Do you have any chemicals that can be used to treat human or animal diseases? Such as antibiotics, hormones, growth factors, certain enzymes or vaccines? Or chemicals that can be poisonous at low amounts? You have purchased them under University permit – quite often without realising it as distributors hold our permit on file and supply chemicals without asking for permit every time order is placed for the regulated chemical.
University holds an SA Health issued permit that allows us “to manufacture, supply, possess and use for the purposes of research, instruction, training or analysis” Schedule 2, 3, 4 and 7 poisons and selected Regulation 25 poisons (list further down). Therefore we need to ensure that all schedule 2, 3, 4, 7 and Reg 25 chemicals in your possession are treated according to the conditions on the permit. The following conditions are listed on our permit and we must be compliant to be allowed to use the permit (please note: “premises” are Bedford Park campus and “permit holder” is University):
The poison(s) that may be possessed are:
SCHEDULE 2, 3, 4 AND 7 POISONS including the following Regulation 25 poisons:
- arsenic as an S7 poison
- cyanides as S7 poisons
- fluoroacetic acid
- methyl bromide
- strychnine as an S7 poison
1. The poisons must not be re-sold or supplied to any other person. What it means: do not gift/provide to collaborators at other institutions.
2. The permit holder shall store scheduled poisons in suitable containers, appropriately labelled, and shall store Schedule 2, 3, 4 and 7 poisons, when not in use, in a locked receptacle or enclosure. What it means – chemicals must be stored in locked cupboards, safes, fridges, freezers. If fridge/freezer cannot be locked – then a lockable box such as small key/petty cash safe can be used and stored in the fridge/freezer.
3. The poisons shall not be kept elsewhere than at the premises specified, except when in accordance with written guidelines or protocols prepared by or on behalf of the permit holder.
4.Access to the poisons shall be restricted to persons under the direction of the permit holder, or in accordance with written guidelines or protocols prepared by or on behalf of the permit holder.
5. A record indicating the quantity of each Schedule 2, 3, 4 and 7 poison manufactured, produced, received, used or destroyed during the currency of this permit must be kept by the permit holder. What it means: a record sheet (one per container) must be kept that has information about purchase, usage and disposal of scheduled chemical. Click here for an UPDATED generic usage sheet – you can add extra fields to it for your convenience, but do not remove any prompts.
6. The permit holder shall comply with the requirements of the SA Health ”Suspected Theft or Loss of Drugs or Substances from Licence or Permit Holders” policy dated September 2011. What it means: notify WHS unit if you suspect theft or notice unauthorised or unaccounted use.
The scheduled substances are listed in the SUSMP document (short for “Standard for the Uniform Scheduling of Medicines and Poisons” known in short as “Poisons Standard”) and fall under the following categories (definitions from SUSMP):
- Schedule 2 – Pharmacy Medicine – Substances, the safe use of which may require advice from a pharmacist and which should be available from a pharmacy or, where a pharmacy service is not available, from a licensed person.
- Schedule 3 – Pharmacist Only Medicine – Substances, the safe use of which requires professional advice but which should be available to the public from a pharmacist without a prescription.
- Schedule 4 – Prescription Only Medicine, or Prescription Animal Remedy – Substances, the use or supply of which should be by or on the order of persons permitted by State or Territory legislation to prescribe and should be available from a pharmacist on prescription.
- Schedule 7 – Dangerous Poison – Substances with a high potential for causing harm at low exposure and which require special precautions during manufacture, handling or use. These poisons should be available only to specialised or authorised users who have the skills necessary to handle them safely. Special regulations restricting their availability, possession, storage or use may apply.
The link to the SUSMP document is here:
Click on the pdf link – 722 pages – and look in the relevant alphabetical lists. For example, antibiotics are mainly in Schedule 4 (pages 58 – 151).
You can also see if chemical is a “scheduled” chemical in the SDS from Chemwatch by checking “Poison schedule”:
Please click here for UPDATED usage sheet (you can modify it to suit your particular circumstances. One record sheet per container please). All fields above the table must be filled – it is also a reminder that all hazardous chemicals must have RA and all protocols that use them also must have RA (and SWP if any risks are identified in the RA). If a group of chemicals is always used together (eg in cell culture or molecular biology) they can be risk assessed together on one form. Contact Hanna.firstname.lastname@example.org for guidance.
If during the audit of your chemicals you identify some that you haven’t used for a while – arrange for disposal. One less record sheet and hazardous chemical risk assessment that you will need to prepare. Click here for FMC disposal form.
If the tasks seems to be a large one – prioritise and start with the chemicals in current/regular use.
Please contact the below for any help or clarification: