Dangerous goods and hazardous substances training in New Zealand

Nothing, chemically. The same diesel, LPG or acid is called a dangerous good when it’s being transported and a hazardous substance when it’s sitting in your workplace. The names come from two separate legal systems: NZTA administers the Land Transport Rule: Dangerous Goods 2005 for anything on a road, and WorkSafe administers the Health and Safety at Work (Hazardous Substances) Regulations 2017 for storage, handling and use. Complying with one tells you nothing about whether you comply with the other, which is where most businesses come unstuck.

How you’re using it determines the training you need.

Usually, if you’re carrying them for hire or reward. Transport operators and couriers generally need one. But the exceptions matter and they’re wider than most people expect: goods carried as tools of trade, for agricultural use or for a commercial purpose in quantities under the limits in Schedule 1 of the Rule don’t require an endorsement, and neither do goods carried for domestic or recreational purposes below those limits. Substances classified UN 3077 or UN 3082, environmentally hazardous and toxic to the aquatic environment, are excepted even above the limits.

Several situations. Small packages of dangerous goods in limited quantities or consumer commodities can be carried without a declaration, placards or an endorsement, provided the aggregate quantity doesn’t exceed 50 litres or 50 kilograms including packaging. Dangerous goods in excepted quantities (very small amounts of low-danger product, the classic example being 30 millilitres of perfume) allow up to 1,000 packages with no declaration, segregation, placards or endorsement. A driver under the direct supervision of a passenger who holds a current D endorsement is also covered. Note that many dangerous goods can’t be carried as small packages at all. You do need a D endorsement to carry lithium ion batteries for a solar power system, but you don’t when they are just for your power tools. Understanding the quantities is key.

Being under the limit removes the endorsement, not the duty. If you carry dangerous goods as tools of trade, for agricultural use or for a commercial purpose within the Schedule 1 limits, you’re still responsible for making sure the goods are properly packaged and identified, segregating incompatible substances so they can’t react, securing the load on the vehicle, and carrying emergency response information. A tradesperson with a couple of gas bottles and some solvent in a ute is inside this regime whether they realise it or not.

When you hold flammable or oxidising substances above set quantities. WorkSafe’s thresholds are specific: one extinguisher for more than 50 kg of non-permanent 2.1.1A gas or 30 cubic metres of permanent gas, and two for more than 200 kg or 120 cubic metres of 2.1.1B. For flammable liquids, one extinguisher above 50 litres of a 3.1A substance and two above 200 litres, or two above 250 litres of 3.1B. Extinguishers need a minimum 30B rating and must be clearly visible and readily accessible. The old rule about being within 30 metres was replaced in 2017.

The Regulations don’t say “spill kit”; they require you to control the adverse effects of spills and container failure, which is a broader duty. In practice a spill kit sized to what you hold is the usual way of meeting it. Separately, pooling substances above certain quantities require a secondary containment system — a bund or equivalent capable of holding the contents if a container fails. Buying a kit off the shelf and hanging it on a wall doesn’t discharge the duty on its own; the kit has to match the substances, and someone has to know how to use it, so training is important.

Enough to do the job safely, which the Regulations frame as workers being effectively trained and supervised. That means understanding the substances present, reading and using safety data sheets, knowing the labelling and signage, understanding segregation, understanding the risks, knowing what to do in a spill or fire, and knowing where the emergency response plan and equipment are.

Our courses cover this information.

An inventory of the hazardous substances you hold, safety data sheets for each of them, a site plan showing where they are, and training records for your team. Depending on what you store and how much, you may also need location compliance certificates, stationary container system certificates and approved filler certificates. The inventory is the one that gets neglected and the first thing an inspector asks for, because everything else — extinguisher requirements, containment, signage, certification — is calculated from what’s on it.

Gas cylinders, fire extinguishers, aerosols and non-refillable gas canisters are covered by Part 15 of the Hazardous Substances Regulations, which deals with gases under pressure. Storage separation distances apply — for example, LPG cylinders in quantities over 100 kg must be kept clear of buildings or protected by fire-resistant construction. Cylinders forming part of a vehicle, ship or aircraft follow the transport rules for that mode instead. Separate training is required for forklifts using LPG as fuel.

On private land the transport rule doesn’t apply, but the workplace duties do, and the machine matters. Forklift operators moving LPG cylinders, fuel or chemical drums need to understand segregation, damage risk and what to do if a container fails. If the forklift itself is LPG-powered, whoever changes the bottles is handling a hazardous substance. None of this requires a D endorsement, and quite a lot of it gets overlooked because the goods never leave the yard.