Is a chemical risk assessment mandatory in Australia?

Not always. The WHS Regulations don’t make a risk assessment mandatory for hazardous chemicals, but Part 3.1 requires a risk-based approach to managing risks to health and safety. A risk assessment is often the best way to meet that duty, and some work, such as high-risk crystalline silica processing, requires a written plan.

What does the Code of Practice say about how to do a chemical risk assessment?

It recommends starting with the label and SDS, scaling the effort to the level of risk, and consulting the workers who do the job to see how it is actually done. A detailed assessment is needed for high-risk chemicals such as carcinogens, or where exposure is uncertain.

Is a chemical risk assessment the same as a COSHH assessment?

No, though they are similar. COSHH is the UK’s Control of Substances Hazardous to Health regime, which focuses on health exposure. Australia’s WHS Regulations require risks to both health and safety from hazardous chemicals to be managed, so a complete assessment also covers fire, reactions, spills and storage.

Do dangerous goods need a separate risk assessment?

Not necessarily. Many dangerous goods are also hazardous chemicals, and the WHS Regulations cover both when they are stored and used at a workplace. One product risk assessment can address both, as long as it covers storage, segregation, quantities and fire risk as well as health.

Does a hazardous chemicals register count as a risk assessment?

No. A hazardous chemicals register lists every hazardous chemical at the workplace with its current SDS. It is a legal requirement, but it does not assess risk, and Safe Work Australia notes it does not replace communicating hazards to workers.

How often should a chemical risk assessment be reviewed?

Review it when controls aren’t working, before a change at the workplace that could create new risks, when new information comes up (such as an updated SDS or changed exposure limit), when consultation shows a review is needed, or when a health and safety representative asks. Many organisations also set a regular review date.

Who can do a chemical risk assessment?

The Code of Practice says assessments should be done by people with a practical understanding of the WHS laws, an understanding of the work processes involved, and the ability to gather information and consult. A supervisor can handle simple assessments. Complex or high-risk ones may need specialist input, such as an occupational hygienist.

What is the difference between a WES and a WEL?

Workplace Exposure Standards (WES) are the current limits for airborne contaminants. From 1 December 2026, they are replaced nationally by Workplace Exposure Limits (WEL). Most values are unchanged, but some are lower and new chemicals are added. Check Safe Work Australia’s list for the products you hold.

Do these rules apply in Western Australia and Victoria?

The principles do, but the legislation differs. Western Australia uses WHS laws for hazardous chemicals and separate dangerous goods safety laws for storage, including site licences above manifest quantities. Victoria uses its own OHS Regulations and Dangerous Goods (Storage and Handling) Regulations. Workplace Exposure Limits apply everywhere from 1 December 2026.

Chemical Risk Assessment: More Than Health Exposure

Most of the hazardous chemicals regulations aren’t about exposure. So why are most chemical risk assessments?

In August 2026, a Victorian company was fined $40,000. Inspectors had found four 205-litre drums of Class 3 flammable liquid sitting beside intermediate bulk containers of a Class 8 corrosive, after the company had already been issued an improvement notice about it.

Picture the chemical risk assessment for either of those products. It almost certainly listed gloves, eye protection and ventilation. It probably referenced the exposure standard. It may even have been signed off and filed.

What it almost certainly didn’t ask was the question that led to the fine: what is this product stored next to?

Why do most chemical risk assessments focus only on health exposure?

Because many of the tools and methods behind them come from occupational hygiene. They ask the questions an industrial hygienist would: routes of entry, dose, duration, exposure standards and PPE. Silica, occupational cancer and the new Workplace Exposure Limits keep the spotlight there too, and rightly so.

The result is a blind spot. Fire, reactions between incompatible products, spills reaching stormwater and damaged containers get treated as someone else’s problem: facilities, the dangerous goods coordinator, or the fire brigade.

What do the WHS Regulations actually ask?

The model WHS Regulations require risks to health and safety from hazardous chemicals to be managed. A formal risk assessment isn’t mandatory, but a risk-based approach is, and the specific duties show what it has to cover:

Safety: identify reaction risks (reg 354), control fire and explosion (355), keep chemicals stable (356), contain spills (357), protect from damage (358), and have fire protection and emergency arrangements (359 to 362).
Quantity and storage: the register (346), manifests and placards (347 to 350), and safety signs (353).
Health: exposure standards and monitoring (49 and 50) and health monitoring (368).

Count them. Most of the specific duties are about what happens in the store, not in someone’s lungs. Western Australia and Victoria legislate some of this differently, particularly dangerous goods storage, but the same risks are covered.

Map of hazardous chemicals duties in the model WHS Regulations. Six safety duties, three quantity and storage duties, and two health duties.

What happens when storage risks are missed?

2018

West Footscray

An unregistered warehouse packed with illegally stored chemicals burned for more than a week. More than 140 firefighters responded, and dead fish and eels washed up along Stony Creek.

140+ firefighters

2019

Campbellfield

Around 300,000 litres of chemicals caught fire. Two workers suffered severe burns and 11 schools and kindergartens closed because of toxic smoke. The operator was fined $2.9 million, which went unpaid after the company collapsed.

$2.9 million fine

2026

Victoria

Class 3 drums beside Class 8 IBCs, Victoria, August 2026

$40,000 fine

Neither was an exposure problem. Both were storage, quantity and segregation failures. (All three examples are Victorian, where similar duties sit under the state’s own OHS and dangerous goods regulations.)

Does health exposure still matter?

Absolutely. In 2024, 188 workers died from traumatic injuries at work, while a 2019 AIOH Foundation estimate puts deaths from occupational disease at around 4,900 a year. And from 1 December 2026, new Workplace Exposure Limits replace the current standards, so many assessments need reopening anyway. The point isn’t to assess health less. It’s that health is one question in four.

“An exposure limit is a ceiling, not a target. And it says nothing about fire.”

Four myths worth retiring

MYTH 1

“Section 8 of the SDS is the assessment.”

Section 8 covers exposure controls. The safety risks live in Sections 7, 9 and 10.

MYTH 2

“Below the exposure limit means we’re compliant.”

The duty is to minimise risk so far as is reasonably practicable, and the limit says nothing about fire.

MYTH 3

“PPE is the control.”

PPE is the last line of defence in the hierarchy of controls. Elimination, substitution, isolation and engineering come first.

MYTH 4

“The register covers it.”

A register is a list with SDSs attached. It isn’t a risk assessment.

So what does good look like?

A complete chemical risk assessment works through four areas at the specific site: fire and explosion, health and exposure, spills and the environment, and storage and segregation. It applies the hierarchy of controls, and it’s done with the people who actually store and handle the product.

Four areas of a chemical risk assessment: fire and explosion, health and exposure, spills and environment, and storage and segregation. Most assessments only cover health and exposure.

Our free guide, What good looks like: chemical risk assessments in Australia, sets it out in three pages: the four areas, six practical steps, the hierarchy of controls for hazardous chemicals, the SDS sections to use, template fields, and an eight-question self-check.

Because a chemical risk assessment that only asks about exposure is answering one question in four.