THE NEED FOR A NEW SYSTEM OF MANAGING HAZARDS

Hazard Identification and Control Banding as a Potential Alternative to Risk Assessment John J Whale Monash University Occupational Health and Safety Unit Email: john.whale@eng.monash.edu.au ABSTRACT Monash University and many other organisations have used the traditional matrix or consequence likelihood tables as the primary method of assessing risk. This method, although simple and effective in the hands of a competent practitioner, does little to direct the user towards typical or multiple controls associated with acceptable protection from the hazard. Recent changes to the Victorian Occupational Health and Safety Regulations 2007 have removed the need for assessment and instead have placed the emphasis on the use of controls for known Hazards. Monash University is developing a method to better direct those who manage hazards to adopt appropriate controls within the Hierarchy and to use layers of controls to minimise the potential effects of known hazards. The University s Control Banding method has been developed to include several classes of hazards, specifically in the areas of Manual Handling, Equipment & Process (physical), Chemical, Biological and Radiation Exposure, and link the known associated hazards within these classes to defined control options thereby removing any control option ambiguity from the assessment. THE NEED FOR A NEW SYSTEM OF MANAGING HAZARDS Risk management is an integral part of any safety management system (SMS) and the risk assessment process is seen as an important component for the management of hazards (Gallagher 2000, Bluff 2003). The risk assessment process, however, has multiple components and may be complex and confusing to the novice or untrained user. Risk management involves establishing an appropriate infrastructure and culture and applying a logical and systematic method of establishing the context, identifying, analysing, evaluating, treating, monitoring and communicating risks associated with any activity, function or process in a way that will enable organizations to minimize losses and maximize gains. (AS/NZS 4360:2004 - Risk Management, pg 5) The current risk management process leaves the participant with a perceived added workload (normally not factored into projects although crucial for success), insufficient added project or operational value, as well as no direction in the best way to control the hazards identified (Gadd 2004). This unfortunately means risk management can become a process or rule which is avoided, generalised and seen as a barrier to work rather than an integral part of the job (Leplat 1998). The change in the Victorian OHS Regulations (2007) removes the need for analysis as a step in choosing an appropriate control for known hazards. The removal of the assessment component from the regulation allows the resources currently being committed by organisations to the documentation of risk assessments (in order to comply) to be shifted to concentrate on managing hazards through known controls. The emphasis of the regulation now lies in the Page 1 of 10

hazard identification and implementation of controls, with the hierarchy of controls still being a prominent feature within the regulations (Victorian OHS Regulations 2007). The Victorian OHS Regulations (2007) state several different categories of risk that need specific controls (Manual Handling, Plant, Chemicals etc) and that in essence, an employer must, so far as is reasonably practicable, identify all hazards to health and safety associated with those tasks to be undertaken by an employee. The control of risk is similar for these categories and, put simply, the employer must ensure that the risk of a task affecting an employee is eliminated so far as is reasonably practicable. Where it cannot be eliminated, an employer must reduce that risk so far as is reasonably practicable by: substituting the way the task was to be performed with a process that presents a lower level of risk; or using engineering controls; or isolating the plant from people. (Victorian OHS Regulations 2007) These primary controls give the highest level of protection from the hazard and are used in preference to, or in conjunction with, secondary controls such as the use of administrative controls or personal protective equipment (PPE). The Victorian OHS Regulations (2007) state that the employer must as part of the control structure provide sufficient information, instruction and training to enable the employee to perform his or her work in a manner that is safe and without risks to health. The Regulations also require similar information to be provided by suppliers and designers of equipment. From both a Monash University and a safety professional point of view this may mean a more standardised, directive approach to controlling known hazards rather than the use of secondary controls. ISSUES WITH THE CURRENT SYSTEM: Monash University currently uses a modified consequence versus likelihood matrix system of risk assessment similar to that prescribed in HB AS/NZS 4360 - Risk Management Companion Guide -Table 6.6 to evaluate the level of risk and assign controls for the particular hazards identified. Although this method is adopted in many industries and universities there are many issues in its execution. The matrix has been seen as a simple way to assess risks and generate a risk score. However the value of the assessment is in the control selection, which needs background knowledge in the field of the hazard or significant training. Successful achievement of goals and objectives depends on how risks and uncertainties involved with them are assessed and optimal decisions are taken in containing and managing the risks. (Tummala, et al 1996) The main issues with the current assessment method are: individuals may score Consequence and Likelihood differently therefore the end assessment (risk score) may be inaccurate ambiguity with end score significance in relation to controls needed addition of controls and reassessment may not reduce risk score so process is perceived as futile (when the process focus is about assessment not control) Page 2 of 10

control may be over or under represented as a solution and therefore be oppressive to the process or not adequately reduce the risk similar scores may be represented for tasks which are obviously dissimilar in risk o I.e. making a cup of tea and taking it to one s office versus operating a lathe. Within Monash University there is currently an emphasis on all tasks requiring a risk assessment with risk controls being left up to the risk assessor to identify and then implement. There are many issues which arise from this approach, such as the following. The possibility that tasks or equipment may still have inadequate or outstanding controls from prior assessments where the focus has been on the assessment component only. Many generic assessments are derived from similar equipment or projects which have little to do with the true risks involved or the appropriate controls required for the particular hazard. It may be possible to select an inadequate control for the type of hazard or pick a control down the Hierarchy for the risk level with little guidance to better options. Choosing an incompatible control because of a lack of hazard knowledge. Choosing a lower order control for expediency, in terms of time, resources or cost. Reassessment of risk with new controls may either under or over estimate the control effectiveness with the result that the hazard may not have been sufficiently minimised or, alternatively, that it becomes over protected to the extent that the process becomes unviable. Gadd (2004) found similar pitfalls and concerns with the risk assessment process and states that effective management of health and safety will depend, amongst other things, on suitable and sufficient risk assessments being carried out and on the findings being used effectively (Gadd 2004, Pg 842). MONASH S CONCEPT: RISK BANDING PROTOCOL Monash University s approach to risk banding has been a culmination of many different influences. Firstly, the recent changes to the Regulations presented the catalyst to review current practice. Secondly, the opportunity to elevate the level of controls being utilised where higher order primary controls are essential and are used in preference to or in combination with secondary controls. Thirdly, the shift in staff and post-graduate culture to want to more effectively control hazards within their workplace. Viner (1991) in his book on accident analysis and hazard control indicates that risks are best evaluated by those who experience the adverse consequences... and controls are best implemented by...those who have the authority to make the proposed changes happen (Viner, 1991, pg 125). This new system combines the expertise of risk practitioners to classify recurrent hazards and develop associated control structures, but allows those responsible for hazards in the workplace to identify and manage control implementation. This model has been developed in consultation with many of the stakeholders within the University and focuses on known hazards and recognised treatments or controls that are outlined in many of Monash University s internal guidelines, AS/NZS standards and Government regulations (i.e. OGTR). The model also provides an easy reference for researchers who may Page 3 of 10

be planning activities to identify what controls need to be incorporated within their projects. Such an approach raises awareness of the complexity of the respective projects, together with the need to adequately resource the controls and infrastructure needed. This is particularly relevant in cross faculty research where controls and hazards may be beyond the researcher s area of core expertise. The risk banding protocol uses known controls, mostly multiple layers, for known groups of hazards and has: a focus on the elimination or substitution of hazards changed the risk analysis process to a system which incorporates both Monash University endorsed Protocols and Australian Standards related hazards directly to the selection of known controls use of a hazard specific matrix as well as incorporating a table of control solutions based on the hazard group. The new approach uses the University s traditional Hazard categories and control information that have been redesigned and reformatted to correspond with the current standards. The major hazard groupings currently being used by the University are: physical manual handling chemical radiation biological. Hazard types under these major groupings were expanded to give the user a greater ability to identify the right controls. For example the physical hazards grouping was expanded to include a control selection for noise and laser exposure. Other sub groups within the Physical Hazards grouping may include radiation producing equipment (Xray) and working at heights, which are still in an early development phase. The Control Band system utilises four distinct bands of control based on the level of hazard, these being: 1. low hazard level with low level controls 2. moderate hazard level with the use of selected primary controls 3. high hazard level and multiple primary and secondary controls 4. unacceptable hazard level, no controls or facilities (internally) available and need for external / independent review. Where possible direct controls are identified and combinations to reduce contact or impact from the hazard are used. These applicable controls are then selected for the process / task / equipment Example of the concept and model for biological hazards and associated control tables can be seen in appendix 1. Page 4 of 10

LIMITATIONS OF RISK BANDING CONCEPT It is important to note that the risk banding model is only one tool which can be used to implement controls to reduce injuries or incidents. It is recognised by Monash University that other systematic processes such as competency based training, safety systems and infrastructure, as well as a safety culture, are needed to reduce the risks As Low As Reasonably Practicable (ALARP) (HB436: AS/NZS 4360:2004). James Reason s work in organisational risk management (1997) recognises the need for multiple levels of controls and systems as well as an organisational culture active in safe practices, all of which are needed to reduce injuries or catastrophic events. Reason likened accident causation to a number of slices of Swiss cheese where the slices represented the defence layers of organisation (procedures, calibrations, alarms, barriers, etc) and the holes are weaknesses or gaps (active & latent conditions) in the organisation. Reason proposed that these dormant failures in the system (latent conditions) and human error can combine to allow an incident to occur (the holes in the cheese line up) (Reason 1997). Similarly the model proposed in this paper represents only one slice of cheese, and needs to be combined with other resources and systems to reduce hazards in the workplace. The model also may not be useful for tasks which may still need an assessment component such as: dynamic or evolving tasks or tasks which occur in dynamic environment ie maintenance, installations, field trips, one off activities activities which may require Job Safety Analysis or scrutinizing of procedures such as entry into confined spaces tasks which may have competing or multiple hazards / control options physico-chemical reactivity hazards emerging technologies where hazards and controls are not yet defined psychological injury control. These require a more in-depth and specialised training approach in hazard identification and control. CONCLUSION Current OHS Regulations in Victoria have removed the need for the assessment of risk where known controls exist. The current risk assessment methodology of a likelihood and consequence matrix has known pitfalls and limitations in its execution and guidance for controlling hazards. Control banding may be a simple way of bridging the knowledge gap between an identified known hazards and acceptable levels of control. Page 5 of 10

APPENDIX 1 Concept of the Hazard Model and Control Tables Reduce Process Hazard Eliminate: Redesign, do not use or do Substitute: Use a less hazardous alternative Determine Hazard Classes As either physical or energy, Chemical, Biological, radiation or manual handling No Is Hazard Eliminated Yes Reduce Hazard in each class Eliminate: Redesign, do not use or do Substitute: Use a less hazardous alternative Select Primary Controls from Tables Isolate hazards from the person or the person from the Hazard Use Engineering Controls to protect from the hazard No Is Hazard Eliminated Yes Select Secondary Controls from Tables Administrative controls such as procedures, training and signage Personal Protective Equipmen to reduce the impact of the hazard and as a last line of defence Example of process for Microbiological Hazards Develop Emergency Controls To reduce the impact or aid recovery of a primary or secondary control breach. Isolation, shutdown and contingencies Document process Use Hazard Control Sheets as well as using information in Safe Work Procedures and Manuals Page 6 of 10

Organism Group Microbiological Hazards Procedures Type of procedure with low aerosol risk Risk group 4 4 Risk group 3 3 Procedures with high aerosol risk Risk group 2 2A 2B Diagnostic specimens from animals or humans blood, bodily fluids, tissue Genetically Modified Organisms (GMOs): - DIR - DNIR - PC2 NLRD; 12 categories as listed in GT Act Genetically Modified Organisms (GMOs): - PC1 NLRD; 3 categories as listed in GT Act 2A 2B 2B 1 2B Microbiological Hazard Identification Identify which risk group (RG1-4) the organism belongs to by referring to AS2243.3 Identify if the work involves a genetically modified organism (GMO), then determine to which category it belongs: Exempt dealing, NLRD, DNIR or DIR. Refer to the Gene Technology Act, 2000. Identify if the work involves the use of imported microbiological samples and whether they require an import permit. Refer to the ICON database, which can be accessed from the AQIS website. Confirm if the conditions on the permit require a QAP facility for the organism. This analysis must take into account the use and storage of the organism(s), as well as the disposal of waste products. Each hazard should be listed separately but assessed as part of an overall process. Using the table below, determine what steps need to taken and the controls that are needed before work with this organism commences. Identify what controls are currently in place, make a comparison between this and what the relevant control level stipulates should be in place and record on the risk control sheet the additional measures (if applicable) which are to be implemented. Use as many controls as possible without compromising the process or creating further hazards. Genetically Modified Organisms (GMOs): - Exempt dealings, i.e. exempt host-vector system, < 10L 1 Risk group 1 1 Page 7 of 10

Hazard Control Reference Sheets Micro Biological Hazards Control Group 1 2 3 Description Work with Risk group 1 organisms must be carried out in facilities that have been certified as PC1 by the OGTR Isolation: Engineering: Segregation of waste streams: General waste vs. infectious waste Level 2 A: Work that has been assessed to have a low aerosol risk may be conducted on the bench using good aseptic technique and must be carried out in facilities that have been certified as PC2 by the OGTR. An OGTR license must be obtained prior to commencing work with DNIR s and DIR s Level 2B: All work must be conducted in a Class II Biosafety cabinet and PC2 work practices must be adhered to at all times. Access to PC2 laboratories should be restricted to appropriately trained staff Only work that has been assessed to have a low aerosol risk may be conducted on the bench. Level 2B: Any procedure which may produce aerosols of potentially infectious material should be performed in a Class II Biosafety cabinet. A secondary unbreakable container which can be readily decontaminated must be used for the transport of microorganisms/gmo s between facilities Level 2B: Centrifuges that are used for diagnostic samples or infectious microorganisms must be fitted with either a sealed rotor or removable buckets, for easy decontamination in the event of a spill. Level 2B: Samples must be placed in sealable tubes All work with Risk group 3 organisms must be conducted in a Class II Biosafety cabinet. PC3 work practices must be adhered to at all times. Access to PC3 laboratories must be restricted to appropriately trained staff As per Level 2 and Steam sterilizer (autoclave) must be located within PC3 facility for processing of infectious waste Aerosol containment Class II Biosafety cabinets Centrifuges with sealed rotors and removable buckets Administration: No consumption/storage of food or drink can be permitted in the facility. If food/drink is to be used for research purposes, it must be clearly labelled Not for human consumption. As per level 1 and. As per level 2 and. Page 8 of 10

Personal Protective Equipment (PPE): Safe Work Instructions for all procedures Training to include Monash University Biosafety & Organism specific training Relevant vaccination(s) e.g. Hepatitis B, Q- fever Suitable disinfectant must be available at all times for regular decontamination of work benches e.g. Sodium hypochloride or Ethanol All potentially infectious waste must be steam sterilised before leaving the building or a medical waste contractor must be engaged for infectious waste disposal Safe work instructions for all procedures including spill clean up procedures Medium level supervision Training to include Monash University Biosafety, Pathogen specific training, Emergency training including spill management High level of planning and supervision of task Health monitoring Lab coat/gown As per level 1 and As per level 1 and Closed footwear Suitable gloves must protect against biological as well as any chemicals used in the procedure. Refer to Ansell Glove chart Suitable gloves must protect against biological as well as any chemicals used in the procedure. Refer to Ansell Glove chart Safety eyewear Respiratory protection Long hair must be tied back Control Band 4 Work must be carried out in Physical Containment Level 4 (PC4) certified facilities which are located within the Animal Health Laboratories in Geelong and the VIDRL in North Melbourne. Page 9 of 10

REFRENCES AS/NZS 4360:2004, (2004) Risk Management, Downloaded from Standards online (8/4/09) Bluff, L, (2003) Systematic Management of Occupational Health and Safety - Working Paper 20 National Research Centre for Occupational Health and Safety Regulation Gadd S.A., Keeley D.M., Balmforth H.F. (2004) Pitfalls in Risk Assessment: Examples from the UK Safety Science 42 (2004) 841 857 Gallagher, C. (2000). Occupational Health and Safety Systems: System Types and Effectiveness. Thesis, Deakin University HB436: AS/NZS 4360:2004 (2004) - Risk Management Companion Guide, Downloaded from Standards online (8/4/09) Leplat,J. (1998) About implementation of safety rules, Safety Science 29 (1998) Monash Risk Control Program (2004) http://www.adm.monash.edu.au/ohse/assets/docs/others/risk-control-program.pdf Occupational Health and Safety Regulations 2007, S.R. No. 54/2007, Version incorporating amendments as at 1 July 2008, Downloaded from http://www.dms.dpc.vic.gov.au/ Rao Tummala, V. M., Leung, Y.H. (1996). A risk management model to assess safety and reliability risks. International Journal of Quality, 13(8), 53-62. Reason.J.T, (1997) Managing the Risks of Organizational Accidents. Ashgate Pub Ltd Viner, D. (1991). Accident Analysis and Risk Control. Ballarat: Derek Viner Pty Ltd. Page 10 of 10