DOSH_Draft Manual - Simple Assessment of Chemical Hazardous to Health (CRACKit)

Manual on Simple Assessment of Chemical Hazardous to Health [Oleh: Jawatankuasa Penggubalan Bagi Manual Penaksiran Ringkas Risiko Bahan Kimia Berbahaya Kepada Kesihatan ] JKKP, MOHR [Last Updated 29 Okt 2010]

Manual on Simple Assessment Chemical Hazardous To Health 2009

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CONTENT

PART 1: INTRODUCTION

1.1 Legal Requirement

1.2 Chemical Hazardous to Health

1.3 Detailed Assessment Vs Simple Assessment

1.4 Why Control Chemicals Hazardous To Health?

1.5 Who Can Conduct A Simple Assessment?

PART 2: SCOPE AND APPLICATION

2.1 Chemicals Hazardous To Health Covered By This Kit

2.2 Routes Of Entry

2.2.1 Inhalation

2.2.2 Skin Absorption

PART 3: CONCEPTS

3.1 Hazard Classes and Groups

3.1.1 Pesticide

3.1.2 Other Chemicals

3.1.3 Hazard Group Consideration For Mixtures

3.2 Factors Which Affect Exposure

3.2.1 Scale Of Use 3.2.2 Ability To Become Airborne

3.2.2.1 Solids 3.2.2.2 Liquids

3.2.3 Frequency And Duration Of Exposure 3.3 Control Approaches to Reduce Exposure

3.4 Control Guidance Sheets

3.5 Workforce Involvement


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PART 4: CRACKit STEPS

4.1 Step 1- Gather Information

4.2 Step 2 - Determining Hazard Group

4.3 Step 3 - Determining Dustiness and Volatility

4.4 Step 4 - Deciding the Scale of Use

4.5 Step 5 - Selection of Control Approach

4.6 Step 6 - Finding the Task – Specific Control Guidance Sheet(S)

4.7 Step 7 - Assess Other Chemicals and Tasks

4.8 Step 8 - Develop And Implement Action Plan

4.9 Step 9 - Review Assessment


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PART 1: INTRODUCTION

1.1 Legal Requirement

As stipulated in the Occupational Safety and Health Act 1994 (OSHA), it is one of the primary

duties of an employer to protect their employees from the adverse effects of chemicals. To perform

this duty, an assessment of all chemicals used in the workplace must be carried out in order to identify,

evaluate and control any health risk associated with work activities involving the use of chemicals.

Under Part IV of the Occupational Safety and Health (Use and Standard of Exposure of

Chemicals Hazardous to Health) Regulations 20XX, hereinafter referred to as USECHH Regulations

20XX, the duty to perform an assessment of health risks arising from the use of chemicals hazardous to

health at the place of work is mandatory whereby employers are not permitted to use any chemicals

hazardous to health unless an assessment has been conducted. However, the employer may choose

to conduct a simple assessment instead of the full assessment if he meets the criteria specified under

sub regulation 10(3) of the USECHH Regulations 20XX.

This Chemical Risk Assessment and Control Kit (CRACKit) has been developed to help an

employer to carry out a simple assessment of the health risk arising from the use of chemicals

hazardous to health at the workplace and to meet their duties under USECHH Regulations 20XX.

1.2 Chemical Hazardous to Health

Chemical hazardous to health is defined under the USECHH Regulations 20XX as:

(a) Listed in Schedule I, II or III of the USECHH Regulations 20XX;

(b) Classified in any hazard class specified in Part B of the First Schedule of the Occupational

Safety and Health (Chemical Classification, Labeling and Safety Data Sheet) Regulations 20XX;

(c) A pesticide as defined under the Pesticides Act 1974; and

(d) A scheduled waste listed in the First Schedule to the Environmental Quality (Scheduled

Wastes) Regulations 2005.


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Part B of the First Schedule of the Occupational Safety and Health (Chemical Classification,

Labeling and Safety Data Sheet) Regulations 20XX are those chemical posing hazard to health. These

chemicals are classified into various health hazard classes with hazard statement or H-code in the

H300 series.

This also includes chemical that have been classified under Part B of CPL Regulations with risk

phrases ranging from R20 to R59 (excluding R50 - R59). However those chemical with risk phrases R6x.

under EU Directive 67/548/EEC (Directive on Dangerous Substances) also considered as chemicals

hazardous to health.

1.3 Full Assessment vs Simple Assessment

There are basically two approaches to conduct assessment, any one of which may be applied

depending on the hazard class of the chemical, chemical use situation and the complexity of the work

process. These approaches are: -

a) Full assessment (CHRA); and

b) Simple assessment.

a) Full Assessment

Full assessment should be conducted for each and every workplace where chemicals

hazardous to health are used. It should be conducted by a registered chemical risk assessor appointed

by the employer for each and every workplace where chemicals hazardous to health are used.

Generic assessment is a full assessment done at representative locations which maybe applied

to all other locations in which the work activities are similar, with comparable levels of risk, and similar

control measures.

b) Simple Assessment


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A simple assessment involves a process of grouping workplace risks into control bands

based on combination of hazard and exposure information. A simple assessment may be

conducted, instead of the full assessment, if all chemicals hazardous to health used in a

particular work unit that meet criteria of subregulation 10(3) of USECHH Regulations 20XX is:

i. Listed in the chemical register; and

ii. Not classified as carcinogenicity category 1; mutagenicity category 1 or 2; or

respiratory sensitization category 1.

For purpose of conducting simple assessment the required information are R-phrases or

Hazard classification (GHS), physical form, boiling point and operating temperature of chemicals

(where applicable), quantity used and total duration of exposure to the chemicals.

The flow chart for assessment of risk to health is shown in the Figure 1.0 below and the

procedure to conduct a simple assessment is described in the CRACKit manual.

For purpose of conducting simple assessment the required information are R-phrases or

Hazard classification (GHS), physical form, boiling point and operating temperature of chemicals

(where applicable), quantity used and total duration of exposure to the chemicals.

The flow chart for assessment of risk to health is shown in the Figure 1.0 below.


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Assessment of Risk to Health

Identify chemical used in particular work area/process and its hazard

Meet criteria in subregulation 10(3) & required information

available?

Conduct Chemical Health Risk Assessment

(CHRA)

Develop action plan

Implement action plan

Conduct simple Assessment

NO

YES

Control approach 1,2

or 3?

YES

NO Seek specialist advice


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1.3 Why Control Chemicals Hazardous to Health?

Chemicals hazardous to health used in the workplace can harm employees’ health if exposures aren’t properly controlled. If an employer fails to prevent exposure or to properly control any exposure that does occur, there are number of consequences:

(a) It adds to the unnecessary and preventable burden of ill health (see below); (b) Business performance can be damaged through lost time for sick leave and through

product waste; and (c) There can be civil claims for damages; and (d) It is an offence under USECHH Regulations 20xx.

Simple assessment can help an employer to control exposure and meet his legal duties. It addresses some of basic requirements of USECHH Regulations 20xx for some chemical hazardous to health in a simple and practical way. It also flags up other things that an employer need to tackle.

It may be helpful to a safety and health professional, a safety and health officer, a safety and health committee member, a chemical supplier or a trade association.

Ill health caused by chemical hazardous to health at work

There are an estimated 18,000 occupational disease every year from 1999 to 2006, mostly related to exposure to chemical hazardous to health. These cases including lung disease, pesticides poisoning, cancer and mesothelioma and skin disease.

Source: Ministry of Health Malaysia

0 1 2 3 4 5 6

Category 1

Category 2

Category 3

Category 4

Series 3

Series 2

Series 1


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1.4 Who Can Conduct A Simple Assessment?

According to subregulation 13(2) of the USECHH Regulations 20xx, an employer may appoint a person to carry out a simple assessment. This person should have knowledge on:

(a) how to interpret Safety Data Sheets (SDS); (b) process; (c) basic principle of Hazard Identification Risk Assessment and Risk Control (HIRARC); and (d) basic requirement of OSHA, USECHH and relevant guidelines.


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PART 2: SCOPE AND APPLICATION

2.1 Chemicals Hazardous to Health Covered by CRACKit

USECHH Regulations 20xx applies to a wide range of chemical hazardous to health. This kit applies to chemicals hazardous to health that are supplied for use at work. They are referred to here as chemicals. In practice, they are solids or liquids that an employer buys in for use, whether to run a woodworking shop, a print shop, motor vehicle repairs, an engineering workshop or a chemical firm. Typical examples include powder coatings, degreasing solvents and cleaning products, varnishes, ink and paints, and chemicals for making into other products.

Chemicals will generally be covered by the Occupational Safety and Health (Chemical Classification, Labeling and Safety Data Sheet) Regulations 20XX or CLASS Regulations, and should come with a warning label and a safety data sheet.

The kit does not generally apply to the following types of chemicals, though they are covered by USECHH Regulations 20xx:

(a) chemical classified as Carcinogenicity (Category 1), Mutagenicity (Category 1 or 2) or Respiratory Sensitization;

(b) process generated dusts and fumes (e.g. wood dusts, solder and welding fume) as these are not classified and are not listed in the chemical register, although many of the solutions described in CRACKit can successfully control these problems;

(c) organic dust, e.g. grain dust, cotton dust and paddy husk dust; and (d) gases, e.g. hydrogen sulphide, ammonia, hydrogen, etc. (e) scheduled waste is listed in the First Schedule to the Environmental Quality

(Scheduled Wastes) Regulations 2005.

2.2 Routes Of Entry

2.2.1 Inhalation

In industry, inhalation is the most significant route of entry. Inhalation involves breathing in of airborne dusts and fibers, gases, vapours, mists or fumes. As we breathe in, the airborne chemicals will enter the upper respiratory tract (nose, mouth and throat), the air passage ways (trachea, bronchi, bronchioles, and respiratory bronchioles) and some of the chemicals will penetrate into the gas exchange area (alveoli). Very soluble chemicals pass through the lungs in minutes. Less soluble chemicals are trapped in the alveolar region, exhaled out, swallowed or expectorated. Very fine dusts that are trapped in the alveolar region can cause lung disease such as silicosis, asbestosis and lung cancer.


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2.2.2 Skin Absorption

Absorption of chemicals through the skin is another important route of entry especially for chemicals that are lipid soluble such as pesticides. These chemical penetrated the intact skin and get into the blood stream. Other chemicals may enter the body through cuts or damaged skin. Different parts of the body have different skin structure and thickness and hence different resistance to chemical penetration. Some chemicals can cause damage to skin or skin disease (e.g. dermatitis, acne and eczema). Others pass through the blood stream and distributed and deposited in various organs or system causing various illnesses and disease such as leukemia, hepatitis and kidney failure.

Since inhalation and skin absorption are the two most significant routes of entry of chemicals into the human body, they will be covered in this manual. Entry of chemicals through ingestion or through injection will not be covered by this manual.


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PART 3: CONCEPTS

There are two main factors that affect whether the employees’ health is likely to be harmed, and these can help to identify adequate controls. The factors are:

(a) The type of damage the chemical causes and the amount needed to cause it; (b) How much of the chemical is likely to get into the air around employees and be

breathed in, or come into contact with their skin or eyes. This in turn depends in the amount being used, its dustiness or volatility and total duration of exposure.

CRACKit uses these factors to identify adequate controls.

3.1 Hazard Classes And Groups

Different chemicals can harm employees in different ways, and some are more poisonous or can cause more harm than others. For example, some chemicals will only cause minor irritation to the eyes or throat, whilst other chemicals can make it more difficult to breathe or can kill. Some effects will be obvious straight away, whilst other effects will take many years to appear. It is important that all these effects are controlled, but chemicals which can cause more serious effects will need a greater degree of control than less harmful chemicals.

3.1.1 Pesticide

For pesticides, control guidance sheet can be selected directly from Table 3.8 without going through the processes of determining the hazard group, ability to become airborne and scale of use.

3.1.2 Other chemicals

Chemicals are placed into four different groups, A to D to indicate the degree of hazard by inhalation. Group A is the least hazardous and group D is the most hazardous. An additional group, group S indicate if it is hazardous to get the chemicals on the skin or in the eyes. Table 3.1 and 3.2 presents the hazard group A-D and S based on the risk phrase (R-phrases) under CPL Regulations 1997 or EU Directive 67/548/EEC (Directive on Dangerous Substances) or hazard classification under CLASS Regulations 20xx. Refer to Appendix 1 for List of risk phrases (R-phrases) and hazard statements (H-code).


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One important way to reduce risk is by using a less hazardous chemical. Consider substituting the chemical used to a chemical in a less hazardous group.

Table 3.1: Hazard Group A - D (chemicals causing harm when airborne)

Hazard Group R-phrases H- code Group A R36, R36/38, R38,

…………………………………………. R65, R66, R67 …………………………………………. All R-phrases not otherwise listed (exclude R42, R45, R46, R49, R68)

H303, H304, H305, H313, H315, H316, H318, H319, H320, H333, H336 and all H-numbers not otherwise listed (exclude H334,H340,H341,H350)

Group B R20, R20/21, R20/21/22, R20/22, R21, R21/22, R22, ………………………………………….. R68/20, R68/21, R68/22, R68/20/21, R68/20/22, R68/21/22, R68/20/21/22,

H302, H312, H332, H371

Group C R23, R23/24, R23/24/25, R23/25, R24, R24/25, R25, …………………………………………...R34, R35, R37, …………………………………………...R39/23, R39/24, R39/25, R39/23/24, R39/23/25, R39/24/25, R39/23/24/25, ………………………………………….. R41, R43, …………………………………………. R48/20, R48/20/21, R48/20/21/22, R48/20/22, R48/21, R48/21/22, R48/22, …………………………………………. R68/23, R68/24, R68/25, R68/23/24, R68/23/25, R68/24/25, R68/23/24/25

H301, H311, H314, H317, H318, H331, H335, H370, H373

Group D R26, R26/27, R26/27/28, R26/28, R27, R27/28, R28, …………………………………………. Carc cat 3 R40 or R40 (3), …………………………………………. R48/23, R48/23/24, R48/23/24/25, R48/23/25, R48/24, R48/24/25, R48/25, …………………………………………. R39/26/27/28, R39/26, R39/27, R39/28, R39/26/27, R39/26/28, R39/27/28, R60, R61, R62, R63, R64

H300, H310, H330, H351, H360, H361, H362, H372


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Table 3.2: Hazard group S (chemicals causing harm in contact with skin and eyes)

R-phrases H- code

R21, R20/21, R20/21/22, R21/22, ……………………………………….. R24, R23/24, R23/24/25, R24/25, ……………………………………….. R27, R27/28, R26/27/28, R26/27, ………………………………………. R34, R35, ………………………………………. R36, R36/37, R36/38, R36/37/38, R38, R37/38, ………………………………………. R39/21, R39/24, R39/27, ………………………………………. R40/21, R41, R43, R42/43, ………………………………………. R48/21, R48/20/21, R48/40/21/22, R48/21/22, R48/24, R48/23/24, R48/23/24/25, R48/23/25, R48/27, ……………………………………….. R66, R68/21, R68/24, R68/27 (any chemicals with “sk” notation as prescribed in Schedule I of USECHH Regulations 201x)

H310, H311, H312, H313, H314, H317, H318, H319

3.1.3 Hazard Group Consideration for Mixtures If the task involved using a mixture made in the workplace, the hazard group can be determined based on the following considerations:

(a) If any component is in Hazard Group ‘S’, then the mixture is Hazard Group S. (b) If any component is in Hazard Group ‘D’ ≥ 0.05% then the mixture is Hazard Group D. (c) If any component is in Hazard Group ‘C’ ≥ 0.5% then the mixture is Hazard Group C. (d) If any component has a classification ‘R43’ then see subsidiary R43 rules (refer 4.5.3). (e) If any component is in Hazard Group ‘B’ ≥ 10% then the mixture is Hazard Group B. (f) Otherwise the mixture is Hazard Group A.


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3.2 Factors Which Affect Exposure

3.2.1 Scale of use

The amount of chemicals used will determine the way chemical is handled and how much the employees are exposed to the chemicals. The amount of chemical use per operation or batch (or a day for a continuous process) can be described as small, medium or large. Use the information in the Table 3.3 to see if the use is small, medium or large.

Table 3.3: Quantity of chemical in use.

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

3.2.2 Ability to become airborne

The physical form of a chemical affects how likely it is to get into the air. For solids, the physical property is its dustiness, and for liquids, it is volatility. The dustier or more volatile the chemicals, the more it is likely to become airborne. It may be possible to reduce the amount of chemical getting into the air by buying and using the chemical in a different form, for example, by:

(a) replacing fine powders with pellets or less dusty granules; (b) Using liquids at a lower temperature

3.2.2.1 Solids

The dustiness of a solid is classified as low, medium or high. Table 3.4 describes the level of dustiness of chemicals being used.

Table 3.4: Level of dustiness

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.


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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.

3.2.2.2 Liquids

Volatility describes a liquid’s ability to turn into a vapour, and therefore to get into the air.

Some liquids, highly volatile ones, do this more readily than others, and so create the potential for

greater exposures than chemicals with lower volatility.

The degree of liquid volatility can be determined based on either the vapour pressure or the boiling point and process temperature. The information on vapour pressure and boiling point is normally found in the safety data sheet (SDS) for that chemical.

To determine the degree of volatility based on vapour pressure, refer to Table 3.5a and

Table 3.5b.

Table 3.5a: Degree of Volatility based on vapour pressures

Volatility band Vapour pressure Low Less than 500 Pa Medium 500 to 25 000 Pa

High More than 25 000 Pa

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

For tasks carried out at room temperature 25oC, the volatility of a liquid is classified as low, medium or high as specified in Table 3.5b.

Degree Descriptions Example

High

Boiling point below 50o

C Butadiene

Medium

Boiling point between 50 and 150o

C Acetaldehyde, acetone, chloroform, diethylamine

Low

Boiling point above 150o

C Ethylene glycol, carbon tetrachloride, n-butyl acetate


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For task carried out above room temperature, the chemical’s boiling point and process temperature can be used to decide volatility from Graph in Figure 3.1. Read across from the boiling point, and up from the process temperature. The section in which two lines meet on the graph will tell the volatility. If it falls on a dividing line, the higher volatility is selected. If the task involves a range of process temperature, use the highest value.

Figure 3.1: Graph to select volatility of liquid

3.2.3 Frequency and duration of exposure

A third factor, duration of exposure, influences exposure potential. This assessment contains a filter for activity with a total time below 15 minutes per day. A more detail explanation is given in step 5.


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3.3 Control Approaches To Reduce Exposure

CRACKit recommends four groups of controls, called control approaches. The four approaches are:

Note: • CGS means Control Guidance Sheets • Please refer to Appendix 2 for details on general ventilation, engineering control and containment.

Each control approach covers a range of actions that work together to reduce exposure:

(a) Good plant and equipment design; (b) Regular housekeeping and cleaning; (c) Regular maintenance, examination and testing of equipment; (d) Employee training and supervision; and

1 – General Ventilation (see CGS 100)

A good standard of general ventilation and good working practices.

4 – Special (see CGS 400)

Specialist advice is needed in selecting control measures and to seek further help.

2 – Engineering Control (see CGS 200)

Typically local exhaust ventilation ranging from a single point extract close to the source of hazards, to a ventilated partial enclosure. It includes other engineering methods of control, e.g. cooling coils for vapours, but not complete containment.

3 – Containment (see CGS 300)

The hazard is contained or enclose, but small-scale breaches of containment may be acceptable. Often used where a substance is very hazardous or a lot of it is likely to get into the air.

Least reduction in exposure

.

.

.

.

.

.

.

Greatest reduction in

exposure

Special help needed


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(e) In some cases, using personal protective equipment (PPE).

Table 3.63.6 can be used to identify the control approaches using the information on the hazard group, scale of use and ability to become airborne.

Table 3.6: Control Approach Selection

Amount used Low

dustiness or volatility

Medium volatility

Medium dustiness

High dustiness or

volatility

Hazard group A

Small 1 1 1 1

Medium 1 1 1 2

Large 1 1 2 2

Hazard group B

Small 1 1 1 1

Medium 1 2 2 2

Large 1 2 3 3

Hazard group C

Small 1 2 1 2

Medium 2 3 3 3

Large 2 4 4 4

Hazard group D

Small 2 3 2 3

Medium 3 4 4 4

Large 3 4 4 4

Formatted Table


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3.3.1 Adjustment for frequency and duration of use (time-weighting)

A threshold of 15 minutes’ use per day is applied to adjust the control approach. A total duration of exposure of less than 15 minutes, will result in a drop of one level in the Control Approach. Example from control approach 3 (containment) drops to 2 (engineering control), or from 2 to 1 (general ventilation). The superficial reason for this assessment is task-based and precautionary. This adjustment does not apply for control approach 4.

3.3.2 Subsidiary R43 rules for mixtures Where any component of the mixture has R43 ≥ 0.1% but < 0.5%, grouping the mixture as Hazard Group C results in an over-precautionary Control Approach. The volatility or dustiness should relate to the major component of the mixture (Hazard Group A or B). The following matrix in Table 3.7 replaces Table 3.6 for chemicals in Hazard Groups A and B that contain 0.1% to less than 0.5% of an R43 component, provided that no other mixture component giving Hazard Group C or D.

Table 3.7: R43 mixture rules

Note: CA1, CA2 and CA3 are Control Approaches.

The option for stipulating water as a mixture ingredient is not implemented (water, by default, is Hazard Group A). However for mixtures of solid in water, the volatility may be assumed as ‘low’ rather than medium (e.g. boiling point >150°C, not 100°C).

3.4 Control Guidance Sheets

The control guidance sheets are arranged according to the control approach they cover. There are:

(a) General sheets on how to use each control approach; (b) More detailed sheets that give examples of good practice controls for common tasks

such as mixing, weighing and sieving; and

Low dustiness/ volatility

Medium volatility

Medium dustiness

High dustiness/ volatility

Amount Substance with >= 0.1% to <0.5% of a component with R43 and no

other mixture component giving Hazard Group C or D Small

CA1 CA2 CA1 CA2

Medium

CA1 CA2 CA2 CA2

Large CA2

CA3 CA3 CA3


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(c) Additional sheets on avoiding skin and eye contact with chemicals, and on selecting and using personal protective equipment.

The control guidance sheet or sheets is selected based on the task or tasks description. If the task does not match with the task description in Table 3.8 and Table 3.9, the general principle control guidance sheet is selected for the relevant control approach.

Table 3.8: List of control guidance sheet Control Approach 1

Task description Solid Liquid Small Medium Large Small Medium Large

General ventilation 100 100 100 100 100 100

General storage 101 101 101 101 101 101

Open bulk storage 102 Removing waste from a dust extraction unit

103 103 103

Control Approach 2 Local exhaust ventilation 200 200 200 200 200 200 Fume cupboard 201 201 Laminar flow booth 202 202 Ventilated workbench 203 203 Removing waste from a dust extraction unit 204 204 204

Conveyor transfer 205 205

Sack filling 206 207

Sack emptying 208

Filling kegs 209 Charging reactors and mixers from a sack or keg

210 210

IBC filling and emptying 211

Drum filling 212

Drum emptying using a drum pump 213

Weighing 201 214 201

Mixing 201 215 216 201 217 217

Sieving 218 218

Screening 219

Spray painting 220 221

Powder coating 222 222

Batch lamination 223 223

Continuous lamination 224 224


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Pickling bath 225 226

Vapour degreasing bath 227 227

Tray drying oven 228 228

Continuous drying labyrinth oven 229 229

Pelletising 230 230 Tablet press 231

Control Approach 3

Containment 300 300 300 300 300 300

Glove box 301 301 Removing waste from a dust extraction unit

204 204 302

Transferring solids 303 303

Sack emptying 304

Drum filling 305 305

Drum emptying 306

IBC filling and emptying 307 308

Tanker filling and emptying 309 310

Filling kegs 311 213

Transferring liquid by pump 312 312

Packet filling 301 313 313

Bottle filling 301 314 314

Weighing 301 315 315 301 316 316

Mixing 301 317 317 301 318 318 Robotised spray booth 319 319 Automated powder bath 320 320

Vapour degreasing bath 321 321 321

Spray dying 322 322 322 322

Control Approach 4 General principles 400 400 400 400 400 400

Chemical causing harm via skin contact General advice S100 S100 S100 S100 S100 S100 Selection of personal protective equipment

S101 S101 S101 S101 S101 S101


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Table 3.9: List of control guidance sheet for pesticide

Control Guidance Sheets for Pesticides Use

Task Description P General principle - handling, storing, cleaning, disposing of pesticides P100

Preparation of pesticides (weighing and diluting of chemical concentrates) P101

Ready-for-use insecticide sprays and dust P102

Eradicating vermin (e.g. rats) using poison baits P103

Fogging and misting using space sprayers P104 3.5 Workforce Involvement

Involvement of employees or safety and health committee member in the risk assessment is important. They are in a good position to know what happens in practice, and they are the ones who will need to use any controls introduced. This could be part of the training and information the employer must provide under USECHH Regulations 20xx.


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PART 4: CRACKit STEPS

The flow chart to carry out for chemical hazardous to health are as shown in Figure 4.1 below.

Solid ‐ Use Table 3.4 on level of dustiness

Use Table 3.6 for selection of control approach

Use Table 3.8 for selection of task specific control guidance sheet

Identify chemical

Liquid ‐ Use Table 3.5a & 3.5b and Figure 3.1 to decide volatility

Use Table 3.9 to select control guidance sheets (P100, P101, P102,

P103, P104)

Use Table 3.3 for scale of use

Gather Information

Use Table 3.1 and Table 3.2 to get Hazard Group

Get R‐Phases or GHS hazard classification

Review assessment

Develop and implement action plan

Is it pesticides?

NoYes


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Figure 4.1: Flow chart to carry out assessment

4.1 Step 1- Gather Information

4.1.1 The assessment begins with the gathering of the following:

(a) Chemical register; (b) Safety Data Sheet (SDS); (c) Label; (d) Information about the task where chemical is used (e) Existing control measures such as general ventilation, local exhaust ventilation and etc; (f) Other information such as layout plan, process flow, operating temperature of process

and number of workers exposed to chemical.

Note: 1. The SDS should contain the following information;

a) Risk phrases or hazard statements (usually given under Sections: Hazard Identification or Regulatory Information);

b) The boiling point or vapour pressures for liquid. If the above information is not available contact the supplier.

2. If the safety data sheet is not available or outdated, get the current safety data sheet from the supplier. 4.1.2 Identify a work area/process using chemicals. 4.1.3 Select a task to assess within the work area/process. Note: It may be helpful to categorise the task as described by the specific control guidance sheets such as mixing, weighing, transfer, storage, separation, surface coating, lamination, dipping, drying, pelletising and etc. 4.1.4 Identify the chemical used. 4.1.5 Record the following in the assessment form (SA 2) provided in the manual. Use a separate form for each chemical assessed the:

(a) date of assessment; (b) work area/process, (c) task involved; and (d) name of the chemical assessed.

4.1.6 If the chemical used is pesticides go to Step 6.


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4.2 Step 2 - Determining Hazard Group

4.2.1 Check the R-phrases or hazard statement/H-Code from safety data sheet against those in Table

3.1 to decide which hazard group (s) the chemical belongs to. R-phrases or hazard statement/H-Code are normally found in three sections of the safety data sheet – Composition (which gives information on the separate ingredients), Hazard Identification and Regulatory Information (which gives information on the final product).

4.2.2 Decide on the group from hazard group A to D, and be careful to match the risk phrases or

hazard statement/H-Code exactly. Some risk phrases can appear alone or in combination with others. This is indicated by a / between the numbers, e.g. Harmful in contact with skin and if swallowed (R21/22) means that both harmful in contact with skin (R21) and harmful if swallowed (R22) apply to the chemical. In addition, check group S (refer Table 3.2), to see if contact with skin and eyes is also a hazard. If the safety data sheet does not contain risk phrases or hazard statement/H-Code from Table 3.1 the chemical belongs to group A.

4.2.3 If there are a number of risk phrases on the safety data sheet which appear in different hazard

groups from A to D, always select the higher group. For example, for a chemical with R21/R22 (group B) and R60 (group D), select group D.

4.2.4 Some R-phrases start with the phrase Carc cat, Muta cat or Repr cat. It is important to note that

a chemical marked Carc cat 3 R40 belongs in group D, and one marked Muta cat 3 R40 belongs in group E.

If the risk phrases or hazard statement/H-Code on the safety data sheet and label could not be found, or the right hazard group could not be determined, contact the chemical supplier for information.

4.3 Step 3 - Deciding The Scale Of Use

Decide the amount of chemical used per operation or batch by using Table 3.3 and record on the form. If in doubt about the amount, opt for the larger quantity.

4.4 Step 4 - Determining Dustiness And Volatility

4.4.1 Solid form

For solid, use Table 3.4 to decide on the level of dustiness. If in doubt about the level of dustiness, opt for the dustier description.


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4.4.2 Liquid form

To work out the volatility of a liquid, its vapour pressure or boiling point needs to be found on the safety data sheet (SDS). This can normally be found in physical properties section of the (SDS).

Where information on the substance’s vapour pressure or boiling point is given in a range of value, use the lowest value.

If a preparation is made up of two or more substances with different boiling points, use the lowest value.

For tasks carried out at room temperature, compare the boiling point against the ranges in Table 3.5 to decide on the degree of volatility and record in check sheet.

4.4.3 Other forms

For paste, gel, slurry and etc their volatility should be considered if data on boiling point or vapour pressure is available.

4.5 Step 5 - Selection Of Control Approach

4.5.1 Table 3.6 can be used to identify the control approaches based on the outcome from the previous steps. The control approach is found by first going to the hazard group to which the chemical has been allocated as in Step 2. Read across from the scale of use (Step 4) to the appropriate volatility/dustiness column as in Step 3. The number in the box identifies the control approach. Tick the appropriate control approach box on the assessment form SA 2 .

4.5.2 If duration of exposure is less than 15 minutes, it will result in a drop of one level in the Control Approach. This adjustment does not apply for control approach 4. Tick the adjusted control approach in the SA 2 form.

4.6 Step 6 - Finding The Task – Specific Control Guidance Sheet(S)

4.6.1 From the control approaches decided in Step 5, use Table 3.8 to select specific control

guidance sheet(s) that best describe the task(s) carried out. To select the specific control

guidance sheet find the number(s) of the guidance sheets using the following information

from assessment form:

(a) The task;

(b) Whether the substance is a solid or a liquid; and

(c) How much is being used in the task or batch.


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4.6.2 Write the control guidance sheet number(s) on assessment form and find the relevant sheet(s).

4.6.3 If task carried out do not meet the task description, select general control guidance sheet for the control approach selected.

4.6.4 If hazard group S is selected in step 2, extra action is needed to protect employees’ skin and eyes. This means that control guidance sheets, S100 and S101 should be selected, which give advice on protecting skin and eyes, and on selecting and using personal protective equipment (PPE).

4.6.5 For pesticides use Table 3.9 to select appropriate control guidance sheet according to task description.

4.7 Step 7 - Assess Other Chemicals and Tasks

4.7.1 Repeat the assessment for other chemical within the same task using a new form SA 2 for each chemical:

(a) Determine CGS for every chemical;

(b) Then select CGS with the greatest reduction in exposure (refer paragraph 3.3) by taking into consideration its suitability and practicality. Summarise the task using the selected CGS in form SA 1;and

(c) Determine the necessity to conduct exposure monitoring (EM) and/or medical surveillance (MS) by referring to paragraph 4.8.7.

4.7.2 Repeat assessment for another task within the same work area/process.

4.7.3 Repeat assessment for other work area/process.

4.7.4 Develop action plan after completion all assessment.

4.8 Step 8 - Develop And Implement Action Plan

4.8.1 Compare advice given in the control guidance sheet(s) with the current practices including existing control measures in place, procedures, etc.

4.8.2 Look at the range of chemicals used and tasks performed, and decide how best to implement action across the board by taking into consideration suitability and practicality of the control approach selected. If in doubt, seek specialist advice. The advice may come from an expert such as a qualified occupational hygienist, chemical risk assessor and professional engineer involved in the design and installation of engineering control.


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Note:

“Suitability” means it is suitable for protecting the employees, taking into consideration the physical form and toxicity of the chemical, the nature of work, the routes of entry of the chemical and not prejudice to the health of the employees

“Practicality” means practicable having regard to- (a) the severity of the hazard or risk in question; (b) the state of knowledge about the hazard or risk and any way of removing or mitigating the hazard or risk; (c) the availability and suitability of ways to remove or mitigate the hazard or risk; and (d) the cost of removing or mitigating the hazard or risk;

4.8.3 Consider all aspects of the advice on the control guidance sheets as all the aspects work together to provide adequate control. For example a local exhaust ventilation may be the right control installed but it may not be effective in controlling exposure because it is not used, maintained or tested.

4.8.4 If control approach 4 has been selected, seek further guidance or specialist advice on what to do. This is critical because there could be very serious health effects if exposure isn’t properly controlled.

4.8.5 If the S100 and S101 guidance sheets on protecting skin and eyes, and on selecting personal protective equipment have been chosen, link the advice to the control approach selected. These are not a replacement for but in addition to control approaches 1 to 4.

4.8.6 Take account of any safety or environment hazards (refer to hazard statement and advice on the safety data sheet), which may affect the required controls and their implementation.

4.8.7 Consider other actions required to fully comply with USECHH. For example:

(a) Are there other chemical hazardous to health in the workplace covered by USECHH, but not included in this manual, which need assessing and control measures (see Part 2.1)?

(b) The necessity to conduct exposure monitoring:

i. if there could be serious risks to health if control measures failed, deteriorated or not working properly; or

ii. exposure limits might be exceeded. to check for adequacy of control measures. The chemical hazardous to health listed under Schedule I of USECHH Regulations 20xx has been assigned with Permissible Exposure Limits (PEL) to help define adequate control.

(c) The necessity to carry out medical surveillance if:

i. the results of exposure monitoring exceed PEL; or


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ii. the chemical is assigned with ‘sk’ notation in Schedule I and the task is performed with a likelihood of skin contact or absorption; and

iii. the employee is exposed to chemicals listed in Schedule II.

4.8.8 The measures, procedures, and equipment necessary to control any accidental emission of chemical hazardous to health as a result of leakage, spillage, or process or equipment failure.

4.8.9 Determine the appropriate control measures based on the overall assessment and above considerations and develop an action plan. Action plan should include action item, due date, action party and progress status.

4.8.10 Implement the control measures in consultation with employees, and check the effectiveness of the control measures. Take any other identified action in 4.8.7 to fully comply with USECHH Regulations.

4.9 Step 9 - Review Assessment

According to Regulation 12 of USECHH, the employer shall review the assessment if:

(a) there has been a significant change in the work that could affect the outcome of the assessment; or

(b) new or improved control measures are implemented; or

(c) more than five years have elapsed since the last assessment; or

(d) directed by the Director General, Deputy Director General or the Director of Occupational Safety and Health.

DOSH_Draft Manual - Simple Assessment of Chemical Hazardous to Health (CRACKit)

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Transcript of DOSH_Draft Manual - Simple Assessment of Chemical Hazardous to Health (CRACKit)