3 Common Mistakes When Implementing HAZCHEM Control Measures

Whether you’re installing a chemical safety cabinet or laying down floor bunding, it’s vital that your HAZCHEM control measures are effective. To help you understand the importance of implementing hazardous chemical control measures in the correct way, we’ve listed some of most common mistakes we’ve seen in the workplace.

REMEMBER: Your WHS responsibilities are explained in the WHS Regulations as well as Codes of Practice including Managing risks of hazardous chemicals in the workplace. Connect with your local regulator to find out more about WHS laws in your state or territory.

What is a HAZCHEM Control Measure?

A HAZCHEM risk control is a measure put in place to eliminate (or minimise) the level of harm associated with a chemical hazard.

Examples of HAZCHEM control measures could be using chemical-resistant goggles while decanting corrosive liquids, keeping paints and solvents in a dedicated flammable liquids cabinet, or placing your IBCs onto bunded pallets.

Mistakes can be made in the workplace, which can compromise the safety of hazardous chemical control measures.

Hierarchy of Control WHS

WHS control measures are those which meet health and safety requirements and offer effective protection against chemical hazards. There are many levels of controls, which are explained in the Hierarchy of Controls.

By following the Hierarchy of Control, through the process of elimination, substitution, engineering controls, administrative controls and personal protective equipment, you can systematically reduce the risk of hazardous chemicals in your workplace.

For example, some WHS control measures may be:

1. Eliminate hazardous chemicals in the workplace
2. If this is not possible, then substitute with a less harmful substance
3. Control risk with engineering controls such as spill containment, storage and ventilation systems
4. Develop administrative controls that bolster and improve the performance of your engineering controls
5. Select, issue and maintain personal protective equipment that is suitable for both the chemical and the work tasks performed by the worker

However, sometimes the best intentions don’t equal best practice – and mistakes can be made.

Mistakes to Avoid when Controlling Chemical Hazards

There are some common mistakes that we see in workplaces who are looking to control the hazards created by hazardous chemicals and dangerous goods. We’ve compiled this list as a real-life example of the things you SHOULDN’T do when working towards risk reduction and chemical compliance.

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 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 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 several 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. As chemical hazards can be complex, it can be difficult to predict where they will emerge.

Here are some examples of new risks introduced after controls are implemented:

• 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 through incorrect personal protective equipment.

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 Control because they do nothing to eliminate a chemical hazard or reduce chemical exposure. We regularly see administrative controls being misused in several ways.

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

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Common Administrative Control Mistakes

Let’s unpack this topic further by using a simple example that could occur at a worksite.

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

However, there are some mistakes that could be made when attempting to control chemical risk through administrative controls. These include:

• 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.
• 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.
• Relying too much on training - another mistake we see is businesses relying too much on procedures and staff HAZCHEM 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 personal protective equipment

HAZCHEM Control Measures

To ensure that your HAZCHEM control measures are always effective, we recommend using a 4 step risk management methodology. Find out more by accessing your copy of our free eBook How to manage the risk of hazardous chemicals in the workplace, which demonstrates the methodology in practice and how you can apply it to your own workplace.