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Understanding Exposure

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Suzanne Broadbent

Suzanne Broadbent
Principal Consultant, HaS Expertise Ltd
9 Raewyn Pl, Pakuranga, Auckland
Suzanne@has-expertise.co.nz

(P29, Friday 28, Civic Room 3, 10.30)

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    Understanding Exposure Understanding Exposure Presentation Transcript

    • Understanding Exposure Suzanne Broadbent Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 1
    • Exposure to chemicals Is there a GAP in NZ?  Do companies comply with exposure standards?  Do they care?  Is there any consequence if they don’t? Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 2
    • What do we have? Legal Technical Checks Risk Test HSNO Assessment Certification Occ Hygiene ACC audits/ HSE DoL Inspect Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 3
    • This Paper  Legal requirements  The substance – HSNO  The workplace - HSE  Technical –  occupational hygiene  Risk assessment  Why are there problems?  Ways forward Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 4
    • Two Angles  The SUBSTANCE  HSNO HSNO  MSDS  Lifecycle  The Workplace  Hazards  How it is used HSE RMA  Exposure and Risk Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 5
    • HSNO – so what is it about?  The SUBSTANCE  Risk assessment  New products  Test certification  DoL  NZIHSM Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 6
    • HSNO extra bits  Regulations  Transfer gazettes  Approvals for specific substances  Group standards  Industry guidance  Chemical Safety in the Workplace Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 7
    • HSNO - exposure  No mention of occupational hygiene  No mention of monitoring of exposure  Group standard and regulations and specific substance approvals include:  Reference to exposure standard  NO requirement to carry out monitoring or assessment of whether standard is met Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 8
    • Risk and chemicals  AS/NZS ISO 31000: Risk Management  Likelihood  Consequences (severity)  Qualitative/quantitative  ERMA/EPA guideline (workplace chemical risks) focuses on this Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 9
    • GAP 1  No requirement to carry out monitoring of exposure under HSNO (although exp stds) Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 10
    • Risk Assessment Slightly Harmful Extremely Harmful Harmful Highly Trivial Tolerable Moderate Unlikely Risk Risk Risk Unlikely Tolerable Moderate Substantial Risk Risk Risk Likely Moderate Substantial Intolerable Risk Risk Risk Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 11
    • Magnitude/severity Level Description Minimal Short term, reversible, effects very people Minor Short term, reversible, small group of people Moderate Minor, irreversible effects to individuals or reversible effects to larger group (hospitalisation) Major Significant irreversible effects to individuals (hospitalisation). Reversible effects to community. Massive Significant irreversible effects to community and/or death(s). Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 12
    • The Substance – Severity?  Properties of the chemical normally used to consider types of effects and severity  HSNO classifications (simple)  WES Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 13
    • Likelihood Level Description Highly improbable Almost certain will not occur Very unlikely Only occur in very unusual circumstances Unlikely Could occur, but not during normal operation (occasional) Likely Good chance it will occur (normal operation) Highly likely Almost certain Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 14
    • EPA Small Business Guide  Chemical Safety in the Workplace for Small Businesses  Very simple guidance for small business to do risk assessment  No links to exposure assessment, occupational hygiene or monitoring of exposure Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 15
    • Risk and chemicals  A bit mixed up with chemicals  One chemical (just one…)  Various potential effects  Various possible severities  Various likelihoods – many based on exposure levels Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 16
    • Toluene in a wkplce Effect Severity Likelihood From mixing Dizziness CNS From use Memory Ongoing loss exposure Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 17
    • HSNO Risk Assessment in Workplace?  Logical, Standard, sensible approach  Looks quite simple  Actually extremely complex  Not clear about assessing exposure  Not linked in any way to exposure standards  No links with requirements under HSE Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 18
    • Is risk assessment done for workplace exposure  Rarely  We do sometimes, but most clients find it confusing – esp if we need to do monitoring as well  If we are looking at HSNO compliance (inventory etc)  EPA small business guide  Terminology not consistent with Occupational Hygiene Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 19
    • Gap 2  No real guidance on how to carry out health risk assessment under HSNO Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 20
    • HSNO – how does it ENSURE assessment of risks in workplace  Mostly through test certification processes  Sites are only required to be certified for storage and use of flammable substances  Sites on budget  Do requirements for flammables FIRST Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 21
    • Gap 3  No prioritisation of health risks as no test certificate required  No checking of compliance Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 22
    • HSE  Workplace  Hazards  Assessment is about consequence (serious harm) Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 23
    • Gap 4  Our workplace – HSE legislation does not include assessment of risks Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 24
    • HSE Act  Is occupational hygiene required under HSE  Is exposure monitoring?  Section 10, (2) c:  “monitor the employees’ exposure to the hazard”  Interpretation issues Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 25
    • HSE Act – other requirements  WES 2011  MOSHH - 1997  Good, clear guidance and links to exposure monitoring and occupational hygiene  Unclear whether current  Most employers never heard of these Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 26
    • Gap 5  Misinterpretation of requirements under HSE for monitoring and lack of awareness of extra information Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 27
    • How is compliance with HSE encouraged?  Information  Inspections  ACC audits (indirect)  Incident investigations Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 28
    • Gap 6  Limited checks on compliance with HSE requirements for monitoring significant hazards Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 29
    • Occupational Hygiene  Based on risk assessment principals  Identification, evaluation and control of health risks in the workplace  Focus on exposure with clear links to exposure standards (where relevant) Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 30
    • Occ Hyg basis in risk assessment  Hazard identification  Dose response relationship (and establishment of exposure guideline)  Exposure assessment (usually monitoring)  Assessment of health risk Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 31
    • Occupational Hygiene  NZOHS  International profession re-enforced by clear legal requirements  Not so much in NZ Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 32
    • Gap 7  Occupational hygiene is not really a recognised profession in NZ  ZERO occupational hygienists at ERMA/EPA  Few at DoL Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 33
    • Summary  Occupational hygiene and exposure standards are simpler than full risk assessment  Simplistic risk assessment process does not give any realistic assessment of exposure (guesswork)  Hazard assessment not useful  Current systems emphasis hazardous properties and not exposure  Performance based legn needs checks Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 34
    • What do we have? Legal Technical Checks Risk Test HSNO Assessment Certification Occ Hygiene ACC audits/ HSE DoL Inspect Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 35
    • The positive?  Lots of information/legal requirements - confusing  Great system for identify types of hazards (HSNO classifications)  MOSHH (the old one)  Test certification for flammables  Training of approved handlers under HSNO  Commitment to improve (DoL), agenda Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 36
    • The gaps  Nothing in ANYTHING that people understand as clearly requiring exposure assessment  HSNO - risk, HSE - workplace  Limited checks in place under HSNO or HSE to establish level of compliance  Profession (occupational hygiene) not well developed with very limited training opportunities Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 37
    • The Real NZ  Number eight wire  If it is not clearly legally required, we don’t have to do it (Tamahere)  If it is not checked in any way, it is not a priority (Pike River)  If our competitor doesn’t do it..  Especially if it costs money…  If it is not a priority, it doesn’t get done Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 38
    • Is there any hope for our HS workers?  New initiatives - DoL  HSNO - first ever (known) case of a substance with test certification requirements for a substance that was not flammable (toxic)  Push by certifiers to include toxics (tho not occupational hygiene)  Can we get some sort of certification for exposure assessment?  NZOHS working on growth Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 39
    • How does HaS Expertise do stuff  Risk based approach – using dose-response and exposure estimate to determine where/what to monitor  Links to control banding methodology, severity linked to NZ HSNO classifications  Occupational hygiene, exposure standards and monitoring Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 40
    • How to move forward  NZOHS  Closer alignment with Australia  Training course development  New strategies/action planning with DoL  Need for closer links with ERMA/EPA and test certifiers  Working together to eliminate the gaps and overlaps Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 41
    • Test Cert for Class 6?  Emergency plan  Signage  Notification for new facilities  Restricted access + AH  Separation to boundary  Equipment  PPE available  WES are monitored and complied with Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 42
    • Case studies  Workplaces  Timber treatment site (one chemical)  Bakery (flour, hydroxide mist, chlorine, ammonia, noise) Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 43
    • NZ HaSNO Exposure Assessment Powerpoint TemplatesPrepared for OHSIG conference Oct 2011 by ExposureSuzanne Broadbent Slide Number: 44