GUIDELINES FOR WORKING WITH HAZARDOUS SUBSTANCES
- Introduction
- The Risk Management Process
- Identify the Risk
- Assess the Risk
- Control the Risk
- Evaluate the Effectiveness of Controls
- Inventory
- Labelling
- Material Safety Data Sheets (MSDS)
- Monitoring
- Consultation
- Training
- Supervision
- Register of Hazardous Substances
- References
- Schedule
The purpose of these Guidelines is to inform University personnel about the appropriate steps that should be taken to manage the risks from working with hazardous substances. These steps will help ensure that relevant personnel are well informed and consulted about hazardous substance issues and exposure to hazardous substances will be minimised to prevent disease and injury to the workers involved, the community and/or the environment. They will also assist the University to comply with the NSW Occupational Health & Safety Regulation 2001 and the WorkCover Code of Practice for the Control of Workplace Hazardous Substances.
Hazardous substances are used in most workplaces. In addition to laboratories where there may be many hazardous substances, offices may have hazardous substances such as toner in copying machines, cleaning products may be hazardous substances, and dusts and fumes generated by processes such as grinding or welding may also be hazardous substances.
The general definition of a hazardous substance is any substance that has the potential to harm the health of persons in the workplace. This includes poisons and many dangerous goods. It also includes mixtures of hazardous substances. These Guidelines do not apply specifically to infectious substances or radioactive materials, however the risk management process described here can be universally applied for these or any other workplace hazards.
The Workcover Code of Practice for the Control of Workplace Hazardous Substances is the primary reference from which these Guidelines have been derived. It is referred to throughout these Guidelines where greater detail should be obtained.
Work with hazardous substances must be well managed to prevent any exposure, accidents, or ill-effects to the workers involved, the community and/or the environment. To manage these risks, we follow the basic risk management steps:
- identify,
- assess, and
- control the risks, then
- evaluate the effectiveness of the controls.
The risk management process relies upon effective consultation, training and supervision.
Identify whether you or a co-worker are using any hazardous substances. If you're not sure, ask your supervisor and co-workers, and check the labels of the substances in your work area. The Material Safety Data Sheet (MSDS) for a substance will also indicate whether it is hazardous. Also consider those substances which are in enclosed systems, such as pipes and vessels (refer to the NSW WorkCover Code of Practice for the control of workplace hazardous substances).
For additional information about reading Labels, refer to the WorkCover publication Reading labels and material safety data sheets.
If necessary, you can determine whether a substance is considered hazardous by checking whether it is included in the National Hazardous Substances Information System (HSIS) or applying the Approved Criteria for Classifying Hazardous Substances [NOHSC:1008(2004)]. Manufactures and importers of hazardous substances are required to classify all new or imported products.
A Register of hazardous substances identified, used, or produced at the workplace, must be kept in an accessible form.
Any work with hazardous substances must be adequately assessed to determine the level of risk to the health of individuals involved. This will allow reasonable decisions to be made about appropriate risk control measures.
The risk assessment is only required if there is potential for exposure to hazardous substances i.e., vapours or dusts could be inhaled, there could be direct skin contact, or they could be ingested or injected. The assessment is made of the task or process involving the hazardous substance(s) rather than examining each substance individually.
Examples of processes include:
- weighing out powdered hazardous substances
- decanting cleaning fluids
- liquid chromatography
- distillation of solvents
- decontaminating surfaces
- diluting pesticides
- degreasing a motor
- sanding timber etc.
The health risks associated with the hazardous substance(s) used in these processes must be determined by reading the label and reviewing the supplier MSDS, or, if this MSDS cannot be obtained, other equivalent information. The assessment should identify the workers at risk, the likely exposure routes and toxicological effects of the hazardous substance(s) and suitable control measures.
The assessment should be arranged by the relevant supervisor or line manager. The assessment should be conducted by a competent person i.e., someone with sufficient knowledge and skills to evaluate the health risks to individuals involved in the process using the hazardous substances. A record of this assessment should be noted on the Register of Hazardous Substances.
In conducting an assessment, consider not only the individuals involved, but also others nearby who may be affected, or maintenance and cleaning personnel etc. Confined spaces such as pits and tanks often develop concentrated atmospheres of hazardous substances like hydrogen sulphide. Special precautions apply to these areas - refer to the University of Sydney Policy on Working in Confined Spaces.
Simple Assessments
A simple risk assessment involves an inspection of the work area and consultation with the individuals performing the task to determine whether the hazardous substance is, or can be, readily controlled in accordance with the MSDS. If this is the case, the assessment is complete and should be simply noted on the Register of Hazardous Substances.
Detailed Assessments
A more detailed assessment is required where there is uncertainty about the level of risk from working with hazardous substances, or where the risk is significant i.e., the health hazard is serious. Steps 6 and 7 of the "Guidance Note for the Assessment of Health Risks Arising from the Use of Hazardous Substances in the Workplace" [NOHSC:3017(1994)] provide further information on the assessment of risks.
A detailed assessment must be recorded. It is recommended that these risk assessments be kept in the Register of Hazardous Substances.
In some cases, specialist assistance may be needed to complete the assessment e.g., for ventilation engineering advice, monitoring the air in the workplace, or an individual's exposure etc. In these cases, refer to Appendix 1 of the Guidance Note for the Assessment of Health Risks Arising from the Use of Hazardous Substances in the Workplace [NOHSC:3017(1994)] and/or OHS & Injury Management.
Generic Risk Assessments
A generic assessment is satisfactory for like substances and processes i.e., an assessment of one hazardous substance and process may also be applied to a like substance and process.
Prioritising Risk Assessments
In workplaces where there are many hazardous substances, it may be necessary to prioritise the order of risk assessments. In determining this priority, consider the frequency of use and the potential severity of exposure to the hazardous substances e.g., toxicological effects. Those hazardous substances which are used most frequently and whose effects are more severe should receive a high priority for early assessment.
Reassessment
Reassessment is required at least every 5 years if the work is still performed, or earlier where:
- there is a significant change in the work process;
- a work related illness is reported;
- accidents or near misses have occurred;
- monitoring indicates significant exposure, or;
- new information about the hazardous substance(s) or process becomes available.
Any exposure to hazardous substances must be kept as low as practicable, so a range of measures to control the risk may need to be considered for implementation.
Hazardous substances must be controlled according to the level of risk - as determined by the risk assessment. The normal hierarchy of hazard control applies i.e.,
- eliminate the substance or task if it is not essential
- substitute the hazardous substance with something less hazardous
- isolate the process by using barriers or distance
- use engineering controls, such as local exhaust ventilation or automation of the process
- minimise the volumes of hazardous substances used
- establish safe work practices, such as restricting access to the area, keeping the area free of clutter, replacing lids on containers, safe storage and disposal, being prepared for emergencies e.g., spills
- provide training and supervision appropriate to the level of expertise of the personnel involved.
- As a minimum, this would include familiarisation with local hazards and their control, safe work and emergency procedures.
- personal protective equipment (PPE) such as gloves, laboratory coats, safety glasses, dust masks etc., should be used generally as a secondary measure to supplement the other controls mentioned.
For further details about these risk control measures, refer to the WorkCover Code of Practice for the control of workplace hazardous substances.
Records are to be kept of hazardous substances induction and training, including the names of employees, training dates, course outline and trainers name. This training must explain how to avoid excessive exposure to hazardous substances, how to read labels and MSDS, and the usual line of communication and referral for further advice i.e., supervisor etc. For further details, refer to the WorkCover Code of Practice for the control of workplace hazardous substances.
To ensure that the risk control measure(s) implemented are acceptable i.e., practical and effective, it is necessary to consult with the people concerned with the hazardous substance i.e., users and supervisors. Also refer to training and supervision.
After control measures have been put in place to alleviate the risk associated with hazardous substances, they must be periodically reviewed to check their effectiveness. This may include a planned maintenance and testing program for engineering controls, or routine workplace inspection by the supervisor, occupational health and safety committee etc. As a minimum, the requirement for periodic "Reassessment" should be met.
An inventory must be kept of all hazardous substances used or produced at the workplace, including dusts and fumes. This inventory may be kept electronically or in printed form, but shall be accessible to employees who are, or may be, exposed to the hazardous substances, and kept up to date. It is recommended that printed inventories be kept in the Register of hazardous substances.
A template Hazardous Substances Inventory has been provided for Departments to use when compiling their inventories of hazardous substances.
Containers of hazardous substances used or handled in the workplace must be appropriately labelled so that their contents can be identified and to draw attention to the hazards involved. The minimum standards for labelling are given in the WorkCover Code of Practice for the Labelling of Workplace Substances.
Decanted hazardous substances must also be appropriately labelled, although the requirements for labelling are limited depending on how quickly the substance is to be used and the size of the container (refer to the WorkCover Code of Practice for the control of workplace hazardous substances). Suppliers are responsible for the labelling of hazardous substances that they supply to others.
The MSDS gives details about (a) the properties of the substance, its toxicity and reactivity, and (b) precautions for safe use - segregation from incompatible materials, procedures for handling, transporting, spill control and first aid, suitable storage and disposal arrangements, and any facilities or personal protective equipment (PPE) to be used.
Manufacturers or importers must supply material safety data sheets (MSDS) for the hazardous substances they supply. The supplier MSDS must be readily available to employees and students exposed to hazardous substances. It may be convenient to keep printed MSDS together in the Register of hazardous substances, although storage of supplier MSDS electronically is satisfactory, as long as they are readily accessible.
It is not necessary to supply a MSDS if the hazardous substance is produced and used within the workplace or if the substance is a reaction intermediate or sample derived from a laboratory reagent for which there is an MSDS. However, information must be provided about the health effects, precautions for use and safe handling.
The Chem Alert II Database is a useful supplement to supplier MSDS for gathering information about hazardous substances which have been held for some time, printing labels for decanted chemical or for researching new chemicals before acquiring them.
For additional information about reading MSDS, refer to the WorkCover publication Reading labels and material safety data sheets and the WorkCover Code of Practice for the control of workplace hazardous substances.
Monitoring of the work environment may be required either during the assessment of risk from working with hazardous substances, or to check the effectiveness of risk control measures implemented, particularly where serious health effects may result from failure of the controls (because of high toxicity of the substance). Exposure to any hazardous substance must not exceed the National Exposure Standard for that substance. National Exposure Standards can be found in the National Hazardous Substances Information System (HSIS).
Health surveillance via biological monitoring is required for workers at high risk of health effects from exposure to hazardous substances and where there are valid techniques available to detect early signs of the disease or condition. It is also required for any work with a small number of hazardous substances (as listed in Appendix 1).
Where monitoring is necessary, arrangements may be made through the Risk Management Office for an appropriate consultant.
The results of monitoring must be made available to all personnel concerned as part of the risk assessment, although medical confidentiality is to be retained for health surveillance.
Effective and open consultation between the people involved in using hazardous substances and their supervisors is required to ensure that the risks and their controls are clearly understood. During the assessment of a work process involving hazardous substances, the workers involved with the process need to be consulted to give a "hands on" perspective on the likelihood of exposure (from their experience). They will also need to be consulted when deciding on suitable risk control measures to ensure that the controls are not only effective, but are practical and acceptable to those who will utilise them.
Each person working with hazardous substances should be trained to recognise hazardous substances and know where to find and how to interpret information about these substances. They should be familiarised with the risk control measures available and how these are to be used and maintained. The normal channels for communication and referral for further advice eg., check with supervisor, should also be covered.
A record of the hazardous substances training conducted is to be kept. This record should include the details of those who attended, the training date(s), the name of course presenter(s) and an outline of the course content. It is recommended that records of hazardous substances training be kept in the Register of hazardous substances.
Each supervisor has a responsibility for managing the risks from hazardous substances in each area under their control and with consideration for all staff and students working under their direction. This includes putting in place effective mechanisms for consultation with and training of the personnel involved.
The level of supervision given during a work process involving hazardous substances will vary according to the experience and skill level of the person/people involved. Those people with little or no experience/skills in using hazardous substances in a work process should be given close, direct supervision ie., the supervisor should demonstrate, then oversee the conduct of the process until they are satisfied with the level of proficiency. Conversely, for those people with great experience and understanding of the work processes and hazardous substances risk management, supervision may be more distant and general.
A register which traces each aspect of the hazardous substances risk management process is required. A folder which acts as the Register of Hazardous Substances may be kept locally for the storage of (or as a reference to the locations of):
- the inventory of hazardous substances and dangerous goods;
- the MSDS for hazardous substances and dangerous goods stored/used;
- risk assessments and associated work procedures for the tasks involving those substances; and
- relevant training records for personnel involved.
Current References
- NSW Occupational Health and Safety Regulation 2001
- NSW WorkCover 2006. Code of Practice for the control of workplace hazardous substances.
- NSW WorkCover 1996. Code of Practice for the labelling of workplace substances.
- NSW WorkCover 2006. Guide for Reading labels and material safety data sheets.
- National Occupational Health and Safety Commission. National Model Regulations for the Control of Workplace Hazardous Substances [NOHSC:1005(1994)]. Australian Government Publishing Service, Canberra.
- National Occupational Health and Safety Commission. National Code of Practice for the Control of Workplace Hazardous Substances [NOHSC:2007(1994)]. Australian Government Publishing Service, Canberra.
- National Occupational Health and Safety Commission. National Code of Practice for the Labelling of Workplace Substances [NOHSC:2012(1994)]. Australian Government Publishing Service, Canberra.
- National Occupational Health and Safety Commission. Guidance Note for the Assessment of Health Risks Arising from the Use of Hazardous Substances in the Workplace [NOHSC:3017(1994). Australian Government Publishing Service, Canberra.
- National Occupational Health and Safety Commission. Approved Criteria for Classifying Hazardous Substances [NOHSC:1008(2004)]. Australian Government Publishing Service, Canberra.
- National Occupational Health and Safety Commission Hazardous Substances Information System.
- The University of Sydney. Policy on Working in Confined Spaces. 1994. OHS & Injury Management
Historical References
- NSW Occupational Health and Safety (Hazardous Substances) Regulation 1996.
- NSW WorkCover Authority. 1996 & 2000. Reading labels and material safety data sheets.
- National Occupational Health and Safety Commission (Worksafe). List of Designated Hazardous Substances [NOHSC:10005(1994)]. Australian Government Publishing Service, Canberra.
- National Occupational Health and Safety Commission (Worksafe). Approved Criteria for Classifying Hazardous Substances [NOHSC:1008(1994)]. Australian Government Publishing Service, Canberra.
- National Occupational Health and Safety Commission (Worksafe). Exposure Standards for Atmospheric Contaminants in the Occupational Environment [NOHSC:1003(1995)] Australian Government Publishing Service, Canberra.
Appendix 1
NSW Occupational Health and Safety Regulation 2001
Clause 165 Employer to provide Health Surveillance
HAZARDOUS SUBSTANCES FOR WHICH HEALTH SURVEILLANCE IS REQUIRED
|
|
|
|---|---|
| Acrylonitrile |
Occupational and medical history Demographic data Records of personal exposure |
| Arsenic (Inorganic) |
Demographic, medical and occupational history Exposure record Physical examination with emphasis on the peripheral nervous system and skin Urinary total arsenic |
| Asbestos |
Occupational and demographic data Medical interview Records of personal exposure |
| Benzene |
Occupational and medical history Demographic data Exposure record Baseline blood sample for haematological profile |
| Cadmium |
Demographic, medical and occupational history Exposure record Physical examination with emphasis on the respiratory system Standard respiratory questionnaire to be completed Standard respiratory function tests including for example, FEV1, FVC and FEV1/FVC Urinary cadmium and 2-microglobulin |
| Chromium (inorganic) |
Demographic, occupational and medical history Physical examination with emphasis on the respiratory system and skin Weekly skin inspection of hands and forearms by competent person |
| Creosote |
Demographic, occupational and medical history Health advice, including recognition of photosensitivity and skin changes Physical examination with emphasis on the neurological system and skin, noting any abnormal lesions and evidence of skin sensitisation Exposure record, including photosensitivity |
| Crystalline Silica |
Completion of a standardised respiratory questionnaire Standardised respiratory function test, such as FEV1, FVC and FEV1/FVC Chest X-ray, full size PA view |
| Isocyanates |
Occupational and medical history Completion of a standardised respiratory questionnaire Physical examination of the respiratory system and skin Standardised respiratory function test, such as FEV1, FVC and FEV1/FVC |
| Lead (inorganic) |
Medical and occupational history Physical exemination |
| Mercury (inorganic) |
Demographic, medical and occupational history Physical examination with emphasis on dermatological, gastrointestinal, neurological and renal systems Urinary inorganic mercury |
| MOCA (4,4-Methylenebis 2-chloroaniline) |
Urinary total MOCA Dipstick analysis of urine for haematuria Urine cytology |
| Organophosphate pesticides |
Occupational and medical history Physical examination Baseline estimation of red cell and plasma cholinesterase activity levels by the Ellman or equivalent method Estimation of red cell and plasma cholinesterase activity towards the end of the working day |
| Pentachlorophenol (PCP) |
Demographic, occupational and medical history Physical examination with emphasis on the skin, noting any abnormal lesions or effects or irritancy Urinary total pentachlorophenol Dipstick urinalysis of haematuria and proteinuria Records of personal exposure |
| Polycyclic aromatic hydrocarbons |
Exposure record, including photochemical skin burns Demographic, medical and occupational history Physical examination |
| Thallium |
Demographic, medical and occupational history Physical examination Urinary thallium |
| Vinyl Chloride |
Occupational and demographic data Record of personal exposure |
Notes
For further information please contact OHS & Injury Management Tel: 9351 4335, e-mail:
Notes
Last updated: 06 Aug 2007
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