Presented by John Whale Control Banding as a Potential Alternative to Risk Assessment AUSA National Conference Sydney 2009
Background Monash s current risk control program has been in place for over 6 years An system review of the document was scheduled for 2009 Issues with the current system lead OHS to investigate other potential methods of assessing and controlling hazards
Changes to Victorian Regulations - In 2007 a change to the Victorian OHS Regulations - Emphasis removed from risk assessment of hazards and put on to control implementation - Hierarchy of controls remains prominent feature of methodology - Primarily use of Substitution, Isolation and Engineering in combination with: - Secondary controls of Administrative and PPE
Review of Monash s Current System Strategic focus (compliance) has been mainly on assessment component. Inadequate or outstanding controls from prior assessments (assessment the priority) Many generic assessments exist which may have little to do with the true risks or controls required for the hazards. Inadequate controls selected or picking down the Hierarchy for the risk level
Current Monash Method of Assessment - Consequence Vs Likelihood Matrix. - Matrices are tailored to Hazard type. - Some calculation or estimation of factors required within the hazard type. - Controls are determined by the person doing the analysis.
Common flaws Choosing an incompatible control based on assessors knowledge Possibility of choosing a lower control for expediency, downtime of project or cost. Reassessment of risk with new controls may under or over estimate the control effectiveness. (leaving process vulnerable or unusable)
Likelihood Consequence Matrix Likelihood of injury after current controls are considered Consequence Highly Likely Likely Occasionally Unlikely Highly Unlikely Major Injury Extreme Extreme High High High Severe Injury Extreme High High High Medium Moderate Injury High High Medium Medium Medium Minor Injury High Medium Medium Medium Low Negligible Injury Medium Medium Medium Low Low
Pitfalls with Standard Matrix Individuals may score Consequence and Likelihood differently Ambiguity with end score significance Possibly no reduction of risk score so process is perceived as futile Similar scores for tasks which are obviously dissimilar in risk Control may be over or under represented as a solution
Considerations for a Reviewed Model What is the driver behind Hazard control? Are most Hazard and control combinations known? Do hazardous activities generally fall into control categories? Do we currently exercise multiple levels of control? Do we promote redundancy and duplicity? How do we get the most out of the Control Hierarchy?
Control Banding Concept Focus remains on the elimination or substitution of hazards System which incorporates both Monash University endorsed protocols, Regulatory Codes and Australian Standards. Relate Hazards directly to the selection of known controls. Use of a hazard specific matrix as well as incorporating a table of control solutions
Hazard Control Process Eliminate or reduce hazards through Substitution Identify Hazard Categories Identify opportunities within each category to eliminate or substitute For each outstanding hazard identify: Dependent variables within the hazard category Control band based on the variables Controls required for the hazard Current controls and implement those remaining.
Reduce 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 person from the Hazard Use Engineering Controls to protect against 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 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
Hazard Bands 1. Low hazard level with predominantly secondary level controls 2. Moderate hazard level with the use of some primary as well as secondary 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
Laser Hazards Example Hazard Reference Model Laser Class Control level Class 1 & 2 Class 1M,2M & 3R Class 3B & 4 1 2 3 Laser Model Noise
Hazard Group D & E Amount 0.5 g or ml > 0.5 g or ml & 20 kg or L > 20 kg or L Inhalation Risk Rating (IRR) Hazard Control Level Low 3 Med/High 2 All 3 Low/Med 3 High 4 0.5 g or ml All 1 C Concentrate > 0.5 g or ml & 0.5 kg or L Dilute (<5% of haz sub) > 0.5 g or ml & 0.5 kg or L >0.5 kg or L & <20 kg or L > 20 kg or L All 2 All 1 All 2 Low/Med 2 High 3 0.5 g or ml All 1 A & B > 0.5 g or ml & 20 kg or L > 20 kg or L All 2 Low 2 Med/High 3
Control Group 1 2 3 Description Processes with a low risk of serious injury to Processes with a medium risk of serious injury Processes with a high risk of serious injury or the operator or those potentially exposed to to the operator or those potentially exposed to fatality to the operator or those potentially the Chemical. the Chemical. exposed to the Chemical. Engineering: General ventilation should be of a good standard. This includes natural ventilation or controlled ventilation where air is removed by a powered fan As per Control Band One Use all hazardous substances inside a fume hood/cupboard Cold rooms typically have full recirculation of air and thus are not suitable Fume hood if work may impact on others in area (respirator for individuals) Where possible use Fume hood or cupboard or extraction Administration: Ensure all staff are provided with information regarding the hazards associated with the substance/s in use Ensure those using substances have completed a Dangerous Goods & Hazardous Substances training course Consult the Material Safety Data sheet (MSDS) before commencing work Ensure a Safe Operating Procedure/Safe work Instruction is developed for all procedures As per Control Band One and in addition. As per Control Band Two and in addition. Ensure all unattended reactions are clearly labeled Keep the sash down as far as possible (at or below yellow diamond/ white label) Alert colleagues to your activities so they may also take precautions Ensure comprehensive training on the process to be undertaken has been given/received Refer to OHS INFORMATION SHEET 13: Use of Local Exhaust Ventilation Systems & Fume Cupboards Place lids on containers immediately after use Ensure all requirements for licenses, permits or notification to use the chemical are met Store chemicals in accordance with the Monash Chemical Storage Guidelines All staff/students must be confident and competent before being allowed to perform tasks unsupervised Consumption or storage of food and/or drink in the laboratory/workshop is prohibited Consider whether after hours work will be required and if so, develop and after hours procedures Ensure good housekeeping standards are practiced at all times and ensure all containers are affixed with a compliant label (Product name, concentration, DG code if applicable, date and decanter s name) Dispose of all wastes as per the MSDS and waste disposal guidelines where applicable Personal Protective Equipment (PPE): Minimum PPE to be worn at all times -laboratory coat/dust coat/coveralls, safety glasses, closed toe footwear and gloves Ensure Personal Protective Equipment (PPE) is appropriate for the task and chemical As per Control Band One and in addition. Use all hazardous substances with an appropriate respirator As per Control Band One
Possible Limitations of Control Banding Dynamic or evolving tasks or tasks which occur in dynamic environment ie maintenance, installations, field trips, one off activities Activities which may require scrutinizing of procedures i.e. 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
Conclusions Current risk assessment methodology of a likelihood and consequence matrix has known pitfalls and limitations Control banding may be a simple way of bridging the knowledge gap between an identified known hazards and acceptable levels of control Monash now moving into pilot phase of project.
Questions?