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.

10

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.

11

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.

12

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.

13

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

14

Where to get help For assistance and advice contact WorkCover by:

Phone: 13 10 50

Email: contact@workcover.nsw.gov.au

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

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