Chemical safety assessment tool

Transcription

1 Checklist Chemical safety assessment tool This assessment tool provides general guidance to duty holders on developing an action plan to manage chemical safety. June 2017 Background Unsafe use, storage and handling of hazardous chemicals can affect people s health and safety and damage property and the environment. The chemicals that can harm health are known as hazardous substances while those that can have immediate effects (eg poisoning and fire) are dangerous goods (DG). Hazardous substances are regulated by the Health and Safety Regulations 2017 (OHS Regulations) while DG are regulated by Dangerous Goods (Storage and Handling) Regulations 2012 (DG S&H Regulations). Many chemicals are both hazardous substances and DG and the term hazardous chemicals in this document refers to both. Victorian laws relating to the use, storage and handling of hazardous chemicals require the duty holder to take measures to prevent injuries or exposure. This involves a systematic approach to managing chemical safety. About this tool This assessment tool is aimed at sites using or storing significant quantities of chemicals. It will help duty holders who operate these sites to develop an action plan to improve chemical safety. Workplace environments change so it is recommended that employers use this tool regularly. How regularly will depend on the size and complexity of your organisation. How to use this tool This tool has three main sections: Section 1 Hazard identification and risk assessment This section provides general guidance to duty holders on: a register listing chemicals on site and the current Safety Data Sheet (SDS) from the manufacturer, importer or supplier of the product/s consulting with and providing training and instruction to workers, contractors and health and safety representatives (HSRs) undertaking hazard identification and risk assessments. Section 2 Risk controls This section is about actions to control risks related to the use, storage and handling of hazardous chemicals to protect workers and members of the public. Section 3 Emergency planning The final section relates to the site s preparedness for incidents and emergencies. The quantity of products stored and handled at the site will determine the placarding, manifest, emergency planning and fire protection requirements. Before developing and implementing an action plan, employers need to consult with workers and their HSR (see overleaf). WSV1002/05/06.17

2 Chemical safety assessment tool CONSULTATION 1. Have workers been consulted about chemical risk management? 2. Is there evidence that consultation has occurred? Consultation with workers, any HSR, and other affected parties such as contractors, needs to cover the entire chemical safety system. This involves induction, training, providing information, hazard identification, risk assessment, selection and implementation of risk controls, ensuring controls are working and assessing if any proposed changes to plant, processes or systems of work are likely to increase risk. Duty holders need to assign responsibility and establish an agreed consultation process which could be informal or formal depending on the type and size of the workplace. For more information, refer to Consultation on health and safety. A handbook for workplaces Evidence could include minutes of meetings. Other evidence could be records of OHS committees, toolbox talks, safety meetings and information displayed on notice boards and provided during training. SECTION 1 HAZARD IDENTIFICATION AND RISK ASSESSMENT 1.1 INFORMATION SOURCES 1. Is a register kept and maintained for all hazardous chemicals in the workplace and is it accessible to workers? A register is a list of product names of all hazardous chemicals in the workplace and a copy of the current SDS. It is not the same as the DG manifest (see section 3.2). Arrangements are needed to ensure a current copy of the manufacturer s/importer s SDS is obtained on or before the first time a chemical is supplied to the site. The SDS must be checked at least every five years to ensure it is current. Suppliers, on request, must provide a copy of the manufacturer s/importer s SDS that is up-to-date and no more than five years old. Responsibility should be allocated to a person/s for preparing and maintaining the register. See Appendix 1 for an example of a tool to help manage a register. 2

3 1.1 INFORMATION SOURCES 2. Are chemicals labelled with the manufacturer s/ importing supplier s label? 3. Is there a procedure to make sure new chemicals are added to the register and old ones no longer used removed? Employers must ensure hazardous substance containers are labelled. Labels contain important directions on use and storage as well as safety information. 1 All people who organise the purchase of chemicals need to know and follow this procedure. SECTION 1.2 HAZARD IDENTIFICATION 1. Has hazard identification been performed for products listed in the site register? 2. Did hazard identification cover physical properties as well as the processes, systems of work, physical areas and type of incidents associated with the use, storage and handling of the hazardous chemicals at the site? For more detail on hazard identification and prioritisation, refer to the Compliance Code for Hazardous Substances, A step by step guide for managing chemicals in the workplace and the Code of Practice for Storage and Handling of Dangerous Goods. Information is available from the SDS and industry/product knowledge. Examples of industry/product knowledge include chemical reactivity and exposure standards, worker experience and incidents for similar materials or processes at other sites. Hazardous chemicals may also be produced or generated from non- hazardous materials and may include welding fumes, wood dust, silica from grinding or cutting some materials as well as lead from the sanding of lead-based paints. Revise hazard identification to include the above information. 3

4 SECTION 1.3 RISK ASSESSMENT 1. Have risk assessments been conducted for the hazardous chemicals used and stored? 2. Does the risk assessment cover chemical and physical properties, processes, systems of work, and any incidents associated with the hazardous chemicals at the site. 3. Are risk assessments recorded/reviewed/ revised? For guidance on risk assessments, refer to the Compliance Code for Hazardous Substances and Code of Practice for Storage and Handling of Dangerous Goods. When doing a risk assessment also consider: first aid requirements requirements for exposure monitoring (both air and biological/health surveillance) identification of ignition sources in any hazardous zones bunding, other spill containment requirements, hazardous zones and clean up materials. Revise the risk assessment to include the above information. Information is available from SDS and industry product knowledge. See Appendix 2 for a risk assessment example. Set up a system to meet these needs. SECTION 2 RISK CONTROL 1. Have risk control measures been implemented according to the hierarchy of controls? The hierarchy of controls set out in the OHS Regulations is a list of best to worst solution types that need to be applied as required. They are: elimination; substitution; isolation; engineering controls; administrative controls and personal protective equipment (PPE). In addition to the hierarchy of controls there are also specific control measures set out in DG laws eg spill containment, fire fighting facilities, placarding. For guidance on hazardous substances risk control, refer to the Compliance Code for Hazardous Substances. For guidance on DG risk control measures, refer to the Code of Practice for Storage and Handling of Dangerous Goods. 4

5 SECTION 2 RISK CONTROL 2. If any product or process changes have been made, have the specified control measures also been reviewed/ revised to ensure that risks continue to be eliminated or reduced, so far as is reasonably practicable? 4. Is there a heavy reliance on PPE or administrative controls? Review and maintain controls to ensure they remain effective. PPE and administrative controls require greater supervision, maintenance and training etc than other control measures. If there is a heavy reliance on these types of controls, check to ensure the measures are working and effective. Also consider if the hierarchy of controls has been implemented properly. For guidance on administrative controls, refer to A step by step guide for managing chemicals in the workplace (Appendix 4, PPE and administrative controls). Supplementary questions for larger sites 1 1. Is there an up-to-date, comprehensive list of safety-critical controls eg high level alarms and shut-off valves? 2. Is this list reviewed regularly? Controls should be listed in order of importance. Consider how often the list should be reviewed. 3. Is there a safe operating procedure to cover all reasonably foreseeable operating conditions, including commissioning, operation, inspection, testing, maintenance and decommissioning of plant? 1 Major hazard facilities or sites that require notification Procedure should be documented and cross-referenced with the safety-critical control list. 5

6 Supplementary questions for larger sites 1 4. Are the selected controls effective for the level of risk? 5. Is there a system for ensuring changes/ modifications are adequately conceived, designed, installed and tested? 6. Are documented policies and procedures included in such a system? 7. Is there a risk assessment of any changes/ modifications included? 8. Are changes in resources managed in relation to safety issues? 9. Has an appropriate (preventative) maintenance scheme been established for all safety-critical installations and systems to prevent incidents or limit their consequences? Upgrade controls or implement an ongoing warning system. Examples of warning systems are: low/high level alarms in the case of malfunction point-source or stack monitoring low air flow alarms in critical ventilation systems. For information about assessing management of change processes, refer to the major hazard facility guidance note, Management of change Refer to guidance note above on management of change. Preventative maintenance may cover: equipment in hazardous atmospheres eg electrical equipment safety-related control and alarm systems and indicators utilities (electricity, steam, water etc) necessary for safe operation relief and vent systems pressure systems and other containment tanks for DG leak detection systems local exhaust ventilation fume cupboards/spray booths. A permit system assists in identifying and controlling the hazard and associated risks. Permits should cover hot works, cold works, work in confined spaces, work with an ignition source, maintenance work using electrical equipment and using welders and grinders near flammable atmospheres. 6

7 Supplementary questions for larger sites Do all relevant work permits exist, where applicable? 12. Is there understanding about how the controls work? 13. Are workplace audits/ inspections carried out to ensure control measures are working? Information and instructions should have been sourced from the relevant maintenance personnel or contractors. Inspections (see below) should be scheduled and regular. Document findings and actions required. 14. Are maintenance procedures documented and records kept? 15. Is regular maintenance scheduled and occurring at recommended intervals? 16. Are problems, faults or failures reported and addressed? 17. Are interim measures considered if a control measure is found to be deficient? This involves looking, reviewing and addressing symptoms, near misses, observations, chemical odours, poor practices, complaints, injuries and/or contamination of workers and work areas. Options for addressing this include an OHS management system or a quality assurance system. Ensure risks are controlled while the specific control measure is being fixed. 7

8 SECTION 3 EMERGENCY PLANNING 3.1 PLACARDING 1. If the quantities of DG exceed the Placarding Quantity in Schedule 2 of the DG S&H Regulations, has placarding been posted? Placarding warns emergency services of the likely need for extra precautions on their part. Placarding is at two levels. The first is the general HAZCHEM sign at the entrance(s) and the second is the detailed sign on bulk tanks and large stores of packages. 2. Do placards comply with Schedule 4 of the DG S&H Regulations? SECTION 3 EMERGENCY PLANNING 3.2 MANIFEST 1. If the quantities of DG exceed the Manifest Quantity in Schedule 2 of the DG S&H Regulations, has a manifest been prepared? 2. Does the manifest contain information prescribed in Schedule 3 of the DG S&H Regulations? 3. Is the manifest kept in a place that is easily accessible to the emergency services? 4. Are arrangements in place to ensure the manifest is updated? For guidance on manifests, refer to Code of Practice for the Storage and Handling of Dangerous Goods. The manifest provides the fire authority with information to assist them to respond appropriately if there is an incident. A manifest should detail all the matters required under Schedule 3 including class, packaging, any DG used in manufacturing and a plan of the premises. The manifest under DG laws should not be confused with the register of hazardous substances under OHS laws (see section 1.1). The manifest should be near the outer warning placard or another place agreed with the fire authority. Duties should be assigned to responsible persons and procedures/training organised to ensure the manifest is updated. 8

9 3.2 MANIFEST 5. Has WorkSafe Victoria been notified of quantities of DG exceeding threshold quantities? Quantities above the Schedule 2 threshold increase risk and may trigger additional duties for operators. They must notify WorkSafe Victoria under the major hazard facility part of the OHS Regulations. SECTION 3 EMERGENCY PLANNING 3.3 EMERGENCY PLANS 1. If the quantities of DG exceed the manifest quantity in Schedule 2 of the DG S&H Regulations, has an emergency plan been prepared? 2. Has written advice been sought from the fire authority in the development of the emergency plan? 3. Does the plan contain the necessary information? 4. Has the plan been communicated to the relevant people? 5. Are arrangements in place to implement, test and review the plan? For guidance on emergency planning, refer to the Code of Practice for the Storage and Handling of Dangerous Goods. Examples of areas often not addressed properly include spill control and clean up materials and back up personnel in absence of key personnel. The operator must have regard to the fire authority s recommendations when developing a plan. The emergency plan must be reviewed at least every five years. All potential emergencies needs to be identified and addressed and any missing information incorporated into a revised plan. Includes those in adjacent or shared premises. These people need to be identified and provided with the required information. Testing an emergency plan is essential. Reasons for more complex and/or frequent exercises include: large volumes or mixed classes of Schedule 2 dangerous goods staff expected to carry out response roles beyond simple evacuation an exercise does not go to plan. 9

10 SECTION 3 EMERGENCY PLANNING 3.4 FIRE PROTECTION 1. If the quantities of DG exceed the Fire Protection Quantity in Schedule 2 of the DG S&H Regulations, is the required fire control system installed? 2. Has written advice been sought from the fire authority on the design of the system? For guidance on fire protection, refer to the Code of Practice for Storage and Handling of Dangerous Goods. See part 3.2, question 2. Supplementary questions for larger sites Are the system s components (eg sprinklers, fire extinguishers, water tanks) compatible with the types and quantities of hazardous chemical? Is the system accessible at all times to persons on the premises and to the emergency services? Particular chemicals may have to be removed or interim measures implemented while making the system compatible or while seeking advice from the fire authority. It may be necessary to do regular checks to ensure access. Is all fire fighting equipment suitably labelled and visible? Is the system maintained and tested in accordance with technical standards? Refer to section 2 10

11 TRAINING 1. Are there organisational arrangements for awareness of, and compliance with, consultation duties? 2. Have affected workers and HSRs been provided with adequate induction, training, information or supervision relating to the hazards associated with hazardous chemicals used, stored and handled at the site? Arrangements could be discussed at OHS committee and toolbox talks; raised at safety meetings; displayed on notice boards; shared in publications and during training. Identify training needs, establish a training plan and implement it. 3. Have HSRs been provided with adequate induction, training, information or supervision relating to assessing risks (ie the nature of the hazards, properties of the products and processes used)? 4. Has the site provided affected workers and HSRs with adequate induction, training, information or supervision relating to the need for, and proper use of, the selected control measures? 11

12 TRAINING 5. Are there records of which personnel have received training and the material used in training? 6. Has the effectiveness of the training been gauged? 7. Is supervision provided to ensure that control measures are used and maintained correctly? Competency may be gauged by written assessment, competency sign off, practical demonstration or using independent competency assessors. An assessment may include demonstrating: an understanding of the hazards, their control measures and which ones are critical the ability to operate the control measures what needs to be done if a control measure does not work. Include this requirement in supervisory roles and ensure time is allocated to do it. 12

13 Appendix One Hazardous Chemicals Register Management Tool Example of a Workplace This tool is designed to assist your workplace manage its hazardous chemicals register (a list of products and an up-to-date SDS). Company: Site/Area: Date: Person compiling register: Product name Location or process where product used Is the product hazardous? Is the product dangerous goods? MSDS Risk assessment Responsible person Supplied Date Y/N Date Actions/comments LPG Forklift fuel N Y Y December 1999 Y July 2000 SDS nearly out-of-date. Request a new SDS. Paint thinners Painting area Y Y Y August 2002 Y January 2002 Sulphuric acid Process chemical Y Y Y May 2003 Y February 2004 Mineral turpentine Cleaning agent Y Y Y March 2002 Y February 2001 Changed supplier October Need to get new supplier SDS asap and review risk assessment, if required. Chlorine Bleaching agent Y Y Y January 2004 Y August 2001 Planned change to processes in January 2005, need to review risk assessment. Hydroflouric acid Glass etching Y Y Y October 2003 Y May 2001 Acetone Processchemical N Y Y April 2001 Y June 2003 Date for review of register: Last review October Next review January * All hazardous chemicals must have an up-to-date SDS no more than five years old that states the product is hazardous, or if dangerous goods, provide the proper shipping name, UN number, class label and subsidiary risk for those dangerous goods. 13

14 Company: Site/Area: Date: Person compiling register: Product name Location or process where product used Is the product hazardous? Y/N Is the product dangerous goods? Y/N SDS Risk assessment Actions/comments Responsible person Y/N Date Y/N Date * All hazardous chemicals must have an up-to-date/sds no more than five years old that states the product is hazardous, or if dangerous goods, provide the proper shipping name, UN number, class label and subsidiary risk for those dangerous goods. 14

15 Appendix Two RISK ASSESSMENT EXAMPLE - TANKER LOADING Chemical/ substances Benzene Description of use Transfer/tanker loading Types of hazards Flammable (fire/explosion) Current safety measures Is there a risk? Yes/No /unsure Reasons Hose maintenance Y Maintenance program. Static control N Inconsistent use of earth leads across sites and/or damaged leads. Electrical installation Y Hazardous zone suitable electrics. Action required Fire system (Including N Maintenance program. monitors, hydrants, deluge systems and sprinklers) Emergency shutdown Y No maintenance system for routine inspection. Training/instruction N Safe work procedure and training has been provided. Vehicle impact Y Increased traffic flow on site. Spill containment N The catchment or compound has been designed properly. Driveaway protection system Y Dry locks are fitted to vehicles but this does not prevent the vehicle being driven away during loading. Carcinogen PPE N Fully enclosed transfer system, therefore no risk of inhalation/exposure. Training instruction Y Safe work procedure and training has been provided. Existing training found to be relating specifically to DG risks, not hazardous substances. Vapour recovery Y Interconnected system with knock on effects. Top loading Gantry Y Fire and explosion. 15

16 TANKER LOADING RISK ASSESSMENT TEMPLATE Chemical/ substances Description of use Types of hazards Current safety measures Is there a risk? Reasons Action required Yes/No /unsure 16

17 Appendix Three ELIMINATION SUBSTITUTION ISOLATION ENGINEERING Eliminate the use of the chemical or outsource the work to a specialist contractor. If the work has to be done on the premises, an example of elimination is using a physical process (such as ultrasound) instead of a chemical process to clean equipment. Use a safer chemical or a safer form of the substance. Examples: using detergent instead of chlorinated solvent for cleaning using water-based chemicals instead of solvent-based chemicals Safer form or process painting with brush instead of spraying purchasing a chemical in a safer form (eg using pellets instead of powder which reduces dust, using liquids in ready to use form instead of concentrates which require decanting or mixing). Separate people or property from the substance by distance or barriers. Examples: using closed systems fully or partially enclosing the process with exhaust extraction isolating the process to one room with restricted access or using appropriate barriers/screens to separate chemicals moving the process into a positive pressure cabin or room distancing workers from substances/processes through the use of remote controls distancing property, incompatible chemicals and ignition sources from goods. Physical controls (such as plant/equipment) that eliminate or reduce chemical being produced, stop or contain chemicals or limit the area of contamination in the event of spills and leaks. Examples: using fully enclosed ventilation booths using partially enclosed ventilated spray booths using local exhaust or natural ventilation systems using robots designing buildings that are: compatible with the intended goods; made of non-combustible construction as far as practicable; and designed to reduce contamination using bunding to reduce spillage installing drains, tanks or sumps to cope with spilled material installing automatic fire protection and chemical suppression systems. 17

18 ADMINISTRATIVE PERSONAL PROTECTIVE EQUIPMENT (PPE) Using safe work practices including good housekeeping. Examples: reducing the duration and/or frequency of exposure for DG reducing the amount stored and used ensuring safe interim storage of wastes vacuuming or wet sweeping to suppress dust being generated covering containers and making sure lids are attached cleaning up spills immediately ensuring no eating, drinking or smoking in areas where chemicals are used providing suitable washing facilities providing first aid facilities instructing staff how to use chemicals/equipment safely. Protective clothing and equipment for workers, supervisors and visitors. Examples: overalls aprons/gowns footwear gloves safety glasses face shields respirators head protection. 18

19 Further information Call us on: us at: For more information on occupational health and safety, go to WorkSafe Victoria s website: worksafe.vic.gov.au Guidance Compliance Code for Hazardous Substances Code of Practice for Storage and Handling of Dangerous Goods Managing safety in your workplace. A step by step guide. A guide to risk control plans Consultation on health and safety. A handbook for workplaces The information presented in this Assessment Tool is intended for general use only. The Assessment Tool should not be viewed as a definitive guide to the law or industry practice in this area and is not intended to take the place of expert professional and/or legal advice. Whilst every effort has been made to ensure the accuracy of the Assessment Tool, the information contained herein may not apply in every circumstance. You should always check any applicable legislation and make your own assessment about what action you may need to take to ensure you have complied with the law. Accordingly, the Victorian WorkCover Authority cannot be held responsible and extends no warranties as to the suitability of the information for any particular purpose; or actions taken by third parties as a result of information contained in the Assessment Tool. This guidance has been reviewed and updated for the sole purpose of amending year and regulation references relating to the Occupational Health and Safety Regulations, in line with amendments which came into effect on 18 June Victorian WorkCover Authority 2012 The information contained in this publication is protected by copyright. The Victorian WorkCover Authority hereby grants a non-exclusive licence in this publication to the recipient of this publication on the condition that it is not disseminated for profit. The Victorian WorkCover Authority encourages the free transfer, copying and printing of the information in this publication if such activities support the purposes and intent for which the publication was developed. 19