kertas 4 intro to sirac

SIMPLE RISK

ASSESSMENT AND

CONTROL FOR

CHEMICALS

(SiRAC)Rusnah Bt Nanyan

Chemical Management Division

DOSH, Headquarter, PUTRAJAYA

Session Objectives

State the legal requirements for SiRAC

Explain the differences between CHRA

and SiRAC

State the scope and application of SiRAC

Concept and Steps of SiRAC

Legal Requirements

Sub-Regulations 10(1) of

USECHH Regulations 201X

“An employer shall not carry out any work which may expose or is likely to expose any employee or any other person to any chemical hazardous to health unless he has made a written assessment of the risks created by the chemical to their health.”

Sub-Regulations 11(1) USECHH

Regulations 201X

“The employer MAY conduct a simple assessment for a chemical hazardous to health, if-

a) The chemical is listed in the register stipulated under sub-regulation 6(1); and

b) The chemical is NOT classified as carcinogenicity category 1, mutagenicity category 1 or respiratory sensitizer category 1 as specified in the Occupational Safety and Health (Chemical Classification, Labelling and Safety Data Sheet) Regulations 2013


Regulations 201X

Simple assessment shall contain the

following-

1. the nature of the hazard to health;

2. the exposure potential arising from the use

of chemical hazardous to health; and

3. the measures and procedures required to

control the exposure of an employee to

chemicals hazardous to health.


201X

“The employer may appoint a trained

person to carry out a simple assessment

pursuant to sub-regulation 11(1)”

Types of Assessment

Types of Assessments

Full Assessment

Chemical Health Risk Assessment (CHRA)

Generic Assessment (GCHRA)

Simple Assessment

Simple Risk Assessment and Control (SiRAC)

9

Identify chemical used in particular

work unit and its hazard

taMeet criteria in subreg 11(1)

USECHH 20xx & required

information available?

Conduct Chemical Health Risk Assessment (CHRA)

Develop action plan

Implement action plan

Conduct simple Assessment (SiRAC)

NO

YES

Control approach 1,2 or 3?

YES

NOSeek specialist advice

CHRA and SiRAC

10

Who to Conduct SiRAC?

Trained Person1. Knowledge, training and expertise in understanding hazard

and risk;

2. Ability and authority to collate all necessary and relevant

information;

3. Knowledge, skills and experience to make the right

decisions about risks and the necessary precautions;

4. Knowledge on the SiRAC manual

5. How the work activity uses chemicals hazardous to health;

6. How to interpret SDS; and

7. Basic requirements of OSHA, USECHH, relevant guidelines

SiRAC Methodology

SiRAC Methodology

SiRAC is based on the control banding

approach

Other control banding approaches:

COSHH Essentials (HSE of United Kingdom)

ILO Control Toolkit (ILO)

KOSHA Toolkits (Korea)

Stoffenmanager (Dutch)

Scope & Application

Application of SiRAC By default, USECHH 201X requires full

assessment (CHRA) to be conducted for every place of work where chemicals hazardous to health are used (Reg. 10(1))

SiRAC is an option given to employer who uses chemicals meeting the following criteria:

a) chemical is listed in the mandatory register ;

b) chemical is NOT classified as carcinogenicity category 1, mutagenicity category 1 or respiratory sensitizer category 1 as specified in the CLASS Regulations 2013

Application of SiRACEven though legally SiRAC is an option given to employer who uses chemicals meeting the criteria in sub-regulation 11(1), there is also a limitation in applying SiRAC for the following chemicals:

Process generated dusts and fumesE.g. wood dusts, fume released from molten metal

Organic dustE.g. grain dust, cotton dust, paddy husk dust

Gases

E.g hydrogen sulphide, ammonia Scheduled wastes as listed EQ (Scheduled Wastes)

Regulations 2005

Routes of Entry

Routes of Entry-SiRAC Inhalation Skin/Eyes Contact

Concepts and Steps

CHEMICAL

RISKS?

Probability of harm, injury, illness or disease from

overexposure to chemicals

Risk = Hazard x Exposure

Hazard is determined from chemical classification

Exposure is determined by the quantity of chemical

used and its ability to become airborne

Routes of exposure considered in SiRAC is

inhalation, dermal contact and absorption

Chemicals

causing harm

when airborne

Chemicals capable

of causing harm if in

contact with

skin or eyes

+

Group A

Group B

Group C

Group D

Group S

HAZARD DETERMINATION

HAZARD DETERMINATION

Hazards are grouped into 4 groups (for

chemicals causing harm when airborne):

Group A (least hazardous)

Group B

Group C

Group D (most hazardous)

23

HAZARD

DETERMINATION

Group Schemicals capable of

causing harm if in contact with eyes or skin

H-CODE

H-code or the hazard statement code describes the nature of the hazards of the chemicals as specified in First Schedule of the CLASS Regulations 2013

It is assigned to each of the hazard statement

used for reference purposes

not part of the hazard statement text and shall not be used to replace it.

Examples of H-code:

H301: Toxic if swallowed

H310: Fatal in contact with skin

H317: May cause an allergic skin reaction

Direct Advice

Specific CGS (based on task performed)

for work activities or industries covered are :

Pest Control (Table 3.8)

Soldering (Table 3.9)

Cleaning Services

(Table3.10)

Lithography Printing (Table

3.11)

EXPOSURE DETERMINATION

Magnitude of

Exposure

Scale of Use

&

Ability to Become

Airborne

+ Frequency &

Duration

Per Operation/Batch

Or

Per Day

Total Duration >

15 minutes per day


1. Scale of use

Determine the way chemical is handled and how much employees are exposed

Amount used per batch/operation or per day (continuous operation) can be described as

SMALL , MEDIUM, LARGE

Quantity Solid Liquid

Weight Typically received in Volume Typically received in

Small Grams Packets or bottles Millilitres Bottles

Medium Kilograms Kegs or drums Litres Drums

Large Tonnes Bulk Cubic metres Bulk


2. Ability to become airborne

Physical form of the chemical affects how likely it is

to get into the air.

For solids - determined by its dustiness

Depends on its physical form-the finer the solid the more

likely for it to become airborne

For liquids-determined by its volatility

Volatility depends on its vapour pressure - the higher the

vapour pressure, the more volatile the chemical

Volatility also depends on the operating temperature - the

higher the operating temperature, the more easily vapour

will be formed and become airborne

Level Descriptions Example

Low Pellet like solids that don’t break up. Little dust is

seen during use.

PVC pellets, waxed

flakes

Medium Crystalline, granular solids. When used, dust is seen,

but settles out quickly. Dust is left on surfaces after

use.

Soap powder.

High Fine, light powders. When used, dust clouds can be

seen to form and remain in the air for several

minutes.

Cement, carbon black,

chalk dust.

Table 3.4: Level of dustiness

Degree Descriptions Example

High Boiling point below 50oC Butadiene

Medium Boiling point between 50 and

150oC

Acetaldehyde, acetone,

chloroform, diethylamine

Low Boiling point above 150oC Ethylene glycol, carbon

tetrachloride, n-butyl

acetate

Table 3.5b: Degree of volatility based on boiling point at 25oC

VAPOUR PRESSURE

Pressure exerted by a vapour.

Describes tendency of a chemical to form vapour

Useful (with evaporation rate) in estimating how

quickly a substance becomes airborne within the

workplace (estimation of the inhalation or fire

hazards)

High vapour pressure => volatile(easily vapourised)

Volatility band Vapour pressure

Low Less than 500 Pa

Medium 500 to 25 000 Pa

High More than 25 000 Pa

CONTROL APPROACH

TRADITIONAL CONTROL BANDING

Elimination

Substitution

Modification

Containment

Ventilation

Work Practices

Personal Protective

Equipment

Special-

Expert Advice

Containment

Engineering Control

General Ventilation

PPE for

Respiratory, Skin &

Eyes protections

CONTROL APPROACH

The risk controls are divided into 4 bands or approaches:

• General ventilationCA 1

• Engineering controlCA 2

• ContainmentCA 3

• SpecialCA 4

35

Unit

OperationSheet title

Solids Liquids

Small Medium Large Small Medium Large

Control Approach 2: Engineering control

Mixing Mixing G201 G215 G216 G201 G217 G217

Sieving Sieving G218 G218

Screening Screening G219

Surface

coating

Spray painting G220 G221

Powder coating G222 G222

Lamination Batch lamination G223 G223

Continuous lamination G224 G224

Dipping Pickling bath G225 G226

Vapour degreasing bath G227 G227

Drying Tray drying oven G228 G228

Continuous drying

labyrinth oven

G229 G229

Pelletising Pelletising G230 G230

Tablet press G231

General or Dilution Ventilation Allows chemical emissions to mix with the work

room air then dilutes to acceptable exposure levels

07/10/201536

Engineering

control

37

Local Exhaust Ventilation (LEV)

Fume CupboardSpray booth

CONTROL APPROACH ADJUSTMENTS

CA is adjusted for a very short total duration of

exposure

For very short exposure duration (less than 15

minutes per day) CA drop by 1 level except if CA is

4 or 1.

CONTROL GUIDANCE SHEET (CGS)

G SERIES

(General)GENERAL TASKS

SPECIFIC TASKS

S SERIES

(Skin)

GENERAL GUIDE

PPE SELECTION

R SERIES

(Respiratory) GENERAL

PRINCIPLE

P Series

(for Pest Control)

Direct Advise

SPECIFIC

TASKS

W Series

(for Soldering)

C Series

(for Cleaning Services)

LP Series

(for Lithography Printing)

CONTROL GUIDANCE SHEET (CGS)

Sample of CGS

3. Use Table 3.3 for

scale of Use

5. Finding The Task- Specific

CGS

2. Get H Code

Table 3.1 & 3.2 to get

Hazard Group

Solid

4. Use table 3.4 on

level of dustiness

Is Direct

Advice

Available?

Liquid

4. Use Table 3.5a & 3.5b

and Figure 2 to decide

volatility

6. Select Relevant CGS

• Table 3.8 Pest Control

• Table 3.9 Soldering

• 3.10 Cleaning Services

• 3.11 Lithography Printing

7. Develop & Implement

Action Plan

Report Writing and Record

Keeping

Yes No

SiRAC

Steps

1. Gather Information &

Identify Chemical

5. Use Table 3.6 for selection

of Control Approach

or

Report Format

Form SA1

Form SA2a

Form SA2b

Form SA3

Simple Assessment FormSA1

Company :

Address :

Telephone : Fax : Email :

Type of industry : Employer/Representative Name

:

Position :

Assessor Name : Assessor Contact No. : Assessor

Email :

Total no. of chemicals at the workplace : No. of chemicals assessed (using simple

assessment) :

Summary of Simple Assessment

Process : Task description CGS Existing

control

**

Further Action

Control

Measure

**

Training

yes (✓)

no (×)

EM*

yes (✓)

no (×)

MS*

yes (✓)

no (×)

*Note: CGS: Control Guidance Sheet, EM: Exposure Monitoring, MS: Medical Surveillance

** Existing Control; Control Measure (Fill in the following code)

1. General Ventilation

2. Local exhaust ventilation

3. Containment

4. Training

5. Safe work procedures

6. PPE (please specify) _____________________________________________________________

7. Others (please specify) _____________________________________________________________

Identify and Gather Information on Chemicals SA2a

Work Area :

Date of Assessment :

Process No. of

Worke

r

Task Name of

Chemicals

R-

phrase

/ H-

code

Quantity

Use

Physical

s form

Temp. (oC) Total

Duration

of

Use/day

(min.)

Existing

control

B.P O.T

Simple Assessment Worksheets

SA2b

Work Area :

Date of Assessment :

No. Task Name of

Chemical

s

Hazard

Group

(A, B, C,

D, S)

(Table

3.1&

Table

3.2)

Scale

of Use

(S, M, L)

(Table

3.3)

Dustiness/Vola

tility

(L, M, H)

(Table

3.4/Table 3.5a

or

Table 3.5b)

Total

Duratio

n of Use

<15min

?

Control

Approach

(CA)

(Table 3.6

or

Table 3.7)

CA

Adjustm

ent

Control

Guidanc

e Sheet

(CGS)

(Table

3.8)

Action Plans

SA3

No. Task Name of

ChemicalsExisting control

Adequacy

of control

Action to be

takenDue Date PIC

I ______________ will be responsible for the improvements as specified in the action plan. I also promise to keep good

records of the assessment and hand it over to my successor if my company ceases to carry on business or hand it over

to the Director General of Occupational Safety and Health if there is no successor.

Signature of employer : Position: Date:

Review Asessment

Review In line with USECHH Regulations requirements

Assessment need to be reviewed under any one of the following condition:

> Significant change in work

> New/improved control measures implemented

> 5 years has elapsed

> Directed by DG, DDG or Director of OSH

kertas 4 intro to sirac

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