Managing Dangerous Substances & No Time to Lose Campaign

IOSH Ireland East Branch

24th October 2018

Dangerous Substances – an Irish experience.

Michelle McDermott

https://healthy-workplaces.eu/en

Healthy Workplaces MANAGE DANGEROUS SUBSTANCES 2018-19

“any liquid, gas or solid that poses a risk to workers’ health

or safety”https://osha.europa.eu/en/themes/dangerous-substances

3 steps to manage dangerous substances

Identify hazards

Assess exposure

Set measures /controls

CHEMICALS- Identification

Label

https://hsalearning.ie/

BUT ….

Risk Assessment

“no asbestos material was found during the 2004 demolition”

https://www.iosh.co.uk/News/Black-cabs-research.aspx

Hazards not identified

Other Dangers..….• Biological Agents • https://osha.europa.eu/en/theme

s/dangerous-substances• emerging risks• green jobs • nanomaterials

When the Inspector Calls……

Chemicals

CMRLead

RCS

Radon

Noise

VibrationAsbestos

Biological Agents

Legionella

Why?

Do you have one?

Chemical Inventory

When the Inspector calls...Risk Assessment

* Risk * Assessment

SDS

Routine & Non Routine

Process / Work

MethodsHealth

Surveillance

Monitoring

Information

• Examples Include • Asbestos Survey

• Incidents

• Equipment Manuals

• Maintenance Requirements

• Regulatory Websites

• Safety Alerts

• Noise Survey (ototoxic)

• Good Practice Guides

• Etc….

“Risk of Dermal Exposure”

Assess the exposure

Consider:

WHAT IS THE EXPOSURE?

WHO uses the

chemical?

HOW LONG is user exposed to chemical?

HOW OFTEN is chemical used?

HOW is the chemical used?

HOW will user be exposed?

HOW MUCH is used?

Can NON-USERS be exposed?

“Same Chemical!”

Life Cycle Risk Assessment

Emergency &

Interaction

Ordering

Delivery

Storage

Transport

Use

Disposal

Chemical Storage

• A, B, C, D …….NO

• Safety Data Sheet – section 7 & 10

• Acid and Alkali corrosives – incompatible

Risk – very low, acceptable, unacceptable?

Exposure Controls

Exposure Controls

PPE

RPE LEV

SDSHierarchy of

Control

* Risk * Assessment

Carcinogens Regulations

Employer Obligation

• reduction of the use of carcinogens and mutagens at the workplace,

• the prevention or reduction of workers’ exposure to carcinogens or mutagens

• and the measures which should be implemented to that effect.

Measures : in so far as is technically possible,

• the replacement of the carcinogen or mutagen by a substance, mixture or process which is not dangerous or is less dangerous to workers’ health,

• the use of a closed system or other measures aiming to reduce the level of workers’ exposure.

In that context, it is essential to take the precautionary principle into account where there are uncertainties.

Hierarchy of Control

• Principles of Prevention

• Substitution support• www.echa.europa.eu• http://www.subsport.eu/• Importance of Design

Capture hood – must be fit for purpose

What not to find…

• Controls must consider all hazards of the task so additional risk are not created and controls are compatible.

Approaches to documentation

Construction Risk Assessment ???

Hazard: DustControls:•Work will be assessed to determine activities that generate dust •BUT……..•All internal dust shall be removed •BUT HOW…..

Risk Assessment Process

• SDS & Label & Other

• Environment

• Process / Task

• Who & How?

Risk Assessment

• Process ?

• LEV ?

• PPE ?

• Consultation

Controls• Training

• Maintenance

• Monitoring – audit, air, HS

CHECK

What not to find

Can you combine with other documents ?

•Cleaning Regime?

•SOP?

•NOP?

•Method Statement ?

•Quality Procedure?

•Laboratory Protocol?

More relevant “risk assessment”Use of Con saw to cut blocks

• Consider Task / Activity based

• Hazards - RCS, Noise, ergonomic…..

• Risk of Silicosis, hearing loss, WRULD, …..

• Controls =

Formulation XYZ Risk Assessment

Add 50l water to Tank A

Weigh and add 50kg powder to tank Wear dust mask, wear goggles,

wear gloves

Close lid and turn on mixer No PPE required

Add 5L of solvent directly to tank Wear half face mask and safety

glasses

Weigh and add 34kg powder to tank Wear dust mask, goggles and wear

gloves

Mix and slowly add 10l of solvent to tank Wear half face mask, eye

protection, gloves

Is this compliant ? ? ? ? ?

Hazard information

• Powder contains silica - Exposure to silica dust during weighing , addition

to tank and sweeping – can cause silicosis

• Solvent vapours can cause headaches, dizziness, and defatting of skin

• Process takes approximately 1 hour and is carried out 6 times per day

• There is 1 hour clean up at end of shift – dry sweeping of dust, rinsing of

tank using solvent containing benzene which causes cancer

• Manual handling of powder and solvent drums

• There is an annual maintenance and clean of the tank

• In event of malfunction contact Service Technician immediately.

Controls1. Wear powered respirator with A2P3 filter

2. Wear nitrile rubber gloves to EN374, 1 mm thick. Dispose of

after each cycle.

3. The powder is delivered to weighing location by pallet truck.

4. The solvent is piped directly to area beside tank.

5. Powder to be weighed in 10kg batches.

6. In event of spill, continue wearing PPE and use spill material

located in area and dispose of waste in chemical shed

containers

7. Health surveillance provided– all staff trained on skin checks

and lung function questionnaire once per year with follow up

as required

Risk Reduction Plan

1. Correct RPE and training – immediately

2. Eliminate Dry sweeping

3. Investigate elimination of weighing and

measuring– can powder be purchased in

preweighed bags or automatic dispensing

of powder or liquid?

4. Local exhaust ventilation to be

investigated

5. Consider monitoring as part of above

project – see Code of Practice for

Chemical Agents.

6. Alternative methods for cleaning to be

investigated

1. New RPE to be purchased and

personnel trained - A. N. Other

2. Vacuum with HEPA filter to be

purchased by 13 November

2015- A. N. Other

3. - 5 Project for A Baker (advice

of a competent occupational

hygienist to be sought)

Initial report due by 13 December

2015

Risk Reduction Plan

1. Eliminate Dry sweeping

2. Investigate elimination of weighing and

measuring– can powder be purchased in

preweighed bags or automatic dispensing of

powder or liquid?

3. Local exhaust ventilation to be investigated -

Responsibility of A Baker by 13 December 2015

(advice of a competent occupational hygienist

to be sought)

4. Consider monitoring as part of above project –

see Code of Practice for Chemical Agents.

5. Alternative methods for cleaning to be

investigated

1. New RPE purchased and personnel trained - A. N.

Other - COMPLETE-

2. Vacuum with HEPA filter to be purchased by 13

November 2015- COMPLETE- risk assessment of use

and emptying and training carried out – Documented

in Clean up SOP

3. & 4 & 5 - Project for A Baker

Initial report due by 13 December 2015

Initial report indicates:

• preweighed bags - cost €X,

• Automatic dispensing of powder - cost by €Y

• Bulk purchase of solvents and a solvent line with in

line metering will cost €Z

• Possible elimination of RPE so reduction in fit test

costs, cost of filters and health surveillance

• Alternative cleaning method identified with no

benzene – See Carcinogens Regulations, Cost neutral

as increased cost of new method off set against

reduced disposal (waste is non-hazardous)

Risk Control Process

• SDS & Label & Other

• Environment

• Process / Task

• Who & How & when?

Risk Assessment

• Process ?

• LEV ?

• PPE ?

Controls• Training

• Maintenance

• Monitoring – audit, air, HS

CHECK

2582 participants in biomonitoring study - 85 % had a mixture of 40 substances. 5% had extreme levels

Europe• EU-OSHA - NAPO man

https://www.napofilm.net/en/napos-films/napo-danger-chemicals - The Napo series of films are produced in computer graphics. They feature characters in the world of work, faced with health and safety issues. There are several with chemical themes.

• European Commission

• European Chemicals Agency

Roadmap on Carcinogens

• https://roadmaponcarcinogens.eu/

• https://roadmaponcarcinogens.eu/solutions/good-

practices/dust-free-working/

• http://www.dustfreeworking.tno.nl/

• http://www.hazchematwork.eu/

HSA• www.hsa.ie

• www.besmart.ie http://hsalearning.ie/ - courses here for small business- employers and employees and chemicals

• http://www.hsa.ie/eng/Topics/Simple_Safety/

• Newsletters

• Safe Supply, Use and Management of Chemicals -www.hsa.ie/chemicals

• Chemicals Helpdesk –chemicals@hsa.ie

BOHS & IOSH

• http://www.notimetolose.org.uk/

• http://www.breathefreely.org.uk/

Legislation• Many of the above will refer to UK or other legislation so please download the

full texts of the Irish legislation from www.irishstatutebook.ie . See:

• Safety Health and Welfare at Work Act, 2005

• Safety Health and Welfare at Work (General Application) Regulations, 2007

• Safety Health and Welfare at Work (Chemical Agents) Regulations 2001

• Safety Health and Welfare at Work (Chemical Agents) (Amendment) Regulations 2015

• Safety Health and Welfare at Work (Carcinogens) Regulations 2001

• Safety Health and Welfare at Work (Carcinogens) (Amendment) Regulations 2015

• Safety, Health and Welfare at Work (Construction) Regulations 2013

• Updates to Carcinogens and Mutagen Directive underway

The Health and Safety Authority wish to make it clear that only the Courts can interpret statutory legislation with any authority and this information is subject to revision in the light of further information.

Additional external sources of information are provided. The HSA is not responsible for, and cannot guarantee the accuracy of information on sites that it does not manage; nor should the inclusion of a hyperlink be taken to mean endorsement by the HSA of the site to which it points.

https://eguides.osha.europa.eu/dangerous-substances/my-chemical-guide

1. Do you know which risks with dangerous substances may occur at your work places and have you documented the risks?

2. Hazard pictograms – if you have products with these labels, are the labels understood?

3. Have you got a list of the chemical products in use or stored in your company?

4. Do you use and understand the Safety Data Sheets?

5. Are dangerous substances generated in any process in your enterprise?

6. Are the workers aware of the risks with the chemical products and do they know how to work safely and how to protect themselves?

7. Has any of your employees had health complaints or has been ill due to exposure to dangerous substances present or used in your business?

https://eguides.osha.europa.eu/dangerous-substances/my-chemical-guide-long-questionnaire

• Hazard pictograms

• The danger symbol(s) - double-check question

• Products with fire or explosion risks

• Specific chemical products and dangerous substances

• Are dangerous substances that contaminate the air generated in your workplace?

• Eye wash and emergency shower

• Pregnant or breastfeeding

• Young workers

• Space for specific national protection of groups of workers

• Specific activities

• Imports, mixing, repacking and distributing

• Specific chemical substances — asbestos

• Identify and dispose unnecessary chemicals

• Safety data sheets

• Safety data sheet — quality control

• Knowledge and awareness of risks and how to work safely

• Knowledge and awareness of risks and how to work safely — are knowledge and routines good enough?

• Register

• Risk assessment• Risk assessment — is it good enough?• Purchasing• Routines for purchasing!• Storage• Do you use the substance or chemical product for only

the uses that are listed in the safety data sheet?• Exchange / substitution of dangerous chemical products• Exchange / substitution - outcome • Technical measures to reduce the emission of

dangerous substances into the air in workplaces• Technical measures to reduce the emission of

dangerous substances into colleagues’ workplaces• Personal protective equipment • Personal protective equipment – quality check• Signs and labelling – always available• Safety measure: emergency eye-wash fountain and/or

emergency shower• Safety measure: emergency eye-wash fountain and/or

emergency shower — quality control• Occupational accidents and injuries involving chemical

products• Reporting of occupational accidents and injuries

involving chemical products• Follow-up of occupational accidents and injuries

involving chemical products

http://hsa.newsweaver.co.uk/hsaevents/12rx2cxcej6-1kc5hxmpuz?email=true&a=11&p=53928834

The Health & Safety Authority is inviting all companies using or trading products containing chemicals to participate in its 2018 online chemical usage survey.

The aim of the survey is to establish the general levels of awareness and knowledge among Irish companies of EU chemical legislation. In light of the UK vote to leave the EU, the survey will also gather information on the potential impacts this may have on the trading of chemicals between the UK, Northern Ireland & Ireland. The survey also hopes to gauge the specific knowledge of companies regarding chemicals subject to REACH authorisation and the Rotterdam Regulation for exporting and importing chemicals outside of the EU.

The survey findings will be used by the Authority to identify key programme areas where it can provide specific support to Irish companies to manage chemical safety. It will also help identify aspects where companies may need more support to achieve regulatory compliance when the UK exits the EU in 2019. Your participation is therefore important.

Businesses and workplaces using or trading products containing chemicals are invited to complete the survey and be in with a chance of winning an iPad.

To Do………• Do you have an Asbestos Register?

• Do you have a Chemical Inventory?

• Do you manufacture or import substances?

• Have you considered BREXIT on your REACH & CLP obligations ?

• Does you risk assessment comply with the Chemical Agents Regulations?

• Do your controls follow the Hierarchy of Control?

• Do your controls work? How do you know?

• Are personnel trained on PPE?

• Are personnel fit tested for RPE?

Thank you

IOSH No Time to Lose campaign:

spotlight on asbestos

#NTTLasbestos

Louise HoskingIOSH Vice President