PPE for Chemical Storage and Handling
How Compliance Decisions Should Drive PPE, Not the Other Way Around
Chemical storage and handling is one of the most common areas where businesses believe they are compliant, yet still carry real safety and regulatory risk.
Chemicals are often stored, used and handled daily without incident. Until something changes. A spill. A reaction. A fire. A complaint. An inspection.
When that happens, one question comes into sharp focus.
Was the risk properly understood, and were the right controls in place before PPE was chosen?
Chemical risk is not just about what you store
Many businesses focus on what chemicals they have onsite. Regulators look at something broader.
Chemical risk includes:
How chemicals are stored
How they are handled during normal operations
What happens during cleaning, maintenance or transfer
What workers may be exposed to during spills, leaks or fires
This is why chemical safety cannot be managed through PPE alone. It is managed through a system, with PPE sitting at the end, not the beginning.
Where the regulatory pieces fit together
Chemical compliance is not a single obligation. It is a connected framework.
In most jurisdictions, this framework includes:
Regulations covering hazardous substances
Separate regulations for dangerous goods or flammable and combustible materials
Requirements to maintain chemical registers or inventories
Safety Data Sheets that describe hazards, controls and emergency measures
While specific legislation and terminology may differ between regions, the underlying expectations are consistent. Employers are required to identify chemical hazards, assess risk, implement higher order controls, and use PPE to manage residual risk.
For context, in Victoria this framework sits across the OHS Regulations 2017 and the Dangerous Goods (Storage and Handling) Regulations 2022, supported by chemical registers and Safety Data Sheets, with guidance provided by WorkSafe Victoria.
Why PPE decisions often go wrong with chemicals
In many workplaces, PPE is selected early, sometimes before the regulatory picture is clear.
Common issues include:
PPE chosen before confirming whether substances are hazardous or dangerous goods
PPE based on what has always been used rather than current Safety Data Sheets
One set of PPE expected to cover normal operations and emergency situations
No clear distinction between routine handling PPE and spill or fire response PPE
This is where businesses unintentionally drift out of compliance.
How compliance should drive PPE decisions
When chemical risks are approached properly, PPE selection becomes far more straightforward.
A defensible decision flow looks like this:
Identify the substances
What chemicals are stored or used?
Are they hazardous substances, dangerous goods, or both?Maintain a chemical register
Up to date and reflective of actual use, not just procurement records.Review Safety Data Sheets
Including:Health and physical hazards
Exposure routes such as skin, eyes and inhalation
Required controls
Emergency and spill response guidance
Apply the hierarchy of control
Storage design, segregation, ventilation, containment, safe systems of work, training and procedures.Select PPE for residual risk
PPE for normal operations, and separate PPE for abnormal or emergency situations, based on the Safety Data Sheets and exposure.
At this point, PPE is no longer guesswork. It is a logical outcome of compliance.
Normal operations versus emergency situations
One of the most common gaps in chemical management is failing to distinguish between:
PPE for routine handling, and
PPE for spills, leaks or fires
For example:
Gloves suitable for decanting may not protect against a spill
Eye protection used daily may be inadequate during a splash or release
Respiratory protection may not be required during normal work, but critical during an incident
Safety Data Sheets often make this distinction clear, but only if they are actively reviewed and applied.
Where PPE fits, and where it does not
PPE plays an important role in chemical safety, but only when:
Higher order controls are already in place
PPE is selected based on specific chemical hazards
Emergency scenarios are considered, not just routine tasks
PPE requirements are documented, trained and reviewed
When PPE is treated as the primary control, it often masks deeper gaps in storage, handling or system design.
Bridging risk advisory and practical solutions
This is where Risk Advisory and Solutions comes together.
At RAS OHS, chemical safety and PPE are approached as a compliance driven system, not a product decision.
That means:
Reviewing chemical storage and handling obligations
Checking alignment with applicable hazardous substances and dangerous goods regulations
Verifying chemical registers and Safety Data Sheet accuracy
Clarifying PPE requirements for normal and emergency conditions
Supporting businesses to source chemical appropriate PPE where it is genuinely required
This approach reduces regulatory risk and ensures PPE actually performs its intended role.
Final thought
In chemical safety, PPE is not the first question. It is one of the last.
When chemicals are identified correctly, registers are accurate, Safety Data Sheets are understood and higher order controls are in place, PPE decisions become clearer, defensible and far more effective.
That is what good risk management looks like in practice. That is where PPE genuinely adds value.
