Hazardous Chemical Substances

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As per the Hazardous Chemical Substances Regulations, hazardous chemical substance “HCS” means any toxic, harmful, corrosive, irritant or asphyxiate substance or a mixture of substances for which an occupational exposure limit is prescribed, or an occupational exposure limit is not prescribed, but which creates a hazard to health. With this definition, we can define most chemicals as hazardous chemical substances due to the fact that most chemicals can be hazardous to health if not used correctly.


Exposure to chemicals in the workplace can result in acute or long term detrimental health effects, along with devastating consequences for our environment. The risk that this places on employers do vary depending on industry and the chemicals which are used, however, we should not convince ourselves that workplace chemical accidents are only isolated to construction and engineering. In Utah, United States, Jan Harding was eating at a local restaurant with her husband, Jim, on 10 August 2014 when she sipped her tea and started gagging and coughing. An employee mistook degreaser – made of sodium hydroxide (Lye) for sugar, mixing it into the tea which caused severe chemical burns to Harding’s throat and mouth almost resulting in her death. A simple lack of control, such as an unlabelled chemical container, can lead to a potential death of employees or visitors to our workplaces.


The Hazardous Chemical Substances Regulations provides guidelines for employers to reduce the risk of workplace exposure to HCS. The foundation of controlling exposure to HCS is the assessment of potential exposure which is an area which seldom receives the attention it deserves. During the assessment, the following important information is gathered –

  • the HCS to which an employee may be exposed;

  • the effects the HCS can have on an employee;

  • where the HCS can be present and in what physical form it is likely to be;

  • the route of intake by which and the extent to which an employee can be exposed; and

  • the nature of the work, process and any reasonable deterioration in, or failure of any control measures.


By failing to conduct a suitable and sufficient assessment of potential exposure, employers lose the opportunity of identifying the essential information required in ensuring the health and safety of their employees and to meet the requirements of the regulation. These are –

  • to provide information and training for employees on HCS;

  • medical surveillance of employees exposed (if applicable);

  • ensuring easy access to material safety data sheets;

  • provision of the required personal protective equipment for the HCS in use, safe storage and labelling of HCS containers as well as disposal procedures to name a few.


If we consider the level of compliance to occupational health and safety legislation in South Africa, which is on average low, as well as the number of work-related fatalities which occur, employers have a long way to go in ensuring the safety and health of their employees. Controlling the hazardous chemical substances in our workplaces is one key aspect and a leap in the right direction.


The Hazardous Chemical Substances Regulations are also applicable to alcohol-based hand sanitisers which should contain at least 70% ethanol or isopropyl alcohol. Potential hazards of alcohol-based hand sanitisers include fire, explosion, and serious eye irritation. Even small quantities of flammable vapours from a leak or spill that accumulate in poorly ventilated areas may ignite and cause serious injury and damage. To this end, a business must manage the health and safety risks that are associated with handling alcohol-based hand sanitisers, and ensure safe packaging, labelling and the provision of information about the product, including safety data sheets.

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