Dangerous goods storage: what triggers an EPA or WorkSafe licence

What triggers a dangerous goods storage licence in Victoria?

Most Victorian manufacturers storing dangerous goods don't need a licence for everyday quantities — but two separate regulators can require one once you cross certain thresholds. WorkSafe Victoria requires notification once stored quantities exceed the levels set in the Dangerous Goods (Storage and Handling) Regulations 2022, and a licence for high consequence dangerous goods (HCDG); EPA Victoria requires a licence for certain higher-risk bulk storage activities under the Environment Protection Regulations 2021, regardless of what WorkSafe requires.

What counts as a dangerous good?

The Dangerous Goods Act 1985 (Vic) defines dangerous goods as substances that are corrosive, flammable, combustible, explosive, oxidising or water-reactive, or otherwise hazardous. WorkSafe Victoria's examples include flammable liquids (petrol, kerosene, some paints), corrosives like hydrochloric acid, flammable gases such as LPG, non-flammable non-toxic gases like CO2, asbestos and explosives. If your manufacturing process generates dangerous goods as a by-product, that counts too — not just goods you purchase and store deliberately.

When does WorkSafe require notification or a licence?

As the occupier of a workplace, your first duty is to identify all dangerous goods stored and handled on site, including anything generated during manufacturing. From there:

• Notification threshold — you must notify WorkSafe if your workplace stores or handles dangerous goods in quantities exceeding the relevant amounts specified in Schedule 2 of the Dangerous Goods (Storage and Handling) Regulations 2022. The specific quantity depends on the class of dangerous good, so check your goods against the schedule rather than assuming.
• Major hazard facilities — sites storing, handling or processing very large quantities of hazardous chemicals may be classified as a major hazard facility under the Occupational Health and Safety Regulations 2017, which brings additional obligations.
• High consequence dangerous goods (HCDG) — a licence is required to import, export, manufacture, store, sell, supply, use, handle, transfer, transport or dispose of HCDG (which includes certain types of ammonium nitrate used in fertilisers), and a permit is required to handle HCDG unsupervised.
• Transport — a separate licence applies to transporting dangerous goods by road or rail above set limits, under the Dangerous Goods (Transport by Road or Rail) Regulations 2018.

Even below the notification threshold, WorkSafe Victoria's Code of practice for storage and handling of dangerous goods still applies — labelling, separation of incompatible goods, and adequate ventilation are baseline requirements regardless of quantity.

When does EPA Victoria require a licence?

EPA Victoria's licensing sits alongside WorkSafe's, not instead of it. Certain "prescribed activities" defined in Schedule 1 of the Environment Protection Regulations 2021 require an EPA permission before you can operate — and the level of permission (registration, permit or licence) depends on the risk. Licences are reserved for the highest-risk activities, such as bulk chemical storage.

A concrete example: under the G04 – Bulk storage activity category, you need an EPA development and operating licence if you store certain carbon-based liquid compounds — including petroleum products and oil — in tanks exceeding 10,000 litres capacity, with a total design capacity of 1 megalitre or more. This applies regardless of whether the same goods also trigger a WorkSafe notification.

Separately from licensing, every business that produces, uses or stores solid or liquid materials — including dangerous goods and waste — has a general environmental duty under Victorian environment protection law to eliminate or reduce the risk of harm to human health and the environment, so far as reasonably practicable. That duty applies whether or not you hold an EPA licence.

How WorkSafe and EPA obligations differ

	WorkSafe Victoria	EPA Victoria
What it's protecting	Worker health and safety	Human health and the environment (spills, leaks, fire, pollution)
Trigger	Quantity thresholds in Schedule 2 of the Storage and Handling Regulations; HCDG status	Prescribed activities in Schedule 1 of the Environment Protection Regulations (e.g. bulk storage above set tank capacities)
What you get	Notification, licence (HCDG) or permit	Registration, permit or licence, depending on risk level
Applies even without a licence?	Yes — code of practice requirements (labelling, separation, ventilation)	Yes — general environmental duty

What manufacturers should do first

1. List every dangerous good on site, including manufacturing by-products, using supplier safety data sheets (SDS).
2. Check quantities against Schedule 2 of the Dangerous Goods (Storage and Handling) Regulations 2022 to see if WorkSafe notification applies.
3. Check storage volumes against EPA's prescribed activity list, particularly if you store bulk liquids like fuels, oils or chemical stock in tanks.
4. Don't assume "below threshold" means "no obligations" — the WorkSafe code of practice and EPA's general environmental duty apply regardless of quantity.

Because the two regulators use different triggers, it's genuinely easy for a manufacturer to be compliant with one and exposed under the other without realising it. A site assessment can map what you're storing against both sets of thresholds in one pass — you can book one with Ardmor's team at https://ardmor.com.au/book-audit.

FAQ

Do I need a licence to store dangerous goods in Victoria? Not always. Below the quantity thresholds in Schedule 2 of the Dangerous Goods (Storage and Handling) Regulations 2022, you generally need to comply with WorkSafe's code of practice rather than hold a licence. Above those thresholds, notification requirements apply, and high consequence dangerous goods always require a WorkSafe licence.

What's the difference between a WorkSafe and an EPA requirement for dangerous goods? WorkSafe Victoria regulates dangerous goods storage primarily to protect worker health and safety, with thresholds set in the Dangerous Goods (Storage and Handling) Regulations 2022. EPA Victoria separately licenses higher-risk activities — like bulk liquid storage above certain tank capacities — to protect human health and the environment from leaks, spills and fire.

Does storing small quantities of chemicals mean no obligations at all? No. Even below notification or licensing thresholds, WorkSafe's code of practice (labelling, separation of incompatible goods, ventilation) and EPA's general environmental duty to reduce risk of harm still apply.

This article is general information for Victorian manufacturers, not legal advice. Last updated: 10 August 2026.