WorkCover. Watching out for you. New South Wales Government
MANAGING
CHEMICAL HAZARDS IN THE WORKPLACEADVICE FOR MANAGERS AND SUPERVISORS
GUIDE 1996WorkCover NSW Health and Safety Guide
DisclaimerThis publication may contain occupational health and safety and workers compensation information. It may include some of your obligations under the
various legislations that WorkCover NSW administers. To ensure you comply with your legal obligations you must refer to the appropriate legislation.
Information on the latest laws can be checked by visiting the NSW legislation website (www.legislation.nsw.gov.au) or by contacting the free hotline
service on 02 9321 3333.
This publication does not represent a comprehensive statement of the law as it applies to particular problems or to individuals or as a substitute for
legal advice. You should seek independent legal advice if you need assistance on the application of the law to your situation.
© WorkCover NSW
CONTENTS
INTRODUCTION 2
THE SIx bASIC STEPS 2
POLICy AND PROGRAM 3
JOINT CONSULTATION 4
TRAINING 5
IDENTIFy AND ASSESS WORKPLACE RISKS 6
RISK CONTROL 9
PROMOTE, MAINTAIN AND IMPROVE 11
CHECKING yOUR WORKPLACE 13
WHERE TO GET HELP 14
1
Introduction
The six basic steps
PURPOSE
The purpose of this booklet is to introduce managers and supervisors to the
requirements of the Occupational Health and Safety (Hazardous Substances)
Regulation 1996, (the Hazardous Substances Regulation for short).
There is also a code of practice to help you implement the Regulation: the
Code of practice for the control of workplace hazardous substances, (or the
Control code of practice for short).
For the retail industry, a Guidance Note for the Control of Workplace
Hazardous Substances in the Retail Sector is available.
This booklet outlines how you can protect yourself and others in the
workplace from the harmful effects of chemicals and other substances. It
suggests ways in which you can manage the health hazards posed by the use
of substances which are classified as hazardous by the Regulation.
Employees must be consulted when identifying hazards and the control
measures to be taken. Workplace OHS committees have an important role
here. Your committee (if you have one) should be included when developing
your policy and procedures.
PUbLICATIONS
A number of leaflets and guides on the Hazardous Substances Regulation are
available from WorkCover NSW - see back of this guide for details.
By assessing the risks arising from the use of hazardous substances at work,
you can help protect workers’ health.
The Regulation has a number of requirements. Taken together, they provide a
way of managing risk. There are six basic steps involved:
Six basic steps to safely manage chemicals in the workplace
1. Policy and program.
2. Joint consultation.
3. Worker training.
4. Identify and assess the risks in the workplace.
5. Use adequate risk control measures, including appropriate storage
and emergency plans.
6. Promote, maintain and improve – this includes monitoring, record
keeping and accident reporting.
2
In carrying out these steps, it may be necessary to delegate tasks to various
managers and supervisors in your organisation. It is also important that
supervisors and managers adopt day-to-day procedures to check and maintain
health and safety procedures in the workplace. So, some tasks should
become part of their normal duties.
Step 1 – Policy and
program
OHS POLICy
The first step in achieving improvements in workplace health and safety,
including the use of hazardous substances, is to have an occupational health
and safety policy.
Your health and safety policy is a statement of a principle that your
organisation upholds. It should state your belief and intent, give a clear
direction from management and include the entire organisation. It will also
be the basis for any occupational health and safety decisions and actions.
In summary, make sure that your policy:
• showscommitment
• ensuresaccountabilityatalllevels
• encouragesco-operation
• isabletobeclearlyunderstoodbyemployees.
CHEMICAL SAFETy PROGRAM
The principal aim of a chemical safety program is to systematically
investigate potential chemical hazards in order to minimise the risk of
adverse health and safety effects due to exposure to hazardous substances in
the workplace.
Larger workplaces should have a chemical safety program which consists of:
• anactionplanwhichdetailsthepartthatemployers,employeesandthe
health and safety committee are each expected to play
• alistofprogramprocedures
• organisationchartsshowinglinesofresponsibility
• emergencyplans
• auditreports
• recordsofanyaccidentsorpotentiallyhazardousincidents.
For very small workplaces, some of the items of this program may not be
practical.
The program should also aim to ensure that employees with potential for
exposure to hazardous substances used at work are provided with education
and training. This should cover the nature of hazards and means of assessing
and controlling exposure to workplace hazardous substances.
3
4
The Regulation requires employers to consult with employees (who are likely
to be exposed to risks) on all aspects of the Regulation and any changes to
work practices.
Exposure often depends on the way the chemicals are used. When doing an
assessment, involve the people working with the product in helping to identify
the hazards. Consult employees, supervisors and others with knowledge and
expertise, including plant managers, production managers, floor supervisors,
union representatives and members of the workplace OHS committee.
Health and safety procedures, such as exposure control measures, should not
be introduced without first consulting all people likely to be affected by any
hazardous substance. This includes determining the likely exposure of people
working near to where hazardous substances are used, as well as those who
use them directly.
Step 2 – Joint consultation
Emergency services and other relevant public authorities must have access
to relevant information on workplace hazardous substances and implement
appropriate emergency procedures.
There must be regular checks on the performance of exposure control
measures.
An adequate level of information should be provided to employees through
the provision of MSDS, labelling and training. All hazardous substances used
at work should be provided with labels and MSDS which conform to the NSW
Hazardous Substances Regulation Standard.
Dangerous goods must be stored in accordance with the NSW Dangerous
Goods Regulation.
Standard operating procedures (SOP) should be developed which provide
an organised and planned approach to ensure safety control and accident
prevention for maintenance. These SOP record that correct procedures have
been followed.
Safety systems must be systematically documented. Standards must be set
for health and safety management work.
Provision must be made for regular auditing and review of safety systems
against standards. The levels of responsibility for managers and employees
should be specified along with the tasks and goals for each of these groups in
relation to each of these elements.
Many of these issues will be refined and developed in the successive steps
below.
5
FORMING AN OHS WORKPLACE COMMITTEE
The Occupational Health and Safety (Committees in Workplaces) Regulation
1984 has detailed provisions on the formation, composition and regulation
of OHS committees. The Regulation applies to workplaces with 20 or more
employees. The Occupational Health and Safety Act, 1983 states that
an OHS committee must be established if the majority of the persons in
that workplace request it. For more information, refer to the WorkCover
publication, How to establish an occupational health and safety committee in
your workplace.
The workplace OHS committee also has an important role in recommending
that appropriate training and instruction is carried out in the workplace.
Information must be given to workers, through training. To ensure that
everyone in the workplace receives relevant information, a formal, regularly
updated training program must be developed. The training program should be
related to the activities in the workplace and cover:
how chemical exposures can occur •
the possible results of chemical exposure •
how to read chemical labels and MSDS •
how to follow safe working procedures •
how to use protective equipment •
emergency and first aid procedures. •
Training should also explain the need for workplace monitoring and •
health checks in relevant cases.
A training package, entitled Occupational Health and Safety Workplace
Substances Training Course has been developed by WorkCover. This is
designed to assist employers in meeting their requirements under the
Hazardous Substances Regulation. It is available to trainers accredited
by WorkCover. For further information, please contact the WorkCover
Occupational Health and Safety Education Unit on ph: (02) 370 5290.
Step 3 – Training
6
Step 4 – Identify
and assess workplace risks
FIND INFORMATION AND PROVIDE IT
Information about a chemical used in a workplace is found:
on the label of the container; •
on the Material Safety Data Sheet (MSDS); and •
in publications such as codes of practice and standards. •
The label on the container is the first point where people get information
about the chemicals they are using. In many situations, you can tell if
substances are hazardous from the labels on containers arriving in your
workplace. So, many employers will not have to know the technical details of
the classification.
However, if you produce or import hazardous substances then you are
responsible for classifying them. You must use the official definition. The
details are given in the Worksafe publication Approved Criteria for Classifying
a Hazardous Substance. Common hazardous substances are included in the
Worksafe publication, List of Designated Hazardous Substances. You can get
these from the WorkCover bookshop or from a Commonwealth Government
bookshop (see back of this guide for details). The definition of a hazardous
substance includes mixtures.
LAbELS
You must make sure that containers of chemicals and other hazardous
substances in your workplace are labelled. Labels identify the product and
provide safety information including:
the dangerous goods ‘diamond’ and/or the poisons label, where •
appropriate
the chemical name(s) of the ingredient(s) •
the trade name of the substance •
possible harmful effects of the substance •
how to use the substance safely. •
If the label does not give you this information, contact the supplier or
manufacturer. You must ensure that the labels on containers of hazardous
substances are appropriate. If you produce hazardous substances, you should
label them according to Worksafe’s Code of Practice for the Labelling of
Workplace Substances.
Process containers, such as vats and pipes, should be labelled to identify the
contents.
7
MATERIAL SAFETy DATA SHEETS - MSDS
The material safety data sheet (MSDS) should provide detailed information
about:
the substance’s trade name and chemical name(s) (including ingredients •
in mixtures)
health hazard information •
precautions for use •
safe handling of the substance. •
The MSDS must be readily available so that workers can get information
about health hazards in addition to that provided on the label. The
manufacturer or supplier of the chemical must provide an MSDS with every
substance that is classified as hazardous. Manufacturers and importers are
responsible for preparing MSDS.
The MSDS should meet the standard laid down in Worksafe’s Code of
Practice for the Completion of a Material Safety Data Sheet. For imported
substances, ILO (International Labour Organisation) and EU (European
Union) formats are acceptable.
ASSESS THE RISKS IN yOUR WORKPLACE
People can be exposed to the same hazardous substance in different ways.
The level of exposure may vary depending on factors such as how close to a
process a person is working, or the effectiveness of ventilation.
Under the Regulation, you must assess the exposure risks of each hazardous
substance, for each person in the workplace. The results will indicate the
areas where control measures are necessary.
‘Risk’ is the likelihood that harm will result from use of the substance.
‘Hazard’ is a basic property of a substance (for example its toxicity as
determined by tests). The degree of risk depends on the dose - that is, how
much of the hazardous substance can actually get into the body.
To assess the risk of exposure:
a. identify the hazardous substances used in the workplace and list them in
an inventory;
b. obtain information about the hazards to health and safety presented by
these substances;
c. determine the degree of exposure to the hazardous substances;
d. assess the risk to the health and safety of each employee, and
e. decide actions necessary to control risks.
8
Routes of entry:
breathing in
swallowing
skin contact
IDENTIFy SUbSTANCES
It is important for you to know exactly what hazardous substances are in use
in the workplace. Initially check if everything is labelled. Make a list of all
hazardous substances to form an inventory. Don’t forget to consider dusts
and other emissions produced in the workplace. A mixture counts as one
substance.
Adopt a system that will ensure all new chemicals entering the workplace
are added to the inventory and that MSDS are obtained and filed with the
inventory, forming a register.
This task may be easier if you divide your workplace up into areas or work
activities and do each one separately.
ObTAIN INFORMATION
Next, make sure you have MSDS for all the hazardous substances delivered to
your workplace. Check the MSDS for data on health hazards and precautions
for use. Compare this with your existing situation. You may not have an
MSDS for dusts and emissions, so you should compile information like that
contained in an MSDS.
DETERMINE ExPOSURE
Check who is using which hazardous substance and how. Then identify
those employees who may be exposed to each hazardous substance in an
amount which is likely to harm health. Consider the ‘routes of entry’, that
is the ways the substance may enter or touch the body. These include skin
contact; inhalation (breathing in) through the nose or mouth; and ingestion
(swallowing) through the mouth.
ASSESS THE RISK TO EACH EMPLOyEE
The Control code of practice gives guidance on how to do an assessment. The
Worksafe Guidance Note for the Assessment of Health Risks Arising from the
Use of Hazardous Substances in the Workplace is also useful here. You may
be able to use information from other similar workplaces as a guide.
You may find that there is no risk to health. In this case, record this in your
register.
On the other hand, it may be necessary to use a wide range of extra
information. This may include measurements of the amount and time of
employee exposure. This is called ‘monitoring’, and should be done by a
competent person,
such as an occupational hygienist. Air monitoring of the workplace may
be required at regular intervals, to check on the effectiveness of control
measures. This need should be specified in the assessment report.
9
Step 5 – Risk control
Air monitoring may be required at regular intervals
The Regulation requires you to minimise the health risks - this means
that exposure should be as low as possible in your working situation. If a
maximum exposure level has been set for the substance, you can usually
find this on the MSDS. You must not exceed the exposure limit listed in the
Worksafe Standard, Exposure Standards for Atmospheric Contaminants in the
Occupational Environment. These exposure standards are regularly updated.
For a small number of hazardous substances, regular health checks of
workers may be required. The assessment report should determine if this is
required. Further information is given in the next section, Decide action to
control risks.
If the exposure of an employee reaches the exposure standard, or there are
health indications that exposure is too high, immediate action must be taken
to reduce the health risk. An example of action to be taken is to improve
control measures.
DECIDE ACTION TO CONTROL RISKS
If the assessment shows that there is a risk to health or safety, you will need
to:
record the assessment and conclusions about control; •
select control measures; •
ensure that those control measures are properly used and maintained; •
arrange induction and training; and •
determine if monitoring or health surveillance are required•
The Regulation requires you to implement control measures to keep exposure
to hazardous substances as low as practicable, when an assessment has
shown the need. The Control code of practice outlines the various measures
which can be used to eliminate or reduce exposure. These measures are
listed in order of priority, so the higher up the control appears on the
following list, the better it is.
ELIMINATION
Where a task involves the use of a hazardous substance that is not essential,
the hazardous substance should be eliminated, if practicable. An example of
elimination is cleaning by the use of ultrasound instead of chemicals - this is
a physical rather than a chemical process.
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SUbSTITUTION
Substitution includes exchanging the hazardous substance for a less
hazardous one; using the same substance in a less hazardous form; or
using the same substance in a less hazardous process. Examples include:
using a less toxic pesticide and using a non-flammable solvent in place of a
flammable solvent.
ISOLATION
Isolation of the process by distance or the use of barriers can prevent or
reduce employee exposure. The remote operation of a process is an example
of isolation.
ENGINEERING CONTROLS
Engineering controls involve the use of plant or processes which:
minimise the generation of hazardous substances (that is, they are less •
likely to create hazardous substances)
suppress or contain hazardous substances (so the •
substance is not released) •
limit the area of contamination in the event of spills or leaks. •
Engineering controls include enclosure or partial enclosure, local exhaust
ventilation and automation of processes.
SAFE WORK PRACTICES
Safe work practices are administrative practices which require people to work
in safer ways. Examples include: permit to work systems; excluding any non-
essential access; providing means for safe storage and disposal of hazardous
substances; banning eating, drinking and smoking in contaminated areas;
vacuuming dust from areas where cutting processes take place; keeping lids
on containers when they are not in use; and using facilities for effective
decontamination.
PERSONAL PROTECTIVE EqUIPMENT
As far as practicable, control exposure by the measures listed above rather
than by the use of personal protective equipment (PPE). Limit the use of
personal protective equipment to situations where other control techniques
are not practicable or where they do not adequately control exposure.
PPE may be used as a temporary measure until adequate control is achieved
by other means (for example, where urgent action is required because of
plant failure or during routine maintenance operations). Although exposure
occurs regularly during such work, the infrequency and small number of
people involved may rule out other control measures.
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Step 6 Promote, maintain
and improve
Personal protective equipment must be selected and used in accordance
with WorkCover NSW approval (for equipment where approval is given) and in
compliance with the relevant Australian Standards.
ENSURE CORRECT STORAGE
Check the MSDS for advice on storage and chemical compatibility.
All substances which are classed as dangerous goods should be stored
in accordance with the Regulations of the Dangerous Goods Act, 1975.
Dangerous goods entering the workplace are usually identified by the class
(‘diamond’) label on the container. WorkCover has an accredited dangerous
goods consultant scheme.
ESTAbLISH EMERGENCy PLANS
You should establish and write down an emergency plan and procedures in
case of leaks, spills or other uncontrolled releases of hazardous substances.
The procedures should cover: first aid, emergency showers, evacuation
procedures, safe disposal methods, identifying source(s) of release, repairs
and follow-up.
The plan should be revised from time to time. Details of the plan should be
included in employee training.
MONITORING AND HEALTH SURVEILLANCE
In some situations you may need to regularly check the amount of hazardous
substances in the air. This ongoing air monitoring is in addition to the initial
assessment. It is needed in order to check that control measures are working
and that worker exposure is minimised.
A workplace air monitoring program should be carried out by, or in
consultation with, a properly qualified person, for example an occupational
hygienist. Records of the results of workplace monitoring must be kept for 30
years.
Where employee exposure is found to be close to the exposure standard for
the substance in use, or where medical reasons indicate the exposure is too
high, immediate action must be taken to reduce the health hazard.
For a small number of hazardous substances, the additional step of regular
health checks for workers may be necessary. A list of substances requiring
health surveillance is included in the Hazardous Substances Regulation.
Regular checks of people exposed to hazardous substances helps in detecting
early changes to health related to the exposures. It provides a record of
any toxicity in individuals. This may involve a medical examination or other
tests, such as blood or urine tests. In some cases health surveillance may be
required in addition to workplace air monitoring.
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Health surveillance reports are confidential and employees’ reports cannot
be released without their written consent. Individuals should be informed of
their surveillance results. The employer is also informed of the results and
the need for action, if any.
WorkCover NSW must be notified of certain adverse effects found through
health surveillance. Advice can be obtained from WorkCover’s Occupational
Medicine Branch, on (02) 370 5153.
RECORD KEEPING
The employer must ensure:
that the results of health surveillance remain confidential and are held •
for not less than 30 years
other records, such as assessment reports and the results of air •
monitoring, which do not indicate a need for surveillance are kept for at
least five years.
Records must be kept for this long period because some health effects, such
as cancer, may take a long time to become evident. The medical practitioner
is also required to keep the medical records obtained as a result of health
surveillance as confidential records. The records must be given to WorkCover,
not destroyed, if the workplace or medical practitioner ceases to trade.
Accidents and injuries often highlight the need for safety measures.
Workplaces should establish practical systems for reporting and recording
accidents, occupational illnesses and incidents, such as chemical spills.
ACCIDENT REPORTING PROCEDURES
The OHS workplace committee should monitor the system of accident,
illness and incident reporting and recording in the workplace. To this end,
the committee can examine statistical data and reporting procedures on
accidents and diseases in the workplace.
The committee should examine how well the accident reporting and recording
system is functioning and advise on improvements. The legal requirements
for reporting accidents, illness and incidents to WorkCover NSW should also
be followed. To assist with injury and disease reporting in the workplace refer
to Australian Standard AS 1885.1 - Workplace Injury and Disease Recording
Standard.
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The following checklist is designed to help you carry out the above
management plan.
HAZARDOUS SUbSTANCES MANAGEMENT CHECKLIST
1. Are all containers of hazardous substances adequately
labelled?
2. Have MSDS been obtained for all hazardous substances in
use?
3. Does the workplace have a hazardous substances register
listing the chemicals used at the workplace?
4. Has an assessment of the risks of exposure to hazardous
substances been carried out?
5. Have recommended control measures been documented?
6. Have recommended control measures been put in place?
7. Are there written procedures for the introduction of new
substances to the workplace?
8. Is air monitoring necessary? If yes, has this been
scheduled and a competent person appointed to do it?
9. Has a training program for people using hazardous
substances been established?
10. Have all the people who should be trained under the
training plan received current training?
11. Have all the confined spaces on the site been identified
and work procedures written down including ‘permit to
enter’ procedures?
12. Are health checks necessary? If yes, have these been
scheduled and a competent person appointed to do them?
13. Are dangerous goods stored in compliance with the
dangerous goods Regulations?
14. Have emergency procedures been established and
documented?
15. Do regular emergency drills take place? Are drills evaluated
and observed shortcomings addressed?
16. Are waste hazardous substances disposed of appropriately?
Are there written procedures for this?
Some of these steps can be taken before you order new chemicals.
Particularly when planning a new process, compare alternative chemicals and
use the MSDS to check possible hazards.
Make sure that MSDS are provided when sales representatives give you trial
chemicals.
Checking your workplace
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Where to get help For assistance and advice contact WorkCover by:
Phone: 13 10 50
Email: [email protected]
Visit the WorkCover website at www.workcover.nsw.gov.au
Order publications by calling 1300 799 003.
Catalogue No. WC00454 WorkCover Publications Hotline 1300 799 003
WorkCover NSW 92-100 Donnison Street Gosford NSW 2250Locked Bag 2906 Lisarow NSW 2252 WorkCover Assistance Service 13 10 50Website www.workcover.nsw.gov.au
ISBN 0 7310 5194 7 ©Copyright WorkCover NSW 0708