HAZCHEM Safety: when do you need to review your chemical control measures?

Feb 19, 2019 Posted by Walter Ingles

You’ve been through the workplace and identified each of the chemical hazards. You took action to ensure that every hazard was thoroughly evaluated; assessing the potential to cause dangerous incidents, death, or injury. You introduced chemical control measures — things like ventilation systems, dedicated chemical stores, PPE, emergency showers — and in some cases you completely eliminated the hazard. What now? Are your WHS responsibilities finished?

This blog takes a closer look at the review process, because you must undertake as many reviews as necessary to maintain a safe work environment. Whenever chemical hazards are present at a worksite you have a WHS obligation (even if you don’t know a hazard exists). And sometimes it takes a safety review to uncover an unknown hazard that is making your workers sick and has the potential to cause long term damage or other unnecessary suffering.

What is a chemical hazard review?

A chemical hazard review is simply a series of actions that actively monitor a chemical hazard and any introduced control measures to make sure the controls are working and exposure to the chemical is minimised or completely eliminated.

You can use a wide range of tools to conduct a chemical hazard review including:

  • Physical inspections, observations, and safety audits.

  • Chemical exposure assessments and testing.

  • Accident, incident, injury and illness reviews and tracking.

  • Employee consultation, input, and feedback.

The review process presents a series of questions, but we feel these three are the most important. First: have the controls adequately contained the risk and solved the problem? Second: have any new hazards been created? Third: What else could be done?

Reviews triggered by incidents

As much as you try to be proactive when implementing risk controls, many times a chemical hazard review is conducted in only after a workplace accident, incident, or illness has occurred. Sometimes concerned workers will be the ones to request a review as new relevant hazards are identified. A review would also be needed after the following incidents:

  • Test results indicate that a worker has an unacceptable level of chemical particles or residue in their body.

  • Air monitoring indicates chemical exposure levels are above the permitted workplace exposure standards.

  • A notifiable incident occurs onsite.

  • The workplace is affected by severe weather or a damaging natural disaster.

  • Consultative teams and WHS representatives believe a review is necessary.

  • Sick leave records or other test results indicate a worker may have been injured or become ill because of the chemical hazard.

IMPORTANT: Control measures rarely work if workers are not notified of changes to their work areas or individual job tasks. You should always update your staff induction and training programs to deal with new situations.

Reviews triggered by change

Workplaces are dynamic and constantly evolving, so a chemical hazard review will be necessary as the workplace undergoes change. Examples include:

 Changes to operating procedures or work areas.

  • When undertaking renovations, expansions, closure or transferring the location of job site.

  • New Safety Data Sheets (SDSs) are issued for the chemicals.

  • Staff turnover, a change in management, or engagement of a new contracting company.

  • Installation of new equipment, machinery, mechanical aids, vehicles.

  • Legislation changes, Australian Safety Standards are updated, or a new Code of Practice is released.

 IMPORTANT: Chemical hazard reviews are especially important on construction, mining, manufacturing, and agricultural job sites where change is central to the way you do business.

Scheduled reviews

Even if you have had no incidents or major changes at the worksite, chemical control measures still require review — equipment deteriorates, machines and mechanical devices don’t operate with the same efficiently, PPE gets lost or broken.

So your risk management plan should already have review mechanisms in place in the form of site inspections, review audits, and preventative maintenance.  We suggest building into your risk management plan mechanisms for:

Hazard reviews based on anniversaries of chemical purchases or installation dates of safety equipment and chemical stores.

  • Reviewing each chemical hazard at least once every 5 years — Safety Data Sheets (SDSs) are always updated every 5 years.

  • Quarterly safety audits conducted by external safety consultants who specialise in hazardous chemicals and dangerous goods storage.

  • Daily site inspections by managers, supervisors and team leaders (especially before/after shift changes).

  • Holding bi-monthly meetings of the Safety Committee who discuss work procedures and concerns .

  • Scheduling quarterly maintenance and integrity testing of chemical storage containers and other safety equipment.

 TIP: Keeping accurate records of your risk assessments is important for demonstrating how you are complying with the WHS Act and Regulations. It also useful when undertaking your chemical hazard reviews.

Next steps

100% chemical safety compliance cannot be guaranteed unless your risk management plan has systems in place to ensure that chemical hazards and control measures are regularly reviewed. To learn how to introduce a 4-step risk management methodology with the necessary review mechanisms, download our free eBook How to manage the risk of Hazardous Chemicals in the workplace. It’s easy to understand and reading it won’t take all day. Download and read it now 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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