Safety, Health and Wellbeing

Concessional spirits

Our role is to develop and assist in the implementation of the UWA safety, health and wellbeing programs in order to minimise the risk of injury, illness and property damage.

We provide consultancy and other services to promote best practice and legislative compliance in all University and related activities.

Various groups within the University use potable ethanol for scientific and technical purposes, and this ethanol would normally be subject to excise and duty as drinkable alcohol.

UWA, however, holds a permit to purchase and use concessional ethanol (alcohol purchased free of duty and excise). This exemption is based on the premise that the ethanol will not be used for human consumption.

A key condition of this permit is that all use of concessional ethanol within UWA must be accounted for and recorded. The resulting records must be retained for audit purposes. There are separate permits for the main Crawley Campus and the Queen Elizabeth II Medical Centre site.

Legislation

Requirements

Use of concessional ethanol under the relevant permit is subject to periodic audit by personnel from the Australian Taxation Office (ATO), acting on behalf of the Australian Customs Service. The permits outline a maximum quantity of ethanol permitted to be purchased from nominated suppliers in any 12-month period. The nominated suppliers are also given authorisation by the ATO to provide no more than the stipulated maximum quantity of ethanol to UWA users in any 12-month period.

The two UWA permits (Crawley Campus and QEII) specify total annual allocations of ethanol for the entire University. These allocations arose by consolidating individual allocations for various purchasing centres across the University that identified a need to use concessional ethanol when the permit was obtained.

Each of these users identified one or more nominated suppliers, to whom any orders would be limited for the period of validity of the permit. For each supplier, a maximum supply quantity was also stipulated. These allocations are fixed until the next permit renewal (usually every three years).

Each purchasing centre is limited to the allocation of ethanol they nominated at the time of renewal of the permit, from the suppliers they nominated. Ordering of ethanol in excess of these limits or from other suppliers will see one purchasing centre consuming ethanol allocated for another area, and ultimately other areas will be denied the right to purchase ethanol until 12 months have expired.

Records

Meticulous records must be maintained for a minimum of five years for all use of concessional ethanol. If use is not recorded and significant anomalies are found during audits by the ATO, duty and excise can be charged for the entire UWA consumption for the previous five years, at a rate of $74.72 per litre (as at February 2012). Thousands of litres are used annually within the University, so this represents a significant financial penalty.

The information required to be recorded and maintained in records is:

  • the quantity of ethanol taken/used*
  • the name of person using ethanol
  • the purpose of use (solvent, sterilisation)
  • date
  • signature.

*Signatures must be collected for the final use of the ethanol. Generally this translates to signing for laboratory-sized containers such as lab bottles or winchesters at a maximum. Where larger stocks of ethanol (20 L for example) are purchased (for example, from the Chemistry Store where allocations have been arranged), the purchasing person must sign for the 20 L from the store, but the recipient area must then maintain its own records for the use of that 20 L of ethanol as it is consumed by various users within that area.

The easiest way to maintain records for the purpose of auditing is to retain a copy of all invoices for ethanol purchased (or T forms for internal transactions) along with the associated records sheets for the consumption of each invoice quantity. The records then constitute a self-contained audit trail, with each invoice (or T form) accounted for through the attached usage records.

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