CHALLENGED with managing manual handling problems or even machine guarding or forklift driving, most Australian managers, with a little help from a visit to the Workcover/Worksafe websites, can cobble together a half passable simulation of a due diligence management plan.
But, chemicals ranging through glycol ethers, creosote, arsenic, MOCA, VOCs, synthetic mineral fibre-glass dust, benzene, carbon disulphide, methanol and a host of other chemicals in the powder coating and painting industries, truly push company managers way beyond their capabilities.
And yet thousands of such non–chemist qualified managers around Australia are attempting the impossible. Consider for a moment what this means for the health of tens of thousands of Australian workers.
This, very largely unrecognised, silent Pandora’s box of killers has the potential to sheet home to these workers a wide variety of work related cancers. And because the exposure periods necessary may be 20 or more years we have not yet begun to face what this exposure really means for Australian workers.
For those bosses who are aware of the risk chemical exposure constitutes and who do take their duty of care obligation seriously this is an introductory guide to “getting started” with developing a hazardous chemicals management plan.
Where to start?
The starting point, as with all OH&S issues, is the development of a policy. Apart from the usual introductory commitments and provision of resources, the policy should address a careful analysis, before purchase, of the potential risks the chemical may pose for the business and its workers.
The policy should also include a formal written labelling program, a request to the supplier of an MSDS (material safety data sheet), the start of a chemicals register that is properly maintained and provision for chemical-specific emergency and first-aid requirements.
A consultation program specific to chemicals handling and use should also be started, as should a risk management regime. Risk control measures should be monitored and periodically reviewed and health surveillance carried out as required. Exposure to contractors and visitors should be considered and planned for. Suitable PPE (personal protection equipment) should be purchased and used, with employees supervised and trained in its use.
All accidents and near misses should be diligently recorded and proper information dissemination programs should be regularly run. Finally the chemical wastes and residues be disposed of in an environmentally responsible manner.
As is readily apparent from the above, even the creation of the policy document covers a lot of ground. The policy document is the fulcrum from which radiates the management systems that need to be developed as past of the management plan.
The Rosetta stones for the close analysis of what is involved in the safe use of the chemicals are firstly the MSDS and secondly the Hazardous Substances database developed by NOHSC. All too often the MSDS cannot be located or it is “old” or the MSDS cannot be supplied.
No great matter – head for the NOHSC data-base launched mid-last year. The study of the information on the data-base is critically important – especially examine workplace exposure standards. This data indicates whether a National Exposure standard has been established for a particular chemical. This then leads the employer/manager to the need for an assessment to be carried out. All too often chemicals are used in situations where the belief of the employer is that the building is “well ventilated” or the technical rep advises that the extractor fan is able to operate at a “better than required exit speed”.
The problem is that if the employer has not carried out the requisite risk assessment as per OH&S Regulations 2001 NSW and its Victorian counterpart then he/she has no documented evidence of compliance with the National Exposure Standard. This is tantamount to serious negligence.
The natural flow-on from a risk assessment exercise is the identification and implementation of a set of risk controls and it is part of the employer’s duty of care that he/she install the appropriate controls in regard to the chemical risks in the workplace.
Control measures can consist of one or two or more of types of controls. The most favoured by the regulatory authorities are:
• Elimination - example: Environmentally responsibly disposal of “old” or out of date chemicals. Every six months conduct a house keeping exercise to this effect.
• Substitution – example: Toxic chemical based products are more and more being replaced with water based substitutes. Ask your supplier’s rep. Also, metals that must be machined have had the chromium, cadmium lead, or other heavy metal removed.
• Isolation – example: With some processes the processing operation is the generator of the toxic fume or vapour. Fume extraction may be the simple answer but another option may be segregating that process.
• Engineering – example: Controls include a variety of essentially dilution actions. The problem that remains is whether the exposure still exceeds the National Exposure Standard, hence the need to determine this standard figure in the first place.
• Administrative – example: These include training of operators in a safe work method (SWM). This SWM should first be developed and formalised in writing. Clearly this is a good example of an opportunity to consult with operators and obtain their input. A formal SWM template should be used, and can be re-used in numerous other situations, including training sessions.
• Personal Protective Equipment. A major problem with PPE is cost. Employers frequently purchase the “el cheapo” safety glasses, face mask or ear-plugs at the local hardware store - “guaranteed” to do the job. Not really – only really guaranteed to end up not being used. You get quality according to the price. PPE is a real problem – not for the reasons that regulatory authority inspectors put up but because of cost. Where employers are dealing with toxic chemicals as set out above and thousands like them, the PPE that does not meet the ASA Standard is a serious threat to a worker’s health.
The new NOHSC hazardous substances database is a great step forward, but how long will it be before companies realise chemical exposure faced daily by their employees is a very serious threat to their workers health, and learn they have serious new legal obligations under the Hazardous Substances legislation?
*Ray Schaffer is a principal consultant with Schaffer and Co , health, safety environment consultants, 02 9878 0613. Visit www.environmentdiy.com.au, pose a question and receive an answer at no cost.