POLICY FOR ACQUISITION, USE AND DISPOSAL OF CARCINOGENIC SUBSTANCES

The University of Sydney is committed to safe use of carcinogenic substances. Acquisition and use of known and suspected carcinogens will be minimised. Acquiring, storing, using and disposing of these substances will be carried out in accordance with relevant legislation, guidelines, Australian Standards and established good practice. Heads of Departments and those in charge of research projects in which carcinogenic substances are used are responsible for ensuring compliance with statutory requirements, guidelines, standards and good practice.

GUIDELINES FOR USING CARCINOGENIC SUBSTANCES

1. Introduction
2. Requirements for Working with Carcinogenic Substances in NSW
   2.1 General Precautions for Safely Working with Known & Suspected Carcinogens & Highly Toxic Chemicals
   2.2 General Requirements for WorkCover Listed Carcinogenic Substances
   2.3 Supply of WorkCover Listed Carcinogenic Substances
   2.4 Keeping WorkCover Listed Carcinogenic Substances
   2.5 Notification, Risk Assessment and Control of WorkCover Listed Carcinogenic Substances
   2.6 Exposure Records for WorkCover Listed Carcinogenic Substances
3. References

Appendix - WorkCover Listed Carcinogenic Substances
* Notifiable Carcinogenic Substances
* Prohibited Carcinogenic Substances

The nature of University work means that some staff and students handle known and suspected carcinogenic substances and highly toxic chemicals. There are many types of laboratories where such substances may be found, including all types of chemical laboratories, histology laboratories, biochemistry laboratories, pharmaceutical laboratories, pharmacological laboratories, cancer medicine laboratories, microbiological laboratories, medical science laboratories, veterinary science laboratories, physics laboratories, etc.

Known and suspected carcinogenic substances can be kept and used safely if appropriate precautions are taken. Some carcinogenic substances are regulated by the WorkCover Authority of NSW, and in this case WorkCover must be notified prior to obtaining or using the substance.

This document provides basic guidance on safe practices and legal requirements for the use of carcinogenic substances and highly toxic chemicals. The acquisition, use and disposal of these substances at the University of Sydney must comply with relevant legislative requirements, applicable guidelines and established standards.

For the purposes of this document there are two categories of carcinogenic substances.

• Known or suspected carcinogenic substances, including those listed by the International Agency for Research on Cancer, are covered by the general precautions and regulatory requirements for hazardous substances.
• There are additional requirements for substances listed in the NSW Occupational Health and Safety Regulation 2001 as notifiable or prohibited carcinogenic substances. This latter category is referred to as WorkCover listed carcinogenic substances.

The Occupational Health and Safety Regulation 2001 includes a number of clauses specifically relating to carcinogenic substances, as well as a whole chapter on hazardous substances in general. In addition, WorkCover has issued Guidelines for Notification of Work Involving Use of Carcinogenic Substances.


2.1 GENERAL PRECAUTIONS FOR SAFELY WORKING WITH KNOWN & SUSPECTED CARCINOGENS & HIGHLY TOXIC CHEMICALS

In accordance with Chapter 6 Hazardous Substances of the NSW Occupational Health and Safety Regulation 2001 the following general precautions apply when working with substances known or suspected to be carcinogenic and/or highly toxic.

• Undertake and document a risk assessment in consultation with those who will handle the substance.
• Implement the controls resulting from the risk assessment.
• Follow standard safe laboratory practices and techniques.
• Ensure laboratory facilities are adequate and appropriate, particularly in relation to containment, ventilation, segregation from other activities and security.
• Ensure those working with the substances receive adequate information, instruction, training and supervision appropriate to their level of experience and competence with required laboratory techniques.
• Ensure those working with the substances receive appropriate training and supervision in relation to the hazards and safe techniques, standard operating procedures, use of personal protective equipment, etc, needed to minimise risks to health.
• Be prepared for emergencies, including spills and accidental exposures, as well as routine decontamination.
• Document and implement local rules, standard operating procedures, access controls etc.
• Plan for safe hazardous waste disposal before commencing the project.
• Store the substance safely and securely and follow all labelling requirements.
• In assessing risks and determining safe operating procedures and other controls, refer to suitable reference sources additional to those listed in Section 3 following, eg:
  *substance Material Safety Data Sheet
  *equipment operating manuals
  *specific references for experiment protocols, techniques, etc
  *University of Queensland Guidelines for Working Safely with Carcinogens – sections 4, 6, 10-13, Appendices I & II.

Note that undergraduate students, including honours students, may lack experience in laboratory techniques and procedures. A mistake when handling a carcinogenic substance could result in an exposure with serious long-term health consequences. The risk assessments for any projects proposing that undergraduate students work with carcinogenic substances must consider and document the particular training and supervision measures that will be implemented to take account of this inexperience. This should include details of who will provide in-lab oversight to ensure the student is or becomes competent in the required laboratory techniques and safe operating procedures.

2.2 GENERAL REQUIREMENTS FOR WORKCOVER LISTED CARCINOGENIC SUBSTANCES

WorkCover listed (notifiable and prohibited) carcinogenic substances may not be kept or used without first notifying WorkCover using the approved form at least 60 days prior to the intended use or acquisition. The list of notifiable and prohibited carcinogenic substances can be found in Clause 158 of the Regulation. The list is also published in the WorkCover Guidelines for Notification of Work Involving Use of Carcinogenic Substances. See the Appendix for a copy of the list.

Note that prohibited carcinogenic substances can be used for research and analysis purposes, provided WorkCover is notified and all other statutory and University requirements are met.

2.3 SUPPLY OF WORKCOVER LISTED CARCINOGENIC SUBSTANCES

WorkCover listed carcinogenic substances may only be supplied to people who can provide evidence that WorkCover has been notified of the intended use (Clause 159). The supplier is required to keep supply records under Clause 160 of the Regulation.

2.4 KEEPING WORKCOVER LISTED CARCINOGENIC SUBSTANCES

WorkCover requires renewal of notification every 5 years using the approved form if there is continuing use of the carcinogenic substance. This also applies to ongoing use of WorkCover listed carcinogens for which a WorkCover permit was issued under previous legislation.

2.5 NOTIFICATION, RISK ASSESSMENT AND CONTROL OF WORKCOVER LISTED CARCINOGENIC SUBSTANCES

WorkCover listed carcinogenic substances are subject to the same general requirements for risk assessment and control as all other hazardous substances, as well as some additional requirements. Clause 10 of the OHS Regulation 2001 requires the employer to assess risks to the health of employees and others arising from identified hazards. Clause 12 requires the employer to review risk assessments and control measures. Clause 168 requires the employer to record the results of risk assessments relating to the use of a hazardous substance. Clause 171 requires that certain records be kept for periods of 5 or 30 years.

The Research risk assessment form for Carcinogenic or Highly Toxic Chemicals must be used as a summary risk assessment record for each project involving the use of a notifiable or prohibited carcinogen, whether the project falls under Research Office protocols or not. A copy of this summary Risk Assessment and the completed WorkCover notification form must be lodged with OHS & Injury Management at the same time that WorkCover is notified. Under Clause 171, these records must be kept for at least 30 years after the date of notification.

As specific measures will be necessary to control the risks associated with exposure to a WorkCover listed carcinogen, a detailed risk assessment must be conducted in consultation with those staff, students and others who could be exposed to the substance. The control measures to be adopted as a result of the risk assessment must be adhered to as a condition of using the listed carcinogen. The risk assessment, including details of control measures, must be fully documented, including relevant training and in-lab oversight arrangements to take account of the relative inexperience of any undergraduate students involved in the project (see note under 2.1 above). The risk assessment report, material safety data sheets, standard operating procedures, safe work methods and other relevant documentation must be kept in a location that is readily accessible by those potentially exposed to the carcinogenic substance.

2.6 EXPOSURE RECORDS FOR WORKCOVER LISTED CARCINOGENIC SUBSTANCES

Under Clause 169 of the OHS Regulation, employers must keep records of each employee who has been or is likely to have been exposed to a WorkCover listed carcinogen. In order to comply with these requirements, as well as privacy and confidentiality requirements, any actual or suspected exposure to a listed carcinogen must be immediately notified to OHS & Injury Management using the standard incident reporting procedures. OHS & Injury Management will notify WorkCover as required by Clause 341(f). The exposure must be investigated locally to determine whether the risk controls need to be changed. OHS & Injury Management will review the incident report and may refer an exposed person to an occupational physician for a medical assessment.

The records required to be kept include the full name and date of birth of the employee and their address whilst employed. Under Clause 170, when an employee who was or is likely to have been exposed to a listed carcinogen leaves the employment, the employer must provide a written statement to the employee. This statement must include details of

• the name of the carcinogen(s) involved
• the period of exposure or potential exposure
• how and where records of the exposure or potential exposure can be obtained
• any advisable periodic health assessments and the type of health tests that are relevant.

These records should also be kept for any research students or honorary researchers exposed or likely to have been exposed to a listed carcinogen. Details of the exposure from incident reports and related documents will be placed on the staff member’s personal file (or the student’s file), which will be specially marked for retention as these records must be kept for at least 30 years from the last entry date.

If injury or illness results from exposure to the carcinogen, the risk assessment must be reviewed and WorkCover must be notified in writing of the review and the changes resulting from it (Clause 346(a)).

• Occupational Health and Safety Regulation, 2001.
• Work Involving Use of Carcinogenic Substances - Guidelines for Notification, WorkCover NSW, August 2002
• Work Involving Use of Carcinogenic Substances – Notification Form, WorkCover NSW, August 2002
• Hazardous Substances Information System, National Occupational Health and Safety Commission, incorporating and referencing
  * Adopted National Exposure Standards for Atmospheric Contaminants in the Occupational Environment [NOHSC:1003(1995)]
  * List of Designated Hazardous Substances [NOHSC:10005(1994)] and [NOHSC:10005(1999)]
  * Approved Criteria for Classifying Hazardous Substances [NOHSC:1008(2004)]
  * National Code of Practice for the Control of Workplace Hazardous Substances [NOHSC:2007(1994)]
  * National Model Regulations for the Control of Workplace Hazardous Substances [NOHSC:1005(1994)]
  * National Model Regulations for the Control of Scheduled Carcinogenic Substances [NOHSC:1011(1995)]
  * National Code of Practice for the Labelling of Workplace Substances [NOHSC:2012(1994)]
  * Guidance Note for the Assessment of Health Risks Arising from the Use of Hazardous Substances in the Workplace [NOHSC:3017(1994)].
• Laboratory Safety Manual, CCH Australia – particularly section 38.
• Australian Standard 2243 Safety in laboratories
  * Part 1: General, 1997
  * Part 2: Chemical aspects, 1997
  * Part 8: Fume cupboards, 2001
  * Part 10: Storage of chemicals, 2004.
• Australian Standard 2567 Laminar flow cytotoxic drug safety cabinets, 1994.
• University of Queensland Guidelines for Working Safely with Carcinogens – sections 4, 6, 10-13, Appendices I & II.
• University of Sydney Guidelines on Laboratory Safety, Risk Management Office, 1994.
• University of Sydney Guidelines for Working with Hazardous Substances, Risk Management Office, 1998.
• University of Sydney Hazardous Substances Implementation Course, Risk Management Office, 1998.
• University of Sydney Guidelines for Hazardous Waste Disposal, OHS & Injury Management, 2006.
• University of Sydney ohsrm Program, Risk Management Office, 2002.
• University of Sydney Research risk assessment form for Carcinogenic or Highly Toxic Chemicals.
• IARC Monographs Programme on the Evaluation of Carcinogenic Risks to Humans, International Agency for Research on Cancer.
• Handling Chemical Carcinogens in the Laboratory - Problems of Safety, International Agency for Research on Cancer, Lyon, 1979.
• Laboratory Decontamination and Destruction of Carcinogens in Laboratory Wastes: Some N-Nitrosoamines, International Agency for Research on Cancer, Lyon, 1982.
• Handbook of Toxic and Hazardous Chemicals and Carcinogens, Sittig, M. Noyes Publications, New Jersey, second edition 1985.

Clause 158 of the NSW OHS Regulation 2001

NOTIFIABLE CARCINOGENIC SUBSTANCES

• Acrylonitrile [107-13-1]
• Benzene [71-43-2] - when used as a feedstock containing more than 50% of benzene by volume
• Cyclophosphamide [50-18-0] (cytotoxic drug) - when used in preparations for therapeutic use in hospitals and oncological treatment facilities, and in manufacturing operations
• 3,3'-Dichlorobenzidine [91-94-1] and its salts (including 3,3'-Dichlorobenzidine dihydrochloride [612-83-9])
• Diethyl sulfate [64-67-5]
• Dimethyl sulfate [77-78-1]
• Ethylene dibromide [106-93-4] - when used as a fumigant
• 4,4'-Methylene bis(2-chloroaniline) [101-14-4] - MOCA
• 2-Propiolactone [57-57-8]
• o-Toluidine [95-53-4] and o-Toluidine hydrochloride [636-21-5]
• Vinyl chloride monomer [75-01-4]

PROHIBITED CARCINOGENIC SUBSTANCES

• 2-Acetylaminofluorene [53-96-3]
• Aflatoxins - except in foods where specifically permitted under the Food Act 1989
• 4-Aminodiphenyl [92-67-1]
• Amosite [12172-73-5] (brown asbestos) - except for removal, disposal, maintenance, encapsulation and enclosure purposes and situations where amosite occurs naturally and is not used for any new application
• Benzidine [92-87-5] and its salts (including benzidine dihydrochloride [531-85-1])
• bis(Chloromethyl) ether [542-88-1]
• Chloromethyl methyl ether [107-30-2] (technical grade which contains bis(chloromethyl) ether)
• Chrysotile [12001-29-5] (white asbestos) - except when:
  (a) used for the purpose of research or analysis, or
  (b) being removed or disposed of, or being handled for storage or stored awaiting disposal, or
  (c) encountered during non-asbestos mining, or
  (d) comprising or included in an item being used for the purpose of a historical or educational display.
• Crocidolite [12001-28-4] (blue asbestos) - except for removal, disposal, maintenance, encapsulation and enclosure purposes and situations where crocidolite occurs naturally and is not used for any new application
• 4-Dimethylaminoazobenzene [60-11-7]
• 2-Naphthylamine [91-59-8] and its salts
• 4-Nitrodiphenyl [92-93-3]

Notes
This Policy and these Guidelines endorsed by the University of Sydney Central OHS Committee 04/09/06
Last updated: 15/09/06
Page maintained by: Leanne Mumford