3 common mistakes when implementing HAZCHEM control measures

May 14, 2019 Posted by Walter Ingles

A HAZCHEM risk control is a measure put in place to eliminate (or minimise) the level of harm associated with a chemical hazard. It could be having your workers use chemical-resistant goggles while decanting corrosive liquids; or keeping paints and solvents in a dedicated flammable liquids cabinet; or placing your IBCs onto bunded pallets. We’ve written this blog to help you avoid some of the most common mistakes we seen our clients making when they implement chemical control measures.

IMPORTANT: Here at STOREMASTA we apply the ‘Hierarchy of Controls’ when deciding on the most effective way to control a chemical hazard. The Hierarchy of Controls focuses on eliminating or minimising exposure to a chemical.

MISTAKE 1: transferring the hazard to a different area

The most effective way to deal with any hazard is to eliminate it completely. But it can be very difficult to completely eliminate a chemical hazard — and sometimes your find the risk has just been transferred to a different area. Let’s consider the following example.

Your laboratory conducts a daily test which requires a mixture of 2 x hazardous liquids. The mix must be done carefully as the liquids are volatile and can react violently if not prepared in the correct sequence using exact quantity ratios. Your aim is to completely eliminate the mixing hazard by purchasing pre-mixed chemicals from an external supplier. But you now have a handling and storage hazard as the pre-mixed chemicals are received from suppliers and then stored until required.

The most effective way of eliminating a chemical hazard is to stop using the chemical completely. This may not always be practicable because often the only way to do this is also eliminate a number of work processes and product lines from your manufacturing and sales inventory.

MISTAKE 2: introducing new hazards

Sometimes HAZCHEM controls introduce new hazards to the workplace. Because chemical hazards can be complex it can be difficult to predict where they will emerge. Here are some examples:

  • Diluting cleaning chemicals to reduce the skin contact risk, but it now takes twice as long to get surfaces and equipment clean. The air-borne exposure risk has now been increased.
  • Changing the LPG cylinder supply company because their delivery drivers unload and carry the cylinders by hand and refuse to use forklifts and trolleys. However, the new company can only deliver once per fortnight so you need to increase the number of cylinders you keep onsite.
  • Moving your flammable liquids store outside to reduce the ventilation and fire hazard, but now the chemical store is vulnerable to impact by delivery vehicles and forklifts.
  • Issuing chemical goggles to use while decanting corrosives, but they don’t fit the workers properly and restrict vision. The risk of human error has increased.

IMPORTANT: Chemical controls should always be supported with administrative procedures and training as well as reviewed when actually in place to ensure they remain effective.

MISAKE 3: misusing administration controls

Administration controls sit near the bottom of the Hierarchy of Controls because they do nothing to eliminate a chemical hazard or reduce chemical exposure. We regularly see administrative controls  misused in a number of ways — let’s unpack that further by using this simple example.

EXAMPLE: You carry out oxy-acetylene welding at the job site which requires a cylinder of O2 and an acetylene cylinder. You are looking at ways to minimise the risk of fire, explosion, and chemicals burns.

  1. Not supporting engineering/isolation/PPE controls - the first mistake we see is businesses implementing engineering controls (eg, purchasing gas bottle trolleys and PPE) but not creating safe work procedures or providing training to support the controls. In our example above this would equate to purchasing a gas bottle trolley for the acetylene and O2 bottles but then failing to instruct workers that the cylinders must be disconnected once work is complete and stored separately in according to their hazard class.
  2. Issuing PPE without training - the next error we see is introducing a PPE control like welding goggles and then not providing any training, supervision, or enforcement. Returning to our example: you issue new chemical goggles to all your welding staff but don’t take the time to conduct a training session or provide any supervision to ensure that everyone is now wearing the new goggles and have them fitted correctly.
  3. Relying too much on training - another mistake we see is businesses relying too much on procedures and training. As a chemical control measure, administrative controls should only be used to support other controls because there is always a possibility of human error. Using our example above, training workers in efficient welding techniques and then relying on them to keep welding fume out of their breathing zone. The training would better support a mechanical ventilation system or respiratory PPE.

“Administrative controls should only be considered when other higher order control measures are not practicable, or to supplement other control measures.” SAFEWORK AUSTRALIA

Next steps

To ensure that your HAZCHEM control measures are always effective, we recommend using a four-step risk management methodology. Download our free eBook How to manage the risk of hazardous chemicals in the workplace which demonstrates the methodology in practice and explains how you can apply it to your own workplace. Download and read it today by clicking on the image below:

How to manage the risk of hazardous chemicals in the workplace

Walter Ingles

Walter Ingles Compliance Specialist

Walter is STOREMASTA’s Dangerous Goods Adviser. He loves helping businesses reduce the risk that Dangerous Goods pose upon their employees, property and the environment through safe and compliant dangerous goods storage solutions.

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