CHEMICAL

HAZARDS IN THE WORKPLACE

ADVICE FOR MANAGERS AND SUPERVISORS

MANAGING

GUIDE 1996

WorkCover NSW Health and Safety Guide

WorkCover. Watching out for you.

New South Wales Government

Disclaimer This publication may contain occupational health and safety and workers compensation information. It may include some of your obligations under the various legislations that WorkCover NSW administers. To ensure you comply with your legal obligations you must refer to the appropriate legislation. Information on the latest laws can be checked by visiting the NSW legislation website (www.legislation.nsw.gov.au) or by contacting the free hotline service on 02 9321 3333. This publication does not represent a comprehensive statement of the law as it applies to particular problems or to individuals or as a substitute for legal advice. You should seek independent legal advice if you need assistance on the application of the law to your situation. WorkCover NSW

CONTENTS INTRODUCTION THE SIx bASIC STEPS POLICy AND PROGRAM JOINT CONSULTATION TRAINING IDENTIFy AND ASSESS WORKPLACE RISKS RISK CONTROL PROMOTE, MAINTAIN AND IMPROVE CHECKING yOUR WORKPLACE WHERE TO GET HELP 2 2 3 4 5 6 9 11 13 14

Introduction

PURPOSE The purpose of this booklet is to introduce managers and supervisors to the requirements of the Occupational Health and Safety (Hazardous Substances) Regulation 1996, (the Hazardous Substances Regulation for short). There is also a code of practice to help you implement the Regulation: the Code of practice for the control of workplace hazardous substances, (or the Control code of practice for short). For the retail industry, a Guidance Note for the Control of Workplace Hazardous Substances in the Retail Sector is available. This booklet outlines how you can protect yourself and others in the workplace from the harmful effects of chemicals and other substances. It suggests ways in which you can manage the health hazards posed by the use of substances which are classified as hazardous by the Regulation. Employees must be consulted when identifying hazards and the control measures to be taken. Workplace OHS committees have an important role here. Your committee (if you have one) should be included when developing your policy and procedures.

PUbLICATIONS A number of leaflets and guides on the Hazardous Substances Regulation are available from WorkCover NSW - see back of this guide for details.

The six basic steps

By assessing the risks arising from the use of hazardous substances at work, you can help protect workers health. The Regulation has a number of requirements. Taken together, they provide a way of managing risk. There are six basic steps involved: Six basic steps to safely manage chemicals in the workplace 1. 2. 3. 4. 5. 6. Policy and program. Joint consultation. Worker training. Identify and assess the risks in the workplace. Use adequate risk control measures, including appropriate storage and emergency plans. Promote, maintain and improve this includes monitoring, record keeping and accident reporting.

In carrying out these steps, it may be necessary to delegate tasks to various managers and supervisors in your organisation. It is also important that supervisors and managers adopt day-to-day procedures to check and maintain health and safety procedures in the workplace. So, some tasks should become part of their normal duties.

Step 1 Policy and program

OHS POLICy The first step in achieving improvements in workplace health and safety, including the use of hazardous substances, is to have an occupational health and safety policy. Your health and safety policy is a statement of a principle that your organisation upholds. It should state your belief and intent, give a clear direction from management and include the entire organisation. It will also be the basis for any occupational health and safety decisions and actions. In summary, make sure that your policy: shows commitment ensures accountability at all levels encourages co-operation is able to be clearly understood by employees.

CHEMICAL SAFETy PROGRAM The principal aim of a chemical safety program is to systematically investigate potential chemical hazards in order to minimise the risk of adverse health and safety effects due to exposure to hazardous substances in the workplace. Larger workplaces should have a chemical safety program which consists of: a n action plan which details the part that employers, employees and the health and safety committee are each expected to play a list of program procedures organisation charts showing lines of responsibility emergency plans audit reports records of any accidents or potentially hazardous incidents.

For very small workplaces, some of the items of this program may not be practical. The program should also aim to ensure that employees with potential for exposure to hazardous substances used at work are provided with education and training. This should cover the nature of hazards and means of assessing and controlling exposure to workplace hazardous substances.

Emergency services and other relevant public authorities must have access to relevant information on workplace hazardous substances and implement appropriate emergency procedures. There must be regular checks on the performance of exposure control measures. An adequate level of information should be provided to employees through the provision of MSDS, labelling and training. All hazardous substances used at work should be provided with labels and MSDS which conform to the NSW Hazardous Substances Regulation Standard. Dangerous goods must be stored in accordance with the NSW Dangerous Goods Regulation. Standard operating procedures (SOP) should be developed which provide an organised and planned approach to ensure safety control and accident prevention for maintenance. These SOP record that correct procedures have been followed. Safety systems must be systematically documented. Standards must be set for health and safety management work. Provision must be made for regular auditing and review of safety systems against standards. The levels of responsibility for managers and employees should be specified along with the tasks and goals for each of these groups in relation to each of these elements. Many of these issues will be refined and developed in the successive steps below.

Step 2 Joint consultation

The Regulation requires employers to consult with employees (who are likely to be exposed to risks) on all aspects of the Regulation and any changes to work practices. Exposure often depends on the way the chemicals are used. When doing an assessment, involve the people working with the product in helping to identify the hazards. Consult employees, supervisors and others with knowledge and expertise, including plant managers, production managers, floor supervisors, union representatives and members of the workplace OHS committee. Health and safety procedures, such as exposure control measures, should not be introduced without first consulting all people likely to be affected by any hazardous substance. This includes determining the likely exposure of people working near to where hazardous substances are used, as well as those who use them directly.

FORMING AN OHS WORKPLACE COMMITTEE The Occupational Health and Safety (Committees in Workplaces) Regulation 1984 has detailed provisions on the formation, composition and regulation of OHS committees. The Regulation applies to workplaces with 20 or more employees. The Occupational Health and Safety Act, 1983 states that an OHS committee must be established if the majority of the persons in that workplace request it. For more information, refer to the WorkCover publication, How to establish an occupational health and safety committee in your workplace. The workplace OHS committee also has an important role in recommending that appropriate training and instruction is carried out in the workplace.

Step 3 Training

Information must be given to workers, through training. To ensure that everyone in the workplace receives relevant information, a formal, regularly updated training program must be developed. The training program should be related to the activities in the workplace and cover: how chemical exposures can occur the possible results of chemical exposure how to read chemical labels and MSDS how to follow safe working procedures how to use protective equipment emergency and first aid procedures. Training should also explain the need for workplace monitoring and health checks in relevant cases.

A training package, entitled Occupational Health and Safety Workplace Substances Training Course has been developed by WorkCover. This is designed to assist employers in meeting their requirements under the Hazardous Substances Regulation. It is available to trainers accredited by WorkCover. For further information, please contact the WorkCover Occupational Health and Safety Education Unit on ph: (02) 370 5290.

Step 4 Identify and assess workplace risks

FIND INFORMATION AND PROVIDE IT Information about a chemical used in a workplace is found: on the label of the container; on the Material Safety Data Sheet (MSDS); and in publications such as codes of practice and standards.

The label on the container is the first point where people get information about the chemicals they are using. In many situations, you can tell if substances are hazardous from the labels on containers arriving in your workplace. So, many employers will not have to know the technical details of the classification. However, if you produce or import hazardous substances then you are responsible for classifying them. You must use the official definition. The details are given in the Worksafe publication Approved Criteria for Classifying a Hazardous Substance. Common hazardous substances are included in the Worksafe publication, List of Designated Hazardous Substances. You can get these from the WorkCover bookshop or from a Commonwealth Government bookshop (see back of this guide for details). The definition of a hazardous substance includes mixtures.

LAbELS You must make sure that containers of chemicals and other hazardous substances in your workplace are labelled. Labels identify the product and provide safety information including: the dangerous goods diamond and/or the poisons label, where appropriate the chemical name(s) of the ingredient(s) the trade name of the substance possible harmful effects of the substance how to use the substance safely.

If the label does not give you this information, contact the supplier or manufacturer. You must ensure that the labels on containers of hazardous substances are appropriate. If you produce hazardous substances, you should label them according to Worksafes Code of Practice for the Labelling of Workplace Substances. Process containers, such as vats and pipes, should be labelled to identify the contents.

MATERIAL SAFETy DATA SHEETS - MSDS The material safety data sheet (MSDS) should provide detailed information about: the substances trade name and chemical name(s) (including ingredients in mixtures) health hazard information precautions for use safe handling of the substance.

The MSDS must be readily available so that workers can get information about health hazards in addition to that provided on the label. The manufacturer or supplier of the chemical must provide an MSDS with every substance that is classified as hazardous. Manufacturers and importers are responsible for preparing MSDS. The MSDS should meet the standard laid down in Worksafes Code of Practice for the Completion of a Material Safety Data Sheet. For imported substances, ILO (International Labour Organisation) and EU (European Union) formats are acceptable.

ASSESS THE RISKS IN yOUR WORKPLACE People can be exposed to the same hazardous substance in different ways. The level of exposure may vary depending on factors such as how close to a process a person is working, or the effectiveness of ventilation. Under the Regulation, you must assess the exposure risks of each hazardous substance, for each person in the workplace. The results will indicate the areas where control measures are necessary. Risk is the likelihood that harm will result from use of the substance. Hazard is a basic property of a substance (for example its toxicity as determined by tests). The degree of risk depends on the dose - that is, how much of the hazardous substance can actually get into the body. To assess the risk of exposure: a. b. c. d. e. identify the hazardous substances used in the workplace and list them in an inventory; obtain information about the hazards to health and safety presented by these substances; determine the degree of exposure to the hazardous substances; assess the risk to the health and safety of each employee, and decide actions necessary to control risks.

IDENTIFy SUbSTANCES It is important for you to know exactly what hazardous substances are in use in the workplace. Initially check if everything is labelled. Make a list of all hazardous substances to form an inventory. Dont forget to consider dusts and other emissions produced in the workplace. A mixture counts as one substance. Adopt a system that will ensure all new chemicals entering the workplace are added to the inventory and that MSDS are obtained and filed with the inventory, forming a register. This task may be easier if you divide your workplace up into areas or work activities and do each one separately.

Routes of entry:

ObTAIN INFORMATION Next, make sure you have MSDS for all the hazardous substances delivered to your workplace. Check the MSDS for data on health hazards and precautions for use. Compare this with your existing situation. You may not have an MSDS for dusts and emissions, so you should compile information like that contained in an MSDS.

DETERMINE ExPOSURE breathing in Check who is using which hazardous substance and how. Then identify those employees who may be exposed to each hazardous substance in an amount which is likely to harm health. Consider the routes of entry, that is the ways the substance may enter or touch the body. These include skin contact; inhalation (breathing in) through the nose or mouth; and ingestion (swallowing) through the mouth.

ASSESS THE RISK TO EACH EMPLOyEE The Control code of practice gives guidance on how to do an assessment. The Worksafe Guidance Note for the Assessment of Health Risks Arising from the Use of Hazardous Substances in the Workplace is also useful here. You may be able to use information from other similar workplaces as a guide. You may find that there is no risk to health. In this case, record this in your register. On the other hand, it may be necessary to use a wide range of extra information. This may include measurements of the amount and time of employee exposure. This is called monitoring, and should be done by a competent person, skin contact such as an occupational hygienist. Air monitoring of the workplace may be required at regular intervals, to check on the effectiveness of control measures. This need should be specified in the assessment report.

swallowing

The Regulation requires you to minimise the health risks - this means that exposure should be as low as possible in your working situation. If a maximum exposure level has been set for the substance, you can usually find this on the MSDS. You must not exceed the exposure limit listed in the Worksafe Standard, Exposure Standards for Atmospheric Contaminants in the Occupational Environment. These exposure standards are regularly updated. For a small number of hazardous substances, regular health checks of workers may be required. The assessment report should determine if this is required. Further information is given in the next section, Decide action to control risks. Air monitoring may be required at regular intervals If the exposure of an employee reaches the exposure standard, or there are health indications that exposure is too high, immediate action must be taken to reduce the health risk. An example of action to be taken is to improve control measures.

DECIDE ACTION TO CONTROL RISKS If the assessment shows that there is a risk to health or safety, you will need to: record the assessment and conclusions about control; select control measures; ensure that those control measures are properly used and maintained; arrange induction and training; and determine if monitoring or health surveillance are required

Step 5 Risk control

The Regulation requires you to implement control measures to keep exposure to hazardous substances as low as practicable, when an assessment has shown the need. The Control code of practice outlines the various measures which can be used to eliminate or reduce exposure. These measures are listed in order of priority, so the higher up the control appears on the following list, the better it is.

ELIMINATION Where a task involves the use of a hazardous substance that is not essential, the hazardous substance should be eliminated, if practicable. An example of elimination is cleaning by the use of ultrasound instead of chemicals - this is a physical rather than a chemical process.

SUbSTITUTION Substitution includes exchanging the hazardous substance for a less hazardous one; using the same substance in a less hazardous form; or using the same substance in a less hazardous process. Examples include: using a less toxic pesticide and using a non-flammable solvent in place of a flammable solvent.

ISOLATION Isolation of the process by distance or the use of barriers can prevent or reduce employee exposure. The remote operation of a process is an example of isolation.

ENGINEERING CONTROLS Engineering controls involve the use of plant or processes which: minimise the generation of hazardous substances (that is, they are less likely to create hazardous substances) suppress or contain hazardous substances (so the substance is not released) limit the area of contamination in the event of spills or leaks.

Engineering controls include enclosure or partial enclosure, local exhaust ventilation and automation of processes.

SAFE WORK PRACTICES Safe work practices are administrative practices which require people to work in safer ways. Examples include: permit to work systems; excluding any nonessential access; providing means for safe storage and disposal of hazardous substances; banning eating, drinking and smoking in contaminated areas; vacuuming dust from areas where cutting processes take place; keeping lids on containers when they are not in use; and using facilities for effective decontamination.

PERSONAL PROTECTIVE EqUIPMENT As far as practicable, control exposure by the measures listed above rather than by the use of personal protective equipment (PPE). Limit the use of personal protective equipment to situations where other control techniques are not practicable or where they do not adequately control exposure. PPE may be used as a temporary measure until adequate control is achieved by other means (for example, where urgent action is required because of plant failure or during routine maintenance operations). Although exposure occurs regularly during such work, the infrequency and small number of people involved may rule out other control measures.

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Personal protective equipment must be selected and used in accordance with WorkCover NSW approval (for equipment where approval is given) and in compliance with the relevant Australian Standards.

ENSURE CORRECT STORAGE Check the MSDS for advice on storage and chemical compatibility. All substances which are classed as dangerous goods should be stored in accordance with the Regulations of the Dangerous Goods Act, 1975. Dangerous goods entering the workplace are usually identified by the class (diamond) label on the container. WorkCover has an accredited dangerous goods consultant scheme.

ESTAbLISH EMERGENCy PLANS You should establish and write down an emergency plan and procedures in case of leaks, spills or other uncontrolled releases of hazardous substances. The procedures should cover: first aid, emergency showers, evacuation procedures, safe disposal methods, identifying source(s) of release, repairs and follow-up. The plan should be revised from time to time. Details of the plan should be included in employee training.

Step 6 Promote, maintain and improve

MONITORING AND HEALTH SURVEILLANCE In some situations you may need to regularly check the amount of hazardous substances in the air. This ongoing air monitoring is in addition to the initial assessment. It is needed in order to check that control measures are working and that worker exposure is minimised. A workplace air monitoring program should be carried out by, or in consultation with, a properly qualified person, for example an occupational hygienist. Records of the results of workplace monitoring must be kept for 30 years. Where employee exposure is found to be close to the exposure standard for the substance in use, or where medical reasons indicate the exposure is too high, immediate action must be taken to reduce the health hazard. For a small number of hazardous substances, the additional step of regular health checks for workers may be necessary. A list of substances requiring health surveillance is included in the Hazardous Substances Regulation. Regular checks of people exposed to hazardous substances helps in detecting early changes to health related to the exposures. It provides a record of any toxicity in individuals. This may involve a medical examination or other tests, such as blood or urine tests. In some cases health surveillance may be required in addition to workplace air monitoring.

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Health surveillance reports are confidential and employees reports cannot be released without their written consent. Individuals should be informed of their surveillance results. The employer is also informed of the results and the need for action, if any. WorkCover NSW must be notified of certain adverse effects found through health surveillance. Advice can be obtained from WorkCovers Occupational Medicine Branch, on (02) 370 5153.

RECORD KEEPING The employer must ensure: that the results of health surveillance remain confidential and are held for not less than 30 years other records, such as assessment reports and the results of air monitoring, which do not indicate a need for surveillance are kept for at least five years.

Records must be kept for this long period because some health effects, such as cancer, may take a long time to become evident. The medical practitioner is also required to keep the medical records obtained as a result of health surveillance as confidential records. The records must be given to WorkCover, not destroyed, if the workplace or medical practitioner ceases to trade. Accidents and injuries often highlight the need for safety measures. Workplaces should establish practical systems for reporting and recording accidents, occupational illnesses and incidents, such as chemical spills.

ACCIDENT REPORTING PROCEDURES The OHS workplace committee should monitor the system of accident, illness and incident reporting and recording in the workplace. To this end, the committee can examine statistical data and reporting procedures on accidents and diseases in the workplace. The committee should examine how well the accident reporting and recording system is functioning and advise on improvements. The legal requirements for reporting accidents, illness and incidents to WorkCover NSW should also be followed. To assist with injury and disease reporting in the workplace refer to Australian Standard AS 1885.1 - Workplace Injury and Disease Recording Standard.

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Checking your workplace

The following checklist is designed to help you carry out the above management plan. HAZARDOUS SUbSTANCES MANAGEMENT CHECKLIST 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. Are all containers of hazardous substances adequately labelled? Have MSDS been obtained for all hazardous substances in use? Does the workplace have a hazardous substances register listing the chemicals used at the workplace? Has an assessment of the risks of exposure to hazardous substances been carried out? Have recommended control measures been documented? Have recommended control measures been put in place? Are there written procedures for the introduction of new substances to the workplace? Is air monitoring necessary? If yes, has this been scheduled and a competent person appointed to do it? Has a training program for people using hazardous substances been established? Have all the people who should be trained under the training plan received current training? Have all the confined spaces on the site been identified and work procedures written down including permit to enter procedures? Are health checks necessary? If yes, have these been scheduled and a competent person appointed to do them? Are dangerous goods stored in compliance with the dangerous goods Regulations? Have emergency procedures been established and documented? Do regular emergency drills take place? Are drills evaluated and observed shortcomings addressed? Are waste hazardous substances disposed of appropriately? Are there written procedures for this?

12. 13. 14. 15. 16.

Some of these steps can be taken before you order new chemicals. Particularly when planning a new process, compare alternative chemicals and use the MSDS to check possible hazards. Make sure that MSDS are provided when sales representatives give you trial chemicals.

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Where to get help

For assistance and advice contact WorkCover by: Phone: 13 10 50 Email: contact@workcover.nsw.gov.au Visit the WorkCover website at www.workcover.nsw.gov.au Order publications by calling 1300 799 003.

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