A risk assessment is not a ‘one-time’ exercise and 100% chemical compliance will require you to review and monitor each of the chemical hazards at your workplace — plus any control measures you have implemented. Risk monitoring and review is usually a combination of regular maintenance, audit inspections, and follow-up risk assessments. This blog looks at some of the factors that determine how often you should conduct these reviews to keep your workplace safe and compliant.
REMEMBER ‘You must review and, as necessary, revise control measures so as to maintain, so far as is reasonably practicable, a work environment that is without risks to health or safety.’
Section 38: WHS Regulations
1. High risk chemical hazards exist
The whole point of a risk assessment is to help you create a workplace or job site where people and the environment are kept safe from harm. A HAZCHEM risk assessment identifies chemical hazards and assesses their likely impact at the workplace — so of course another risk assessment must carried out if you increase the amount of chemicals you hold onsite, or you have a near-miss/close-call incident. But if your workplace has a number of high risk chemical hazards you should also program regular risk assessments even if everything appears ‘situation normal’.
For example if you have:
- High risk chemicals that are acutely toxic, reactive, explosive, or carcinogenic.
- A large job site with a lot of intercorrelated areas, visitors and traffic, chemical exposure points.
- Chemical hazards that have been flagged in a previous risk assessment with a high likelihood of occurring.
- A history of incidents involving hazardous chemicals.
- Heavy turnover of trained personnel.
There really isn’t a magic formula for how often a follow up risk assessment should be done, the frequency you choose (once a month, once a quarter etc) will be determined by the size and complexity of worksite, and the severity of hazards.
A follow up (or review) risk assessment works in the same way as your initial assessment. First you identify new chemical hazards that were not previously identified, then you look at the existing hazards and possibly expand your definition of them.
2. Issues arise during testing and monitoring
Chemical hazard controls require follow-up testing and monitoring to ensure that each hazard has been completely eliminated or adequately minimised. Ways to test and monitor chemical safety include:
- Checking if chemical control measures are working in the way you planned - is new machinery or equipment operating properly? Are workers following new safety procedures? Have any new hazards emerged? Is the work area safer?
- Monitoring overall chemical safety at the job site - is the frequency of dangerous incidents reducing? Is the severity of HAZCHEM incidents also reducing?
- Carrying out scenario testing and drills - are workers able to effectively respond to a simulated chemical emergency? Are they confident in their roles and level of training?
- Preventative maintenance and inspections - hazardous chemicals can deteriorate bunds and containers quickly, are there any issues with the integrity and usability of chemical stores, safety cabinets, machinery, decanting systems, bunding, mechanical aids?
Compliance breaches, new hazards, or issues uncovered during testing and monitoring would trigger another risk assessment, but the testing and monitoring should be ongoing.
3. Requests during workplace consultation
A risk assessment can be requested by your Safety Committee or by WHS Representatives if they believe that a chemical control measure is insufficient or a hazard exists that has been properly identified. But we recommend not waiting until something goes wrong to consult with your workers and contractors about chemical hazards. The workers actually using the chemicals and applying the hazard control measures are in the best position to determine their practicality and effectiveness.
During the consultation process we recommend discussing and reviewing:
- Work procedures for chemical handling, decanting, transfer and storage.
- PPE suitability and effectiveness.
- Practicality of emergency procedures including the layout and usability of emergency showers and eyewash stations.
- State of workplace hygiene and the effectiveness of housekeeping procedures.
- Level of competency and training of line staff and floor supervisors.
After consulting with your staff you might decide to conduct a single risk assessment or appoint a team to schedule a series of follow ups.
REMEMBER: ‘The person conducting a business must consult with the workers who are likely to be directly affected by a matter relating to work health or safety.’
Section 47 WHS Act
If you need some guidance materials to help you carry out a risk assessment (or review an earlier assessment) we invite you to download our free eBook How to manage the risk of hazardous chemicals in the workplace. We walk you through our 4-step risk management methodology IDENTIFY - ASSESS - CONTROL - SUSTAIN and provide you with a clear system to ensure all the chemical hazards at your workplace are properly managed.