPECIALISTS COME IN · REF-HSDG-C02

The fire protection quantity is the clearest signal in the Regulations that you’ve moved beyond fundamentals: the law itself now expects fire-authority consultation, and with it fire-protection design, bunding sized to the storage, and often process-safety or hygiene input. That’s where the right specialist earns their keep. The job at this stage is knowing the line is there, getting the fundamentals straight, and bringing the right people in at the right moment rather than the expensive one.

SECTION D · WHERE THIS FITS · REF-HSDG-D01

Storage and handling — and where it stops

SCOPE NOTE

This hub covers storage and handling: chemicals at rest on your premises and the work done with them — conveying within the site, decanting, transferring, dispensing, disposing. Transport of dangerous goods by road or rail is a separate regime under the ADG Code, with its own duties and triggers. Different rules, different chain of responsibility. Where the two meet — goods arriving, being unloaded, then stored — is worth getting advice on rather than guessing.

Each topic below goes deeper than this hub can. They’re the practical questions that follow once the fundamentals are in place.

SECTION E · COMMON QUESTIONS · REF-HSDG-E01

What employers actually ask

Does my chemical register depend on how much I store?
No. For hazardous substances, you must keep a register of every substance supplied to your workplace and its SDS, regardless of quantity. Quantity thresholds change your dangerous goods duties — placards, manifest, notification — not whether you keep a register in the first place.OHS Regs r162
Do I need a safety data sheet even for small amounts?
Yes. You must obtain a current SDS on or before the first time a chemical arrives, whatever the amount, and keep it readily accessible to anyone who might be exposed. A small quantity doesn’t remove the duty.OHS Regs r155–156 · DG Regs r54
What has to go on a container I’ve decanted into?
For a hazardous substance, the decanted container must be clearly labelled with the product identifier. For a dangerous good transferred into a portable container, it needs the class label, subsidiary hazard label and product name — or the product identifier with a hazard pictogram and statement. The only exception is when the substance is used immediately and the container is then cleaned or neutralised straight away.OHS Regs r158 · DG Regs r56
When do placards and a manifest become mandatory?
Both are quantity-triggered for dangerous goods, read off Schedule 2. Cross the placarding quantity (column 4) and placards are required. Cross the higher manifest quantity (column 5) and you must maintain a manifest for emergency services. The thresholds differ by class, so you check your own figures against your SDS.DG Regs r44, r46, r47
When do I have to notify WorkSafe?
When the dangerous goods on your premises exceed the manifest quantity, they become “notifiable goods.” You must notify WorkSafe within 3 business days and have a written emergency plan. Below that threshold, the duty to identify, register and control still applies — you just aren’t notifying.DG Regs r64
If a chemical is both a hazardous substance and a dangerous good, do I do everything twice?
No — but you do carry both sets of duties. The frameworks are built to complement each other. Where they allow it, you can run one process for both: most usefully, if all your dangerous goods are also hazardous substances, a single combined register under the OHS Regulations covers both.DG Regs r58 · OHS Regs r162
How is storage different from transport?
Storage and handling rules govern chemicals while they sit on, and are worked with at, your premises — under the DG (Storage & Handling) Regulations and OHS Regulations. Transport rules govern goods moving by road or rail, under the ADG Code, with a different chain of responsibility. The duties, the triggers and the documents are not interchangeable.DG (S&H) Regs · ADG Code
I’m a retailer — are my duties lighter?
In part. A retailer doesn’t have to list a hazardous substance in the register if it’s in a sealed consumer package intended for retail sale and not opened on the premises. You must still obtain an SDS, and anything opened on site goes back on the register.OHS Regs r162(4)
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Not sure which rules bite on your site?

Start with the fundamentals — what you hold, which laws apply, and where a specialist genuinely needs to step in. A 30-minute discussion is the quickest way to know where you stand.

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RAS-OHS DOC-VIC-HSDG-001 · CHEMICAL STORAGE & HANDLING · VIC
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