Carcinogens: Managing Compliance with Prohibited and Restricted - Procedures

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1. Purpose and Objectives

The purpose of this document is to provide The University of Queensland with the process to manage compliance with the prohibited and restricted carcinogen legislation documented in the Work Health and Safety Regulation (Qld) 2011.

2. Definitions, Terms, Acronyms

Chemwatch - proprietary database used by The University of Queensland to access safety data sheets and other information to control chemical risks.

Hazardous chemicals and hazardous materials - chemicals and other materials that can cause harm to workers and other people, property or the environment through fire, explosion, reaction or release.

Prohibited and Restricted (P&R) Carcinogens - prohibited and restricted carcinogens as defined by Schedule 10.1 and 10.2 of the Work Health and Safety Regulation (Qld) 2011 and duplicated in section 7.1. of this procedure.

Risk Management - coordinated activities to direct and control an organisation with regard to risk.

Risk Management Database - The University of Queensland online database for recording standard and chemical risks, control measures, training requirements and other details relevant to risk management. The database includes a risk management console tab for detailing and recording a risk assessment.

Risk Control - taking action to eliminate health and safety risks so far as is reasonably practicable, or if that is not possible, minimising the risks so far as is reasonably practicable.

Safety Data Sheet (SDS) - a document containing information on the health, safety and environmental aspects of a material or chemical for the purposes of storing, using and disposing of the substance in a safe way.

WHSQ - Workplace Health and Safety Queensland

Workers - all UQ staff and HDR students, including academics, lecturers, tutors, researchers, sabbatical/visiting staff, casual staff, vacation scholars, volunteers and students on work experience (as interpreted from the Work Health and Safety Act (Qld) 2011).

3. Procedure Scope/Coverage

This procedure applies to all workers within UQ facilities who use prohibited and restricted (P&R) carcinogens for research work. It does not include workers at the Chemstore who may temporarily store and transport the carcinogen to the UQ research facility. This procedure must be adopted by Schools, Centres, Institutes and Divisions that use P&R carcinogens.

4. Procedure Statement

This procedure for working with P&R carcinogens ensures the following:

  • Compliance with health and safety legislation including the recording and provision of a statement of exposure for the carcinogen that the worker may have been exposed to.
  • Exposure to all workers who handle, store and use the carcinogen is eliminated, or if this is not practicable, then exposure minimised to ensure the workers' health and safety is not affected.

Note: The term Prohibited Carcinogen really means prohibited without authorisation. For industrial use prohibited carcinogens are unlikely to gain authorisation, but they can be used for genuine research purposes with authorisation. Prohibited carcinogens include industrial or therapeutic chemicals that can be used on an industrial scale with authorisation. For research work both prohibited and restricted carcinogens can be used with authorisation and there is no difference in the application to obtain authorisation. The supporting forms in this procedure entitled Restricted Carcinogen are for both prohibited and restricted carcinogens

5. Responsibilities and Accountabilities

5.1 OHS Division

The OHS Division of UQ is responsible for ensuring the following:

  • That a system is in place to ensure copies of worker records detailing possible exposure to P&R carcinogens are maintained for 30 years.
  • That a system is in place to facilitate a ‘letter of exposure’ provided to workers at the end of their engagement, detailing the names of P&R carcinogens the worker may have been exposed to and the time of this possible exposure, in accordance with section 6.6 of this procedure.

5.2 Managers, supervisors and principal investigators

Managers, supervisors and principal investigators are responsible for ensuring the following:

  • That suitable induction and training are provided to a worker who may be exposed during the storage, use and handling of the P&R carcinogen in research work.
  • That all P&R carcinogens are authorised according to the Work Health and Safety Regulation (Qld) 2011.
  • That all requirements identified in the risk assessment and relevant UQ policies, procedures and guidelines are complied with.
  • That all usage and tracking requirements as defined in the risk assessment and relevant UQ policies, procedures and guidelines are complied with.

5.3 All workers

All workers are responsible for ensuring that they comply with all of the requirements detailed in the risk assessment for the use, handling or storage, and disposal of the P&R carcinogen.

6. Process

6.1 Overview of compliance requirements

Under the P&R carcinogens requirements of Work Health and Safety Regulation (Qld) 2011, a workplace must not use, handle or store, or direct a worker to use, handle or store a P&R carcinogen, unless the regulator has authorised the use, handling or storage of the P&R carcinogen. To gain authorisation there are specific requirements for induction and training, recording of spills and other events where actual exposure is likely to occur, issuing of statements of exposure to workers, and record keeping. Refer to the UQ OHS Division website for details of the responsibilities for these activities Carcinogens - Summary of Responsibilities.

Note: this document deals with legislative compliance only. There is a specific procedure covering general requirements for carcinogens and similarly related substances, e.g. cytotoxic drugs and mutagenic chemicals. In most cases meeting legislative requirements detailed in this document will fulfil the procedure requirements, with the exception of the National Health and Medical Research Council approval process if this is applicable to the research work being undertaken. See PPL 2.70.10b Carcinogens Safety - Procedures for further information.

6.2 Induction and training

The induction, information and training provided must include the following:

  • Labelling containers of the carcinogen to ensure that the carcinogen and other chemical hazards are identified, along with reasons why the information on each part of the label has been provided.
  • How to locate and use an SDS using Chemwatch, along with accessing and interpreting information contained in each part of the SDS.
  • The nature of the hazards and properties of the carcinogen to which workers are or may be exposed including routes of entry into the body and potential health risks.
  • Safe work practices to be followed when using, handling, storing, cleaning up and disposing of the carcinogen.
  • Measures used to control exposure to the carcinogen including the correct use and maintenance of these controls. A sign must be displayed within the work area when the carcinogen is in use. Refer to Form D for an example of a suitable sign. Form D - Restricted Carcinogen in Use
  • The proper use, fitting and maintenance of personal protective equipment (PPE).
  • Ensuring workers are competent in emergency procedures, including evacuation and special decontamination procedures.
  • Ensuring workers are competent and aware of first aid and incident reporting procedures to be followed in the case of exposure, injury or illness.
  • Reasons for air monitoring (if required), type of monitoring used and how to obtain the results from any monitoring conducted.
  • Reasons for health surveillance (if required) and the type of surveillance used.
  • Refresher training should considered on an as needs basis determined by the worker's continuity and experience working with carcinogens.

6.3 Application for authorisation to use, handle or store prohibited or restricted carcinogens

Where the P&R carcinogen is to be used for research work (see tables 10.1 and 10.2, section 7.1), an authorisation to use, handle or store must be obtained from WHSQ by the principal researcher of the work group. See Form 74 Application for authorisation to use, handle or store prohibited or restricted carcinogens.

Completion of this application requires the following information to be compiled:

6.4 Tracking carcinogen usage

A process must be documented to track the usage according to the requirements specified in the risk assessment.

To track a worker’s possible exposure to the carcinogen the minimum data to be stored is:

  • Name of carcinogen the worker may have been exposed to (and concentrations if applicable)
  • Date of this possible exposure to the carcinogen (or start and end dates)
  • Full name of worker
  • Date of birth
  • Address

To track usage of the carcinogen the following records must be kept:

  • Name of carcinogen
  • Date of use
  • Quantity
  • Full name of worker
  • Date of birth of worker, or Aurion Number to complement identification along with name
  • Any incident involving actual exposure to the carcinogen

Recording carcinogen usage on the Risk Management Database:

  • The UQ Risk Management Database has a tick box for flagging the use of a P&R carcinogen, and this needs to be checked along with the completion of the field in the risk assessment for entering the WHSQ authorisation number.

It is necessary to establish a carcinogen record on the UQ Aurion Human Resources Information System and Occupational Health Database:

Once Form C - Restricted Carcinogen is received by the UQ OHS Division, the risk assessment and other supporting documentation will be reviewed, details entered on Aurion, and a record created on the UQ OHS Health Surveillance database. The Aurion record ensures that when an exposed individual ceases work their departure can be identified and a letter of exposure generated. The Health Surveillance database records all usage details of the exposed person along with their work history. This record may contain the relevant exposure history for multiple carcinogens the individual has used while working at UQ.

Guidance on record keeping for carcinogen usage:

  • The Principal Researcher who applies for the authorisation and takes responsibility for fulfilling the legislative requirements for the carcinogen must have an Aurion number. This allows for the automatic recording of the start and finish dates of the project through Aurion, as well as ensuring the researcher has suitable experience and academic standing for the responsibility of legislative compliance.
  • The usage logs for a carcinogen are valuable for documenting individual exposure and copies of the usage logs should be submitted to the OHS Division, either periodically or on termination of the project, where they will be attached electronically to the Health Surveillance Database. It would also be valuable to attach electronic copies of the logs to the carcinogen process risk assessment on the risk management database on a regular basis.

6.4.1 Tracking carcinogen usage - workers not on Aurion human resource management system

In most cases workers names on the authorisation for use of the carcinogen will be on the Aurion system, but a minority may be HDR students who are not paid workers, or do not have a Title Holder position making them eligible for entry onto Aurion.

All workers identified on Form C - Restricted Carcinogen submitted to OHS are entered on the Health Surveillance database used for recording health information about the worker. If the project finishes and a bulk termination occurs, alerting OHS through the flags of other workers on the Aurion database, then those workers without an Aurion number will still have an exposure letter generated for them. In some cases a worker not on Aurion may leave the work group before the project ends. In this case it is the responsibility of the Principal Researcher to alert OHS that the researcher is no longer potentially exposed to the carcinogen to enable an exposure letter to be provided to them.

6.5 Finalising carcinogen work - end of exposure

At the end of an employee’s period of possible exposure to the carcinogen (e.g. by end of engagement, end of project or transfer to another area), a record of the carcinogens the worker may have been exposed to, and the time of this potential exposure must be submitted by the Principal Researcher of the Faculty, Institute or School where the worker was engaged, to the OHS Division for inclusion with the employee’s personnel file.

This record of possible exposure to the carcinogen must include:

  • A copy of the authorisation to use, handle or store a P&R carcinogen.
  • The name of the P&R carcinogens the worker may have been exposed to.
  • Start and end date of this possible exposure to the carcinogen.
  • How and where the worker may obtain records of the possible exposure.
  • Whether the worker should undertake regular health assessments and the relevant tests to undertake.

6.6 Compilation of end of engagement letter

At the end of their engagement the Occupational Health and Safety Division will supply to an employee who has used, handled or stored a P&R carcinogen a letter detailing:

  • The name of the P&R carcinogen they may have been exposed to.
  • The time when they may have been exposed.
  • How and where they may obtain records of the possible exposure.
  • Whether the worker should undertake regular health assessments, and the relevant tests to undertaken.

A copy of the signed statement will be uploaded into the OHS 'carginogen use' database and a copy will also be entered into the UQ employee records.

7. Application Guidance

7.1 Carcinogenic chemicals to which this document applies

Carcinogenic chemicals under regulation are detailed in Schedule 10, Table 10.1 and 10.2 of the Work Health and Safety Regulation (Qld) 2011.

Table 10.1 Prohibited carcinogens (can only be used with authorisation)


Prohibited carcinogen [CAS number]


2-Acetylaminofluorene [53-96-3]




4-Aminodiphenyl [92-67-1]


Benzidine [92-87-5] and its salts (including benzidine dihydrochloride [531-85-1])


bis(Chloromethyl) ether [542-88-1]


Chloromethyl methyl ether [107-30-2] (technical grade which contains bis(chloromethyl) ether)


4-Dimethylaminoazobenzene [60-11-7] (Dimethyl Yellow)


2-Naphthylamine [91-59-8] and its salts


4-Nitrodiphenyl [92-93-3]

Table 10.2 Restricted carcinogens (research work is included in restricted use and authorisation must be obtained)



Restricted carcinogen

[CAS number]


Restricted use


Acrylonitrile [107-13-1]



Benzene [71-43-2]

All uses involving benzene as a feedstock containing more than 50% of benzene by volume Genuine research or analysis


Cyclophosphamide [50-18-0]

When used in preparation for therapeutic use in hospitals and oncological treatment facilities, and in manufacturing operations

Genuine research or analysis


3,3'-Dichlorobenzidine [91-94-1] and its salts (including 3,3'-Dichlorobenzidine  dihydrochloride [612-83-9])



Diethyl sulfate [64-67-5]



Dimethyl sulphate [77-78-1]



Ethylene dibromide [106-93-4]

When used as a fumigant

Genuine research or analysis


4,4'-Methylene bis(2-chloroaniline) [101-14-4] MOCA



3-Propiolactone [57-57-8] (Beta-propiolactone)



o-Toluidine [95-53-4] and o-Toluidene hydrochloride [636-21-5]



Vinyl chloride monomer [75-01-4]



8. Contacts for Further Information

Occupational Hygiene Advisor
OHS Division
Phone: 336 52365

UQ Chemical Store
Faculty of Science
Phone: 336 52345/52528

Director, Health, Safety and Wellness Mr Jim Carmichael


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Director, Health, Safety and Wellness Mr Jim Carmichael
Director, Health, Safety and Wellness Mr Jim Carmichael