A chemical safety review audit examines chemical hazards — plus the control measures you have introduced to bring the risk to an acceptable level. This blog walks you through the hazard review process: when to conduct a review; and considerations for assessing the effectiveness of different types of control measures.
REMEMBER: Control measures that focus on worker behaviour require stringent reviews. And they rarely work if workers haven’t been properly trained, don’t feel invested in the program, or don’t understand the risks to their safety.
When to conduct a chemical safety review
Chemical safety reviews are an essential part of any risk management plan and (ideally) should be programmed into your calendar. Consider the following three ways to introduce review triggers into your chemical safety plan.
Periodic site inspections and safety audits. Have managers, supervisors, team leaders, and WHS representatives conduct site inspections; schedule preventative maintenance and integrity testing of chemical containers and safety equipment; engage external auditors and dangerous goods specialists to inspect your premises.
After accidents, incidents, or requests. Conduct chemical safety reviews to investigate notifiable incidents; or when tests indicates unacceptable airborne concentration levels. A severe weather or natural disaster might also trigger a review to ensure outdoor chemical stores have not been damaged.
Following changes at the job site. Changes to the job site can increase the level of risk. Have review triggers in place for when renovations, expansion, or relocation occurs; new equipment or storage facilities are installed; significant staff turnover; changes to work methods and safety procedures.
“The control measures you put in place should be reviewed regularly to make sure they work as planned. Don’t wait until something goes wrong.” Safe Work Australia
Reviewing individual control measures
A compliant risk management program introduces control measures according to the Hierarchy of Control (HOC). We’ve listed below some considerations for each group of control measures within the hierarchy.
1. Elimination and substitution measures
Elimination controls are the most desirable as they strive to completely remove the chemical hazard from the workplace. But you definitely need a follow up audit to know if the hazard has actually been eliminated. Here is a quick example:
You discover a chemical hazard in the lab. The lab buys raw materials and workers are creating chemical mixtures by hand for their experiments and tests. To eliminate the hazard you decide to purchase only pre-mixed chemicals, now workers are not exposed to the hazardous mixing process. BUT a safety audit determines that the purchasing officer is not ordering enough pre-mixed solution and lab staff are still mixing chemicals themselves at least once a week.
Substitution controls try to find less hazardous chemicals or work procedure. It could be using water-based detergents instead of chemical solvents. Again, a review of your control measures is essential to ensure that the ‘less-harmful’ option has not introduced any new hazards and is actually doing the job. Your review must consider:
The effectiveness of the substitute, and if it meets the technical requirements of the job or process.
Compatibility issues. Is the substitute interfering or reacting with other substances, machinery, or products used during the work process?
Is the substitute now generating any new hazardous chemicals or toxic waste products?
2. Isolation and engineering controls
Isolation controls try to separate workers from chemicals, but in many cases can only reduce the amount of people actually exposed. Isolation equipment like ‘glove boxes’ and sealed enclosures still need to be opened and accessed for maintenance and cleaning, so your hazard reviews should evaluate whether the isolation measure is actually working.
Engineering controls are mechanical devices, equipment and machinery that reduce the impact of a chemical hazard. One of the most common engineering controls are mechanical ventilation systems and LEV. Your review might involve testing breathing zones of workers, as well as carrying out preventive maintenance and cleaning hoods, ductwork, and fans.
3. Administrative controls
Administrative controls are the work methods, operating procedures and staff training programs that focus on chemical safety. They are essential but only effective and reliable if followed up with adequate supervision and regular reviews.
To review administrative controls you would be conducting safety audits and inspections that have checks for things like:
Unauthorised staff and contractors enter restricted areas.
Untrained or unqualified staff handling flammable liquids.
Supervisors not providing sufficient work-rest schedules to limit the amount of time workers are exposed to chemicals.
Poor housekeeping procedures (eg, mixed classes of chemicals in safety stores, chemical containers left with the lids off).
4. Personal Protective Equipment (PPE)
As a chemical control measure, PPE is the least desirable because it only places a temporary barrier between the worker and the chemical. Regular reviews of PPE and how it is being used are absolutely essential. You need to ensure the PPE is actually offering protection and it is being used correctly. Your review should include checks for:
Damaged, broken, missing, or unhygienic PPE.
Workers using PPE that does not fit.
PPE being left lying around the worksite.
Workers taking off PPE too soon, or otherwise using it incorrectly.
REMEMBER: If you don’t provide workers with a suitable place to store their PPE, it can become lost or damaged by dust, water, and vermin.
Now you have a better understanding how the chemical hazard review process works, we recommend that you download our free eBook How to manage the risk of Hazardous Chemicals in the workplace. We’ll introduce you to a full risk management methodology and give you the tools and instructions for implementation at your own workplace. Download and read it today to get your workplace 100% chemical safety compliant.