Reference: MH/CO/09/223

13 August 2009

Attention: Janine Dridan
Community & Stakeholder Engagement
EPA Victoria
GPO Box 4395QQ
Melbourne Victoria 3001

Dear Janine,

Application for Works Approval WA65201, Renex Group P/L, 109-133 Ordish Road South Dandenong

I am writing to provide further clarification of WorkSafe’s review of the above Application for a Works Approval Application No: WA 65201 which was referred to WorkSafe for comment on 22 June 2009.

In our initial letter dated 10 July 2009, it was stated that:

“WorkSafe has not identified any major concerns regarding the control of risks from dangerous goods introduced by the proposal and has no objection to the grant of a works approval on condition that:

“The proposed development must comply with the relevant requirements of the Dangerous Goods Act and its subordinate legislation, particularly the Dangerous Goods (Storage and Handling) Regulations 2000.

In practice this means that the proposal must be in accordance with AS 1940 - The storage and handling of flammable and combustible liquids and also AS 3780 – The storage and handling of corrosive substances”.

WorkSafe’s review of the EPA Works Approval is limited to the storage and handling of dangerous goods at the proposed facility. WorkSafe understands that the occupier is proposing a bulk storage of sodium hydroxide of approximately 25000-30000 litres and storage of waste oil in 200 litre drums up to a maximum of 2000 litres. Sodium hydroxide is a Class 8 corrosive dangerous good while Waste Oil would be classed as a C1 Combustible dangerous good having a flashpoint greater than 61°C. In WorkSafe’s opinion, the storage and handling of these dangerous goods should not pose a significant onsite or offsite risk provided the following can be achieved:

-  the facilities for storage and handling of these dangerous goods is designed, constructed, operated and maintained in accordance with relevant standards, in particular, AS 3780 & AS1940

-  The quantity of sodium hydroxide to be stored onsite exceeds the fire protection quantity for Class 8 corrosives and therefore the occupier will need to request the written advice of the Fire Authority in relation to the design of the fire protection system as required under Regulation 436 of the Dangerous Goods (Storage & Handling) Regulations,

-  the facility complies with all other relevant provisions of the Dangerous Goods (Storage & Handling) Regulations.

WorkSafe is available to discuss the above matters with the applicant directly if required.

If you have any questions, please contact Rodney Gunn on 03 9641 1339 or email .

Yours sincerely

Rodney Gunn

Manager – Major Hazards Unit

Hazard Management Division

WorkSafe Victoria

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