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Registers/Manifests

Registers

Control of Workplace Hazardous Substances National Model Regulations and National Code of Practice 1994

It is a requirement of the National Model Regulations to keep a register of hazardous substances.

Registers

(7) In respect of registers, an employers shall ensure that:

(a) a register is kept and maintained for all hazardous substances used or produced in the workplace;

(b) the register contains, as a minimum, a list of all hazardous substances used or produced at the workplace and the MSDS for all hazardous substances for which MSDS are required by these national model regulations; and

(c) the register is readily accessible to all employees with the potential for exposure to hazardous substances.

Minimum requirements:

The register must be kept up to date. When a hazardous substance is discontinued it must be removed from the register. When a new hazardous substance is introduced it must be added to the register.

The register must be accessible to:

 

Manifests

Dangerous Goods (Storage and Handling) Regulations 1989

Reg 308 Manifests to be kept at certain premises

An occupier must keep a manifest in accordance with regulation 309 if the dangerous goods kept at the premises result in an assessment factor of 10 or more.

Reg 309 Contents, location and revision of manifests

(1) A manifest must

(a) contain the information specified in Schedule 7 about the dangerous goods kept at the premises; and

(b) be kept at a location and in a type of protective container approved by the fire protection authority.

(2) A manifest must be revised as soon as is practicable, and in any event within 7 days, if there is a change in

(a) the type of dangerous goods stored in tanks; or

(b) the Class, packaging group or more than a 20 per cent change in the maximum quantity of any dangerous goods which are stored in packages; or

(c) the Class or packaging group of any dangerous goods used in a manufacturing process.

 

Industrial Processes

Exposure to chemicals can occur in one or more of the following physical forms:

There are many industrial processes which can give rise to these.

Gases

These are materials which (normally) exist as gases at normal temperature and pressure.

eg. carbon dioxide, carbon monoxide, oxygen, oxides of nitrogen, oxides of sulfur and hydrocarbons such as methane, ethane, propane, butane and ethylene.

Gases such as carbon dioxide, carbon monoxide and oxides of nitrogen are produced via combustion. Therefore any industrial processes that involve combustion will probably produce these gases. Oxides of sulfur will be produced if the fuel contains some sulfur.

Exposure to bottled gases can occur via leakages or while they are being used.

Hydrocarbons are usually produced at oil refining facilities or can be found where low molecular weight hydrocarbons are part of manufacturing processes. eg conversion of ethylene into polyethylene.

Vapours

These are the evaporative products of volatile solvents such as petrol, acetone, trichlorethane, benzene, ethanol. etc.

They are found widely throughout industry but typically appear in workplaces such as laboratories, petroleum refineries/petrochemical works, rubber industry, printing processes and print manufacture, solvent manufacturing, cleaning industry, paper manufacture, synthetic fibre manufacture.

Dusts

These are airborne solid particles that range in size from 0.1 to 25 micrometres. They are generated by operations such as mining, quarrying, grinding, road making, detonation, crushing, milling and striking as well as wood dust from cutting, sawing and sanding.

 

Fumes

These are the condensed products of volatilised solids (solids heated to their evaporation point). Fumes most usually consist of metal oxide particles produced from processes such as welding, brazing, oxy-acetylene cutting, electro arc work and around blast furnaces and crucible refining of molten metals.

Smoke

Consists of carbon (soot) particles and other condensed combustion products. Particles are usually less than 0.1mm and are produced form incomplete burning of carbon based fuels such as coal, oil and wood in industry and accidental fires involving these materials along with carpets, plastics, etc.

Mists

These are made up of finely divided droplets of liquid entrained in a gas such as air. They are typically produced in spraying operations such as painting, degreasing, acid spray washes, etc.

Fibres

Fibres are divided into three groups:

Exposure to these fibres can occur during:

 

Control Techniques

Control of Workplace Hazardous Substances National Model Regulations and National Code of Practice 1994

Control

12 (1) Where an assessment under regulation 11 indicates that it is necessary, the employer shall ensure that exposure of employees to hazardous substances is either prevented or, where that is not practicable , adequately controlled so as to minimise risks to health.

(2) So far as practicable, the prevention or adequate control of exposure of employees to hazardous substances shall be secured by measures other than the provision of personal protective equipment.

(3) Where the measures taken in accordance with sub-regulation 12(2) do not prevent, nor provide adequate control of, exposure of employees to hazardous substances, then, in addition to those measures, the employer shall provide those employees with such suitable personal protective equipment as will adequately control their exposure to hazardous substances.

(4) Without limiting the requirements of sub-regulation 12(1), the employer shall ensure that no employee is exposed to hazardous substances at levels above the appropriate exposure standards for the relevant period of time.

(5) An employer shall ensure that all engineering controls, safe work practices and personal protective equipment are effectively maintained.

Consideration of necessary control measures

 

Hierarchy of Control

Elimination

Can you do away with the chemical process? If the answer is yes then get rid of it. If the answer is no, then perhaps the following could be considered:

using a physical process rather than a chemical process;

using clips, clamps, etc instead of using a twin pack glue.

Substitution

Replacing the existing substance with a less hazardous substance.

eg replacing a chlorinated degreasing solvent with a detergent;

brush application instead of using an aerosol can.

using water based paints instead of oil based paints;

Enclosure and Isolation

If possible isolate the hazardous material by separating the process from people either by distance or barriers. Enclosure can either involve enclosing the process or the operator.

eg open solvent containers can have lids placed on them;

remote control booths.

Engineering

Plant or processes which minimise the generation of hazardous substances and their escape into the surrounding work area.

eg Wet methods

Involves spraying the material with water to keep it damp. Used whenever a process produces hazardous dusts.

Ventilation

Involves the use of an exhaust or extraction system to remove airborne particulates, gases and vapours. Ventilation systems can be localised and operate at the point of generation of the hazardous particles, gases or dusts.

The whole work area also can be ventilated.

When using ventilation systems to control emissions of hazardous materials it is essential to consider the following:

# does the local extraction hood draw fumes away from the operators breathing space or past their face;

# is the hood as close as possible to the hazardous source;

# is clean air drawn into the workplace to replace the removed air;

# if air is recycled is it filtered properly;

# does the ventilation system create a noise exposure problem;

# what happens to the contaminated air after extraction; and

# is the efficiency of the system monitored?

Safe Operating Procedures

Safe work procedures are designed to enable employees to minimise their exposure to a hazardous substance by following certain steps. They are one of the least preferred methods as they rely on people doing the right thing. Safe operating procedures are often used in conjunction with engineering controls and the wearing of personal protective clothing and equipment.

eg maintenance of equipment and plant;

housekeeping;

prohibition of eating, drinking and smoking in contaminated areas;

storage of substances; etc.

Administrative Controls

Some control of hazards can be done using administrative techniques. However they rely on people doing the right thing and are used in conjunction with other control techniques.

eg job rotation;

shorter working periods (using STELs);

excluding non-essential entry.

Training

Control of Workplace Hazardous Substances National Model Regulations [NOHSC:1005(1994)]

Induction and Training

10(1) Employers shall provide induction and on-going training to all employees with the potential for exposure to hazardous substances in relation to those substances in the workplace.

(2) The induction and training provided shall be commensurate with the risk identified by the assessment process

(3) Induction and training shall be provided in a manner appropriate to the employees in the workplace.

(4) The employer shall record induction and training. This will be a record for the purposes of these national model regulations.

Dangerous Goods (Storage and Handling) Regulations 1989

Reg 427 Training

An occupier of a workplace must provide information and training to all employees and other people who are engaged in work associated with dangerous goods at the premises on

(a) the identification, properties and potential hazards of the dangerous goods kept or handled; and

(b) the correct use and proper fit of personal protective equipment to be used by people handling the dangerous goods; and

(c) correct procedures to be followed for work relating to the storage and handling of the dangerous goods; and

(d) emergency measures to be taken in the event of a spill, leak, fire or explosion at the premises.

Personal Protective Clothing and Equipment

The use of personal protective clothing and equipment should be limited to situations where other control measures are not practicable or where they are used in conjunction with other control measures.

 

Control of Workplace Hazardous Substances National Code of Practice [NOHSC:2007(1994)]

12.18 Personal Protective Equipment

Where personal protective equipment is used, employers shall ensure that it is:

(a) properly selected for the individual and task;

(b) readily available;

(c) clean and functional;

(d) correctly used when required; and

(e) maintained by appropriately trained staff in accordance with a personal protective equipment maintenance servicing program.

Dangerous Goods (Storage and Handling) Regulations 1989

Reg 428 Provision and maintenance of personal protection equipment

(1) An occupier of a workplace where dangerous goods are kept must

(a) provide personal protective equipment which is suitable for use with the dangerous goods that are stored or handled at the workplace; and

(b) ensure that the personal protective equipment is maintained in a clean and serviceable condition.

(2) A person must not wilfully damage or render ineffective any personal protective equipment provided under sub-regulation (1).

 

PPC&E includes respirators, gloves, boots, overalls, goggles, etc. PPC&E is the least preferred option due to the following:

Types of PPC&E

Body Protection

AS 2210 Safety Footwear

AS 2161 Industrial Safety Gloves and Mittens

AS 3765 Clothing for Protection Against Hazardous Chemicals

 

Eye Protection

Eyes must be protected from both splash and vapours. Eye protection is vital when dealing with chemicals, especially those from Class 8

Ordinary safety glasses will give some protection against splash, a better option would be a full face shield as not only eyes are protected but so is the face. For fuming chemicals, goggles are the preferred option.

AS 1336 Recommended Practices for Eye Protection in the Industrial Environment

AS 1337 Eye Protection for Industrial Applications

Respiratory Protection

When required, proper respiratory protection is vital. It is important that the right type is selected, it is working properly and is fitted correctly.

They are to be used for the following:

nuisance dust;

harmful dust;

gases and vapours;

viruses and bacteria;

moulds and fibres.

They should not be used in:

areas with high concentrations of toxic materials;

low oxygen level areas;

atmospheres where eye damage might occur (this applies to half faces respirators, not full face masks and visors);

areas where contaminants are unknown.

The filters/canisters used in these respirators are colour and letter coded.

Remember:

you must have the correct filter for the chemical being used;

the mask must be clean, well maintained and for individual use only;

mask and filters must be sealed from the air when not in use to prevent unnecessary contamination of the filters.

canisters and filters have a shelf life and a use life.

AS 1715 Selection, Use and Maintenance of Respiratory Protective Devices

AS 1716 Respiratory Protective Devices