OUR daily newspapers and television newscasts have in recent months featured stories about the harm that can be caused by asbestos and toxic chemicals.
Think for example of James Hardie and the dangerous task of sealing fuel tanks on F111 aircraft. For the most part the people who inhaled the asbestos while renovating their house or inhaled the toxic chemical fumes inside the aircraft’s fuel tanks had no idea that exposure would become in time - life threatening.
No less serious, though less likely to hit the headlines is the fact that all too often large medium sized and small companies are storing either bulk or some toxic chemicals in their factories and warehouses about which nothing is being told to employees.
It is not that the bosses are keeping the chemicals’ storage secret, rather, nothing is said about the storing of the chemicals and the workers simply do not know what are the toxic chemicals they are moving by forklift and stacking in the company warehouse/factory.
The exposure takes place through inhalation and via skin contact. Worse still, in most scenarios of this type the companies do little about removing from the surface of the loading dock and the concrete deck of the warehouse/factory, the chemical dusts that accumulate over days and weeks.
At best, they may once a week “clean up”, but the machines used to lift these chemical dusts do a less than perfect job.
And so they inhale the dust unaware that they are inhaling dangerous chemicals. Moreover they get these chemicals on their hands and clothes and carry these around the factory in to the lunch room and even take these deadly messengers home to their families.
Sure, the bigger the corporation the more chance that they have proper safety measures in place but, and this is where the problem lies, it is the SMEs that are the worst offenders. And there are a lot more SMEs than large corporations.
Hazardous vs Dangerous
Let us start at the beginning. Hazardous chemicals must be distinguished from dangerous goods.
Hazardous chemicals are defined as having the potential to cause harm to health, over a period of time – even years. While dangerous goods are those that can cause a threat to health or the environment with immediate effect, for example, acids, alkalis, flammables etc.
The problem however is that some substances can be both hazardous and a dangerous goods at the same time. For employers this is a double-edged sword. Since under section 8 of OH&S Act they have an onerous duty of care to employees, for amongst other things a duty to inform – such as in the case of hazardous/dangerous substances with potential to impact on the health of employees.
A duty often paid scant attention. And one that is made daily more complicated since cost savings and cost effectiveness are the battle cries of the business owners continually searching for any way possible to reduce outgoings.
Opportunities to reduce overheads present themselves in the form of new chemicals or synthetics formulated to make the manufacturing process more simple, or one that has fewer steps or one that requires less processing (thus ensuring cost savings).
The problem is, these new synthetic chemicals often have serious side effects. Whether this is through being toxic to humans and the environment or less biodegradable or being both hazardous and dangerous goods in one. (ie toxic and flammable ).
The real world
The problem is characterised by a scenario where the buyer/s in the organisation decides to purchase a new cheaper synthetic.
Several bags duly arrive, loaded on a pallet and the company’s forklift driver transports the load to the warehouse to be stored on pallet racking.
Quite possibly a bag (or two) are snagged and start to leak powder. Chances are the bags of chemical are going to be there for some weeks, if not months and more likely than not, no one has alerted anyone in the business about how to safely handle this new toxic chemical. It may eventually be recorded in the company’s hazardous chemicals register, more likely such a register does not exist.
Since, it is a new chemical there will very likely not be an MSDS (Material Safety Data Sheet) in the company’s offices. So, no one even has the chance to come to the realisation that the chemical needs special handling.
For example, separation from other chemicals, particular first aid or emergency precautions or special handling techniques, worse yet, as described in our scenario - a bag is leaking powder on the warehouse floor.
Often this nuisance is simply swept with a broom or shovel in to a neat pile under the spot where the bags of the chemical have been stacked. Consider the threat this hazard poses for those workers who may in ignorance handle and try to clean up.
Worse yet, all the personnel in the warehouse are carrying the hazardous chemical around on the soles of their shoes, in to the lunch room and in to the offices of the factory.
Now, there are those superior types who may respond with a self-righteous “that could never happen at my factory.” But, you better believe it, not only could it - never happen – its happening, more likely than not – right now …… if only you knew where to look.
What does this all mean for employers? Employers have a number of critical obligations, for example:
• to provide appropriate information, training and supervision in relation to working with hazardous substances to relevant employees and their supervisors;
• to obtain up-to-date MSDSs and ensure a register of hazardous substances is maintained, and is up-to-date.
• to ensure all hazardous substances are labelled. This is especially important where a large amount of decanting takes place.
• to ensure workers who may be exposed to toxic chemicals are able to access the relevant MSDS and are able to read and apply the appropriate first aid or emergency procedure effectively.
NOTE: This list is illustrative not exhaustive
The problem that exists is that the CEO talks to production, the message – cut costs. The production manager talks to the chemical supplier. The latter come up with a substitute cheaper new chemical or synthetic to use in the process.
Production talks to buying and the chemical duly arrives on the truck some time later. But, this is in fact the seriously wrong way to manage the hazard that will present once the chemical arrives on site. A better hazard management regime would be as follows:
1. Once the new chemical is identified as a possible cheaper replacement, the buyer requests a copy of the MSDS. Well before the new chemical is due to arrive on site. (Note in 2003 NOHSC delivered an Updated National Code of Practice for the preparation of Material Data Sheets 2nd Edition. This will be adopted in 2006.)
2. The MSDS is examined by a competent manager of the company. That person, in effect conducts a risk assessment of the new alternate. And presents to senior management a written report for consideration. Finally, satisfied the company is not saving upfront to suffer considerable expense further down the line because of an important toxic component that has potential to harm employees or the environment, the order to buy is placed.
3. Management hands the MSDS to the OH&S co-ordinator who organises for:
• information dissemination to commence pre-delivery via either the safety committee or safety reps;
• appropriate training to occur for everyone who may come in to contact with the substance before the chemical arrives on site;
• the company first aid and emergency preparedness employees are given the necessary information about the chemical so that they can in turn make all the necessary preparations for the arrival of the new chemical; and
• consultation to take place with relevant employees to enable them to input concerns or suggestions for the safe handling of the new chemical.
In this way, the forklift driver when he off loads the pallet from the delivery vehicle knows what he is dealing with, stores same where he has been told it can be stored safely, and knows what to do , if a packet starts to leak.
Sure, as is so often remarked about this preferred method of dealing with hazardous chemicals – it is just plain common sense.
No it is not that simple but it is very important that businesses start to get really serious about the huge number of new chemicals coming daily on to the market often with a sinister hazardous to health or the environment component.
Read the MSDS’s fine print; refer to the Environmentally Hazardous Chemicals Act and the Regulations there-under, and remember your duty under Section 8 of the OH&S Act, it will keep you out of what could be very serious trouble.
Ray Schaffer is principal consultant with RMHSchaffer and Co , health, safety and environment consultants, 02 9878 0613. Visit www.environmentdiy.com.au, pose a question and receive an answer at no cost.