Six things our DG consultants check first when they walk onto your site

Across hundreds of site visits to Australian manufacturing facilities, warehouses, logistics operations, and mining services businesses, our dangerous goods consultants see the same pattern. Most organisations are further from compliance than they believe — not because they are careless, but because the gap between what a WHS system manages and what dangerous goods regulations actually require is bigger than most people realise.

Dangerous goods compliance is not an extension of WHS. It operates on a fundamentally different logic — prescriptive thresholds, strict liability obligations, and a jurisdictional patchwork that a single WHS framework cannot map onto. By the time a regulator surfaces the gap, the cost of closing it is significantly higher than it needed to be.

The observations below draw on our own field experience — and are validated by experienced practitioners like NS8 Group consultant Les Cameron and our very own Chief Knowledge Officer – Andrew Hahn, who has assessed sites across Australian industry and reviewed the DGXprt platform in practice.

1. Inventory against thresholds — and whether placarding reflects reality

The first thing we look at is not the SDS register. It is the inventory — and whether anyone has compared it against the regulatory thresholds that apply in that state.

WHS asks: what are the hazards, and what controls are reasonably practicable? Dangerous goods regulations ask something entirely different: what do you have on site, and how much? The quantity of each DG class — measured against state-specific Schedule 11 thresholds — determines which obligations apply. Cross a threshold and the obligation is mandatory. There is no risk judgement available and no reasonably practicable test. If the quantity is there, the obligation is there.

Thresholds operate in tiers. Minor storage obligations apply from day one — a hazardous chemicals register, SDS access, and basic spill containment. Above the placarding threshold, outer warning placards must be displayed at every site entrance and individual storage areas must carry appropriate class labels. Above the manifest threshold, a compliant manifest must be prepared, the relevant regulator notified, and fire authorities consulted. Each tier compounds the previous one. Most organisations we assess have never worked out which tier they are actually in.

Placarding is also where we see some of the most common errors. Placard size, format, and placement are defined in regulation — a single generic template does not satisfy every state's requirements, and a placard on the wrong door or in the wrong location does not count. Placards exist specifically so that firefighters and emergency responders know what is inside and can make rapid, informed decisions. Getting this wrong has consequences that go well beyond a compliance notice.

2. SDS currency and accessibility — not just "somewhere on file"

The second check is the SDS library. Not whether SDSs exist — that is almost always true — but whether they are current, GHS-compliant, and accessible to the workers who actually need them.

WHS Regulations require SDSs to be current (within five years), compliant with the GHS standard, and readily accessible to workers at the point of use. A folder in a back office does not satisfy the accessibility obligation. An SDS downloaded in 2019 and not reviewed since very likely does not satisfy the currency requirement.

In our experience, more than 40 per cent of SDSs in Australian workplaces are non-compliant on first assessment — missing sections, out of date, or using pre-GHS classification formats. The downstream effect compounds quickly. Non-compliant SDSs produce unreliable classification data, which corrupts threshold calculations, which makes every compliance decision built on that data unreliable. The register looks complete. The obligations it generates are not.

"DGXprt is not just a ready reckoner to view what should be at a dangerous goods site, in terms of manifests, documentation, prevention and risk management systems, but a total compliance program that keeps the business on top of what the laws require and what good diligence looks like."

— Les Cameron, NS8 Group

3. Manifest status — is it a live document or a historical artefact?

If a site is above manifest threshold, we check the manifest. Specifically: when was it last updated, and does it reflect the current inventory?

A manifest is a live document. The obligation is not to have one — it is to maintain a current one that reflects what is actually on site at any given time. If inventory has changed since the manifest was prepared — a new product introduced, quantities shifted, a product discontinued — and the manifest has not been updated, it does not satisfy the regulatory requirement. The obligation applies from the moment the threshold is crossed, not from the next scheduled review.

In most organisations we visit, the manifest has been assembled manually in a spreadsheet by one person, at one point in time. It captures that moment. It does not maintain itself as inventory moves. That is not how the regulation works, and it is not a gap that goodwill closes.

4. Storage and segregation — the gap that causes incidents

Storage assessment is one of the areas where the gap between "we have a system" and "we are actually compliant" is most visible. Most sites have a storage area. Most sites have not assessed whether that storage area meets the requirements that apply to the specific classes of goods being stored.

The first question is segregation. Dangerous goods must be stored separately from incompatible substances — oxidisers away from flammables, corrosives separated from anything they can react with. The rules are not intuitive and they do not map onto how warehouses are typically organised by product line or customer. AS 3833 provides the segregation framework used across Australian jurisdictions, and the requirements are specific: they cover separation distances, whether goods can share the same room, and whether physical barriers are required.

The second question is whether the storage arrangement will remain compliant as inventory evolves. One of the most common findings in warehouse assessments is that the current layout was designed for the current product mix — and nobody has assessed what happens when a new product class is introduced. Aerosols, for example, require specific separation distances and in some cases caging requirements. A warehouse that is currently compliant can become non-compliant the moment a new line is introduced if the storage implications have not been assessed first.

Beyond segregation, storage compliance covers container integrity and labelling, bunding and spill containment appropriate to the quantities and classes stored, ventilation requirements, and whether the storage area is secured against unauthorised access for goods with security implications. Each of these has specific requirements under the relevant Australian Standards and codes of practice — none of which are captured in a standard WHS risk assessment.

5. Jurisdiction-specific obligations — one template does not cover every state

For any organisation operating across multiple sites, we check whether compliance has been assessed on a state-by-state basis — or whether someone has applied a single national template to every location.

There is no national standard for dangerous goods storage and handling. Victoria operates under its own DG Regulations, entirely outside the WHS framework, with a unique fire protection quantity threshold that triggers mandatory engagement with fire authorities. Western Australia runs a hybrid model. South Australia mandates specific Australian Standards as a legal requirement, not just best practice. NSW updated its WHS Regulations in 2025 with specific DG changes. Each state has different thresholds, different terminology, and different regulatory authorities.

A compliance position that is correct for a QLD site may not satisfy the obligations at a VIC site with an identical inventory. Multi-site operators are exposed at every point of difference between jurisdictions — and most do not know where those points are until a regulator finds one.

6. Who owns this — with the authority to act?

The final check is governance. Specifically: is there one person who owns DG compliance, understands what is required across every site and state, and has the authority and budget to act when a gap is identified?

DG compliance typically lands with the safety function because chemicals are hazards and WHS manages hazards. That is a logical home. But the technical and regulatory demands — threshold calculations, placarding compliance, segregation assessments, state-by-state regulatory interpretation, manifest preparation, regulator notification — go well beyond standard WHS practice. And when that one person is on leave, gets busy, or moves on, the knowledge tends to go with them.

"The moment compliance depends on one person's knowledge rather than a system, you have a vulnerability. Not a performance issue — a structural one. People move on. Systems don't."

— Andrew Hahn, CKO & Co-Founder, DGXprt

What we see in organisations that manage this well is not necessarily a larger safety team. It is a system that holds the prescriptive knowledge so that the people responsible for compliance are working from current, accurate data — not from memory, or from what was correct eighteen months ago.

"DGXprt is a compliance program that works to prevent dangerous goods and hazardous substance incidents that affect people, property and the environment."

— Les Cameron, NS8 Group

The gaps are solvable. But they need a system, not a person.

Every one of these gaps is fixable. None of them require a compliance overhaul or a dedicated DG specialist on every site. What they require is a system that keeps the prescriptive layer current — inventory tracked against thresholds, placarding validated, segregation checked against the right standards, manifests updated as inventory moves, obligations clear and linked to the specific regulation that triggers them — so that the WHS professionals responsible for DG compliance are working from an accurate picture, not a historical one.

The risk is not that organisations are reckless about dangerous goods. The risk is that they are managing it under the wrong framework, with tools that were not built for it, and they will not find out until an audit, a fine, or an incident makes it visible.