Chemicals management in workplaces

The late Dr. Chris Winder, then Associate Professor at the School of Safety Science, University of New South Wales, discussed chemicals management in workplaces: the role of OHS reps and others in the prevention and control of exposure to hazardous substances.

Introduction

There were some interesting findings from the 167 questionnaires returned to the ACTU as part of their 2000 National Survey of Health and Safety Representatives (HSRs):

• 88% say they use chemicals at work;
• 33% say that people at their workplaces have suffered health effects from chemicals at work;
• 75% have not had training about the safe use of chemicals at work;
• 66% say they are aware of legislation and associated responsibilities;
• 23% say that chemicals in their workplaces are not clearly labeled;
• 15% say that the label is not easy to understand;
• Most respondents do not know the difference between "poisons," "hazardous substances" and "dangerous goods";
• Over 50% believe that they have not been given adequate information about the chemicals in their workplace;
• 70% indicated that they would like more information;
• 81% said that not enough is being done by employers, employees and/or governments to ensure chemical safety at work;
• These problems were much worse in smaller businesses.

The assertion that there is adequate control of chemicals in the workplace is not borne out by the experience.

These days we talk about risk management as the accepted approach for controlling workplace health and safety hazards. Risk management can be all things to all people, but for health and safety, it is (at least) three things: identify, assess, control (IAC). IAC can be used to reduce the chemical risks in the workplace.

Chemical Hazard Identification

Remember: You cannot control hazardous substances properly unless you have concise, relevant, accurate and proper information.

So: Who's responsible?

The Supplier: Even before a chemical arrives in a workplace, it is supposed to have undergone a hazard assessment by the person or company, that puts the chemical into its container, such as a manufacturer or importer (usually called the supplier). That hazard assessment includes classification of hazard (for example, danger properties, risk of death, long term health problems, environmental effects) to international standards.

These may vary according to use or potential exposure. For example, the difference between 1000 mls of Xylene (a hazardous substance) will have a risk of harmful vapours in use, whereas 10,000 L of Xylene (a dangerous good) has a risk of flammability in storage.

If this classification process finds that the chemical is hazardous and/or dangerous, the suppliers must then accurately label the container warning users of the hazards. Suppliers must also prepare a material safety data sheet (MSDS), and make the MSDS available before or when they supply the chemical to their customers. If a chemical is going into a workplace, the customer is the employer.

The Employer: Employers must aim to eliminate exposure to hazardous substances at work. Once any chemicals and their MSDS arrive in the workplace, they should be evaluated again for health and safety problems before use. The label and MSDS should be checked for likely hazards, and to ensure existing controls are adequate and suitable. MSDS must be placed in a hazardous substances register that is accessible to all workers with the potential for exposure.

The Role of the HSR in this Process: Read the label and MSDS for all chemicals to work out what needs to be done in your workplace. Question inadequate warnings on labels or MSDS that do not show health problems, especially if you are observing them in your workforce. Make sure all "downstream" containers are labeled properly. Check with your union if you are not satisfied with the information supplied by the employer.

Chemical Risk Assessment

Remember: You cannot eliminate or reduce chemical risks properly unless you have assessed the hazards and worked out how to control any risks arising from use of the chemicals. Every chemical that is a hazardous substance must undergo a risk assessment, to be carried out by the employer in conjunction with workers.

So: Who's responsible?

The Employer: There are different types of risk assessments, such as "tick and flick" assessments for chemicals not considered a risk (who decides? - the employer, if workers don't get involved). More importantly, more formal assessments are required for chemicals that are known to be a risk and not under suitable control in the workplace. These risk assessments must be conducted by a competent person (this can include HSRs). These risk assessments must be recorded and authorised by a responsible person.

These risk assessments must be accessible to workers. All workers must comply with any recommended controls stipulated in such risk assessments.

The Role of the HSR in this Process: Take part in risk assessments being conducted in your workplace. Insist on seeing the risk assessments that have been completed for hazardous substances in your workplace (don't be surprised if none have been completed - employers are erring on the side of convenience). Demand that risk assessments be carried out or revised whenever co-workers are showing signs and symptoms of chemical exposure. The 2000 ACTU survey noted that a third of HSRs reported that people at their workplaces have suffered health effects from chemicals at work. Ensure that co-workers comply with the recommendations made in risk assessments that have been finalised.

Chemical Risk Control

Remember: Hazardous substances are not defined as hazardous because they are safe. They will cause harm to the people who are exposed unless controlled properly. If anybody is showing symptoms, then by definition exposure is already too high - even if only a few people are showing symptoms, something has to be done to either eliminate or better control the offending chemical(s).

Where any unacceptable risk from exposure to hazardous substances cannot be eliminated, it must be controlled.

There are a range of controls that are available for controlling chemical risks. Some are better than others.

General principles of risk control are outlined in the hierarchy of controls:

• Substitution: This is the preferred way of dealing with toxic chemicals. For example, replacement of materials with less hazardous materials and/or processes, and/or re-organisation of tasks or processes to make them less risky;
• Isolation: This is where hazards or risks are located away from everyday activities. Isolation may be by location (carrying out the activity at an isolated area) and/or by time (carrying out the risk activity at a time when few people are around);
• Engineering controls: These are controls that rely on plant or equipment (such as machine guards, process enclosure, booths, fume cupboards) to prevent or reduce exposure to the chemical/s
• Administrative controls: These are controls that rely on safe systems of work to minimise risk. Examples include safe work procedures, tag and lock out procedures, job rotation, competency training and so on;
• Personal protective equipment: These are the last line of defence, and should never be relied upon to prevent exposures, but it's the approach most often favoured or advocated by employers. PPE includes helmets, safety glasses, respirators and masks, ear muffs, impervious gloves, aprons, safety boots and harnesses for fall protection. PPE can introduce other hazards, such as fogging in safety glasses, thermal discomfort communication problems and so on, and unless scrupulously maintained - as is often the case - can cease to function properly.

Where a risk assessment specifies that controls, such as isolation, engineering control, safe working procedures or PPE is recommended, they must be used, and must be used properly.

The Role of the HSR in this Process: Don't just accept that the current controls for the hazardous substances in use in your workplace are good enough. This is especially true if workers are showing signs and symptoms of exposure to chemicals. Use risk assessments and the hierarchy of controls to improve health and safety at work.

Case study: Glutaraldehyde

In the late 1980's the specialist applications of glutaraldehyde (electron microscope fixative, X-ray film developer and so on) meant it was a chemical with fairly narrow uses. The advent of HIV in the early 1980s demanded biocides that could destroy the virus. Claims that glutaraldehyde was an effective biocide meant that this chemical was more widely used, more people were using it and worker exposures were increased, in some cases excessively so. The number of workers exposed increased dramatically, and cases of ill health (including asthma and dermatitis) began to increase.

Firstly, Glutaraldehyde had not been classified fully - an example of why we should always be wary of supplier classifications and use other sources. The label/MSDS did not mention the chemical was a sensitiser- that it could cause asthma and allergic dermatitis and other sensitivity problems. However, few (if any) employers had carried out proper risk assessments, users knew the chemical was irritating and if at all, exposures were poorly controlled.

Here are examples at all levels of the Hierarchy of Controls when applied to Glutaraldehyde:

• Elimination: Use as a surface biocide on walls and floors must cease.
• Substitution: Bleach re-introduced as a biocide. More dilute solutions of Glutaraldehyde can be used where absolutely necessary.
• Isolation: Fully enclosed systems using Glutaraldehyde (or other sterilants) must be used.
• Engineering Controls: Ventilation/fume hoods must be used in places where exposures can be excessive, such as endoscopy units.
• Safe Working Procedures: Written working procedures for effective hazard control where tasks involving glutaraldehyde exposure can be minimised to the lowest possible level.
• Other Administrative Controls: Training of operators, job rotation and the like.
• Personal Protection: Skin, eye and respiratory protection where (and if) necessary.

Conclusion

There are a few chemicals that can never be used safely and as a community, we should move to prohibit their use. We should not take everything that hazardous chemical suppliers tell us uncritically. We should not take everything that employers tell us uncritically. The priority they might give to worker safety is probably not the same priority that workers would give to worker safety.

However, most chemicals can be used safely in the workplace, provided that:

• Hazards are known and understood.
• Chemicals are used correctly.
• The correct equipment for processing chemicals is available, used and maintained.
• Workers are informed about hazards and are trained in the correct procedures to control chemical risks (and they use them).
• Any problems that do arise (spills, splashes and the like) are fixed quickly.

Just make sure you can say this for all the chemicals you use at work.

IAC for chemicals is not brain surgery. And, it is required implicitly in OHS legislation - duty of care, and explicitly in hazardous substances regulation.

More information on the hierarchy: a Safe Work Australia podcast

Managing chemical hazards using the hierarchy of controls
Under the OHS/WHS laws, workplaces handling or using hazardous chemicals must manage health and safety risks by using the hierarchy of controls - that is, seek to eliminate the hazard/risk first. This video demonstrates what to consider when applying the hierarchy and how to go about choosing the appropriate controls.

SWA says that employers and businesses should review their chemical management strategies and use controls higher in the hierarchy in combination with lower level controls for the greatest effect. Employers should also ensure that workers receive training and supervision and consider the risks associated throughout the life of the chemical, for example, during storage, handling and disposal.

Last updated, December 2017

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