Tracking

What is tracking?

Tracking is the recording of what happens to hazardous substances throughout their lifecycle - from importation or manufacture in New Zealand, to the point of use and/or disposal.

Tracked substances are required to be under the personal control of an Approved Handler or otherwise secured under lock and key. In the case of flammable tracked substances there is also the requirement for the site to have a Location Test Certificate.

Why track hazardous substances?

Tracking ensures:

  • appropriately trained people, Approved Handlers, are responsible for the hazardous substance
  • where the substance is flammable, that the place where it is stored has been independently checked to ensure it is safe for the worker and the environment Location Test Certificate
  • information is available for managing emergencies involving the substances
  • Enforcement Agencies have the ability to track back who has or should be responsible for the hazardous substance.

What substances are tracked?

Substances requiring tracking are those that have one or more hazard classification listed in Schedule 1 of the Hazardous Substances (Tracking) Regulations. Tracked substances include:

  • Flammable liquids (Classes 3.1A and 3.2A)
  • Flammable solids (Classes 4.1.2A, 4.1.2B, 4.1.3A, 4.2A and 4.3A)
  • Oxidisers (Classes 5.1.1A, 5.2A and 5.2B)
  • Toxic substances (Classes 6.1A, 6.1B and 6.1C)
  • Ecotoxic substances (Classes 9.1A, 9.2A, 9.3A and 9.4A)
  • Explosive substances (Class 1) except for: small fireworks, safety ammunition, some categories of flares and signalling devices for emergency use, model rocket engines, some articles of Class 1.4.S, and small quantities of propellant powders and gunpowder.

Check the current controls on the substance you are using. The tracking requirement for some substances has been removed.

Tracking does not apply to:

  • Substances used to power vehicle (Petrol), aircraft (Aviation Gas), or ship when in the vehicle, aircraft or vessel.
  • Any fuel gas used in a distribution system, gas installation or gas appliance that is subject to the Gas Act, 1992

Who is responsible for keeping records?

The Person in Charge of a site where a tracked substance is kept is responsible for keeping records.

Where does tracking start?

If the substance is:

  • manufactured in New Zealand, tracking commences at the site of manufacture
  • imported, tracking commences at the port. The UN or ICAO transport documentation relating to the shipment will be acceptable records up to the importer's premises, or person storing the substance on behalf of the importer.

What information do I need before I transfer a substance?

Before a tracked substance is transferred to another location, the Person in Charge must ensure that:

  • The site receiving the tracked substance has an Approved Handler for that substance;
  • If the substances are explosives, flammables or oxidisers, the premises receiving the tracked substance may be required to hold a Location Test Certificate. Whether or not Location Test Certificate is required depends on the quantities and classifications of the substances held at the premise;.
  • Any place the substance is to be held during transit complies with the emergency requirements and transit depot requirements of the hazardous substances regulations.

How does tracking apply to transport?

Tracking applies to transport but there are differences:

  • Records do not need to be held on a vehicle for 12 months.
  • For land transport, compliance with the land transport rules is considered equivalent to the HSNO tracking rules. The Person in Charge of the vehicle is normally accepted as an Approved Handler provided they hold a recognised qualification, eg a 'D' endorsed drivers licence. However, an Approved Handler is required when transport is by a bulk tank wagon or the substance is explosive.
  • For sea and air transport the Maritime and Civil Aviation rules are considered equivalent to the HSNO tracking rules.
  • Transit depots are required to keep records in accordance with the transport rules.

A person sending tracked substances from one location to another must check that the receiving location meets the requirements of the tracking regulations; have an Approved Handler and a Location Test Certificate, if required. However, they will not be required to make the same checks on the transport used to convey the substance, except to ensure that the driver of a vehicle complies with the relevant transport rules.

What information do I need to record?

Table 1 below sets out the records required and the form that the records could take. In many cases normal commercial records are acceptable providing they are readily accessible and contain the required information.

Table 1: Tracking Records Required

Step

Record requirements

Example record

Who keeps the record?

1

Approved Handler in control of the substance:

  • The person's name and position within the organisation
  • The physical address of the person's place of work
  • The substances or classes and phases of the lifecycle for which the person is approved.

A copy of the Approved Handler's certificate held on file, the name and physical address of the organisation.

Person in Charge of the place.

2

Substance information:

  • Unequivocal identification of the substance such as the trade name, common name or the ERMA approval name and number.
  • The total quantity of the substance under the control of the Approved Handler at any one time. This record will change daily with substances being received and dispatched.
  • Location of Tracked Substance i.e. where exactly the substance is stored within the depot or building.
  • Batch or package number (where required).

Delivery dockets, stock records; electronic database systems; and/or other hard copy records

Person in Charge of the place.

3

Transfer to another place:

  • Unequivocal identification of the substance and the amount transferred
  • Address of the place and the identity of the Approved Handler (including Approved Handler registration number if available) to whom the substance is being sent
  • Position of the Approved Handler within their organisation
  • Date on which transfer occurred.

Consignment/stock records; electronic database systems; Approved Handler's certificate; Location/stationary container certificate; and/or other hard copy records

Person in Charge of the place sending the substance.

4

Transport:

As per the Transport Act requirements

A consignment note and a Transport of Hazardous Substances Declaration.

Person in Charge of the vehicle.

5

Lifecycle endpoint (use, treatment or disposal, including accidental spills):

 

  • The manner of disposal i.e. how the substance was used, consumed or released etc
  • The amount of substance disposed of and the date of disposal
  • The location where the substance was disposed of.

Spray diaries; electronic database systems; and/or or other hard copy records

Person in Charge of the place where the use or disposal occurs.

Availability of records

The information identified in Table 1 must be readily retrievable -  within 10 minutes. An enforcement officer must be able to identify the location and quantity of a substance within 2 minutes of viewing the record. If multiple record systems, such as a database and hard copy records are used, they will need to be cross referenced to ensure all the information is retrievable. The documentation must be understandable to a trained person who requires access.

Tracking records must be kept at least 12 months after the substance has been transferred; or three years in the case of use, treatment or disposal of the substance.

Audit Tool

ERMA New Zealand has developed an audit tool to aid in determining if a site(s) is/are complying with the tracking requirements.

This tool can be downloaded here

 

Contact ERMA New Zealand
If you have any questions about hazardous substance compliance contact the Hazardous Substances Compliance Line:

Phone: 0800 376 234, or
Email: hsinfo@ermanz.govt.nz

Or contact us at:
ERMA New Zealand
PO Box 131
Wellington.