How To Control Chemicals Hazardous To Health Effectively

Regulation 14(1) of the Occupational Safety and Health (Use and Standards of Exposure of Chemicals Hazardous to Health) Regulations 2000 (USECHH 2000) requires employers to take the necessary actions to eliminate or reduce the actual or potential exposure of employees to chemicals hazardous to health (CHTH).

These actions may include modifications to work processes, practices, procedures, plants, or the installation of engineering controls. These measures must be implemented within one month of receiving a Chemical Health Risk Assessment (CHRA) report.

Under Regulation 14(2) of USECHH 2000, employers must ensure that the control measures implemented reduce the exposure level of employees to CHTH to the lowest practicable level. For chemicals with assigned permissible exposure limits (PEL), the concentrations of the chemicals must be reduced below these limits.

Additionally, employers are also responsible for ensuring that all safe work systems and practices are documented, implemented, and reviewed whenever there are significant changes to the processes, equipment, materials, or control measures.

What are Hierarchy of Controls

The hierarchy of controls provides a systematic approach to managing exposure to CHTH. Employers should first consider whether CHTH or hazardous processes can be eliminated.

If this is not practicable, each subsequent control measure (substitution, isolation, engineering controls, safe work systems, and personal protective equipment) should be evaluated until an effective control measure or combination of control measures is identified to achieve the required reduction in exposure.

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Eliminate It For Good

Elimination involves permanently removing CHTH or hazardous processes from the workplace. Elimination should be implemented whenever the use of CHTH is not essential to the work activity or process.

Examples:

  • Using a mechanical or physical process to clean an object, such as ultrasonic cleaning instead of a chemical process.
  • Replacing adhesives with clips, clamps, or bolts.
  • Purchasing materials pre-cut or pre-shaped to avoid dust-producing cutting processes on site.

Substitute It With Less Harmful Alternatives

Substitution involves replacing CHTH or hazardous processes with less hazardous alternatives. Substitution should be strongly considered for carcinogens, reproductive toxins, allergens, and neurotoxins due to the difficulty in ensuring safe exposure levels with traditional controls such as personal protective equipment (PPE), industrial ventilation, or encapsulation.

Examples:

  • Replacing chlorinated degreasing solvents with detergents.
  • Using water-based paints instead of organic solvent-based paints.
  • Using paste or pellet forms of chemicals instead of powders.
  • Applying paint by brush rather than aerosol spray.
  • Using dip-coating instead of spray painting.

Isolate the Workers from It

Isolation involves separating workers from the source of exposure by distance, enclosures, barriers, or automated systems.

Examples:

  • Separating toxic or flammable tank farms away from process areas.
  • Using automated systems in chemical processing.
  • Installing heat shields.
  • Separating control rooms from hazardous operation areas.

Install Engineering Controls

Engineering controls are plants, processes, or equipment that aim to minimise the creation, release, or spread of CHTH. Types of engineering controls include full or partial enclosure of hazardous processes, local exhaust or general ventilation systems, process automation, and suppression methods such as water sprays.

Examples:

  • Ventilated spray booths.
  • Robotic welding systems.
  • Local exhaust ventilation attached to grinding machines.
  • Automated removal of items from degreasing baths.
  • Closed reaction vessels.

Implement Safe Work System

A safe work system is a formal work procedure based on a systematic hazard assessment. It defines safe working methods to ensure hazards are eliminated or risks are minimised.

A safe work system integrates workers, machinery, and materials to establish safe working conditions and forms part of the employer’s general duties under Section 15 of the Occupational Safety and Health Act 1994. At the workplace, a safe work system comprises fully documented hazard precautions and safe working conditions that are used in job training. 

Provide Adequate Personal Protective Equipment (PPE)

PPE is considered as a “last resort” or “last line of defence” as it is less reliable due to challenges in ensuring consistent and correct use. PPE should only be used when other control measures are impracticable or as supplementary protection. For PPE to be effective, it must be worn properly and continuously during exposure-prone tasks.

Situations where PPE may be necessary:

  • When achieving adequate control through other means is not technically feasible.
  • During temporary or emergency conditions, such as plant failures.
  • During infrequent maintenance work where other controls are less practicable.