Uncategorised
By Alex Mandl
Alex is the Principal of Shrapnel Explosive Solutions, a dangerous goods and compliance consultancy. He is also a former Chief Inspector of Explosives for Queensland.
Victoria has commenced a significant reform of its dangerous goods regulatory framework following the passage of the Dangerous Goods Transport Act 2026 and amendments contained in the Occupational Health and Safety Amendment (Dangerous Goods) Bill 2026.
The legislation received Royal Assent on 4 August 2026, with the new framework scheduled to commence on 1 April 2028.
For businesses involved in the movement, storage and handling of dangerous goods, particularly those relying on contractors across road, air and sea supply chains, the reform provides a clear timeframe to review existing compliance arrangements before the new legislation takes effect.
A New Legal Framework for Dangerous Goods
The existing Victorian framework regulates dangerous goods transport and storage under the Dangerous Goods Act 1985.
Under the new arrangements, these activities will move into two distinct legal frameworks.
Transport by Road, Rail and Inland Waterways
The Dangerous Goods Transport Act 2026 will become the principal legislation governing the transport of dangerous goods by road, rail and inland waterways.
The new Act is intended to operate alongside the national Australian Dangerous Goods Code, supporting greater consistency for operators undertaking interstate dangerous goods movements.
Storage and Handling
Stationary storage and handling activities will be incorporated into the Occupational Health and Safety Act 2004.
This includes activities such as unpacking, warehouse storage and temporary staging of dangerous goods at workplaces and loading docks.
For businesses involved in freight operations, the distinction between goods being transported and goods being stored or handled within a workplace will therefore become increasingly important.
Operational Implications for Freight Consignors
Responsibility During Transport and Handover
Businesses engaging contractors to move dangerous goods by air or sea may have significant responsibilities associated with the local road transport leg and the point at which goods are handed to another party.
Under the Dangerous Goods Transport Act 2026, the responsibilities associated with the consignor remain an important consideration.
Businesses should ensure that dangerous goods are correctly classified, packaged, marked and placarded, where applicable, before a contractor takes custody.
Documentation responsibilities also remain important. Engaging a subcontractor does not necessarily remove the responsibilities held by other parties within the dangerous goods transport chain.
Loading Docks and Temporary Staging
The movement of stationary dangerous goods activities into the OHS framework places greater attention on loading docks, warehouse floors and other temporary staging areas.
A pallet of dangerous goods that has been unloaded from a vehicle and placed within a facility may be subject to different regulatory obligations from those applying while it was being transported.
This makes the physical interface between transport and workplace handling particularly important.
Temporary staging should therefore be considered as part of the workplace dangerous goods management system, including segregation of incompatible dangerous goods and the management of loading and unloading activities.
Responsibilities of Officers and Management
The incorporation of dangerous goods storage and handling into the OHS Act also increases the importance of existing governance and management responsibilities.
Directors, supply chain executives and operations managers will need to ensure that dangerous goods risks are appropriately identified, resourced and managed within workplace safety systems.
For organisations handling dangerous goods, the reform reinforces the need for senior management to understand how dangerous goods controls operate in practice, rather than treating compliance solely as an operational or contractor responsibility.
The Transition to April 2028
The Dangerous Goods Act 1985 and the existing regulatory framework will remain in force until the new legislation commences.
The commencement date of 1 April 2028 provides industry and government with time to develop the supporting regulations, guidance and implementation arrangements required for the new framework.
WorkSafe Victoria is reviewing the existing dangerous goods regulations as part of this process. Work is also expected to address how stationary dangerous goods requirements will operate within the broader occupational health and safety framework.
Supporting guidance and Approved Codes of Practice may also play an important role in translating the legislation into practical requirements for activities including loading dock management, segregation and contractor handovers.
Industry participation during the consultation period will therefore be important.
Organisations affected by the reforms should monitor consultation opportunities through Engage Victoria and consider whether proposed requirements appropriately reflect operational realities across road transport, warehousing and international air and sea freight.
Preparing for the New Framework
Businesses using transport contractors can begin reviewing several areas before the April 2028 commencement date.
Review Contractor Arrangements
Contracts and Master Service Agreements should be reviewed to determine whether responsibilities for dangerous goods compliance are clearly defined.
Businesses may also wish to review how contractor training, vehicle requirements, documentation and dangerous goods controls are verified.
Map the Physical Interface
Businesses should identify where transport custody ends and workplace staging or storage begins.
Loading docks and staging areas should be reviewed to confirm that appropriate controls exist for incompatible dangerous goods and other foreseeable handling risks.
Review Multimodal Documentation
Businesses involved in international movements should also consider how their internal dispatch systems accommodate different regulatory requirements.
Documentation may need to satisfy Australian land transport requirements under the ADG Code as well as applicable international air or sea transport requirements under the IATA Dangerous Goods Regulations or the IMDG Code.
Final Reflection
Victoria’s dangerous goods reforms represent a significant structural change in how transport, storage and workplace handling will be regulated.
The new legislation does not commence until April 2028, and the detailed regulations and supporting guidance will be critical in determining how the framework operates in practice.
For industry, the transition period provides an opportunity to examine existing contractor arrangements, loading and staging practices, documentation systems and governance responsibilities before the new requirements take effect.
The most effective preparation will be based on understanding where responsibilities sit across the entire dangerous goods movement, particularly at the points where transport, workplace handling and contractor responsibilities intersect.