HAZCHEM ALERT: do you need to monitor the health of your workers?

Mar 16, 2020 Posted by Walter Ingles

If you use or store any type of hazardous chemicals at your workplace you may be required to monitor the health of your workers.

This blog provides a quick introduction to health monitoring and outlines your overall responsibilities. The need for health monitoring is usually triggered by the use of certain high-risk substances (eg, carcinogens) or if chemical exposure levels could fall outside of air-borne exposure standards (eg, during a spill or decanting). You’ll need a risk management approach to ensure you meet your obligations.

REMEMBER: Keeping chemicals in compliant chemical safety cabinets and stores is essential for maintaining airborne exposure standards. You should also be implementing and enforcing good housekeeping practices around your chemical stores.

What is health monitoring?

Health monitoring is a way of identifying if a person’s health has been affected by exposure to chemicals in the workplace. As an employer, you have a responsibility to monitor the health of workers at high-risk of chemical exposure and can be fined up to $30,000 for each offence if you do not.

If health monitoring is required, it must be carried out under the supervision of a registered medical practitioner who is qualified and experienced in workplace health monitoring. You will be using a combination of the following procedures:

  • Interview questions - hazardous chemicals affect individuals differently so learning more about a worker’s lifestyle habits (smoking, drinking, exercise) , medical history (allergies, illnesses), and work practices (hygiene, PPE) can be helpful. Even knowing where an employee eats their lunch and if they wash their hands can prove useful in establishing exposure levels.

  • Medical examinations - testing for certain illness and medical conditions using lung tests, chest x-rays, etc.

  • Biological tests - evaluating blood samples, urine tests, and other body tissue to determine the levels of chemicals and their metabolites.

Workers must not be out of pocket for undergoing health monitoring medical tests. The business owner/employer must pay for all expenses including:

  • Practitioner fees (eg, doctors, specialists, occupational hygienists)

  • Laboratory tests and analysis fees (eg, x-rays, blood tests, urine samples)

  • Out-of-pocket expenses (eg, wages, travelling time, accommodation)

REMEMBER: Health monitoring focuses only on the physical condition of your workers and does not involve testing air quality or monitoring chemical exposure levels — use those actions to determine the risk to your workers.

Deciding if there is a significant risk to your workers

You don’t need to monitor the health of every worker at every job site unless there is a demonstrated risk to their health and safety. A risk assessment that identifies high-risk chemicals and assesses exposure levels will be your best approach. The following situations at your workplace will always trigger the need for health monitoring:

  • Scheduled chemicals - if you use any chemicals listed in Schedule 14 of the WHS Regulations you must implement health monitoring. The schedule includes chemicals like asbestos, lead, mercury, and a range of pesticides that are known for their carcinogenicity, germ cell mutagenicity, and reproductive toxicity.

  • Air monitoring tests - an air quality test indicates constant or high levels of air-borne chemicals in the breathing zones of workers.

  • Risk assessments - a risk assessment indicates a worker is at high risk of chemical exposure. Risk assessments focus on the toxicity and hazard class of the chemicals, and balances that against the quantities being handled/stored, and the daily work practices of employees. This includes how they use PPE and the duration of shifts and tasks involving the chemicals.

  • Reported symptoms in workers - workers report (or are observed) with symptoms or health conditions associated with the hazardous chemicals being used.

EXAMPLE: You conduct a risk assessment on a cluster of workers who handle flammable liquids in the warehouse and chemical stores. Every day these employees receive packaged flammable liquids from delivery trucks, transfer the packaged chemicals to chemical stores, clean up spills when packs are dropped or broken, then decanting the chemicals into portable containers when requested by work teams on the production floor.

Your risk assessment would include (as a minimum) evaluating the chemical hazards, (eg, toxicity, workplace exposure standards) from the Safety Data Sheets, consulting with workers and supervisors to determine the average daily exposure times, the types of PPE they are wearing, the effectiveness of the packaging and chemical stores in containing vapours and fumes, the frequency and concentration level of chemical spills.

Implementing health monitoring vs hazard control

It is important to remember that health monitoring is NOT a chemical control measure, it is a tool to identify if your existing control measures are working effectively. If a health test indicates unacceptable exposure levels you must introduce controls to make the workplace safe or stop using the chemical.

IMPORTANT: If you do need to provide health monitoring to a worker you must tell them about the medical tests and monitoring BEFORE they start working with the chemicals. There are also mandatory requirements for record keeping.

Next steps

Health monitoring is an essential requirement under Division 6: Health Monitoring in Australian WHS Regulations and to be carried out effectively, requires the understanding and implementation of a risk management methodology. Downloading our free eBook How to manage the risk of Hazardous Chemicals in the workplace for detailed instructions about incorporating health monitoring into STEP 4 of your risk management plan. 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 Storage Specialist. He helps organisations reduce risk and improve efficiencies in the storage and management of dangerous goods and hazardous chemicals.

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