Understanding Exposure

Understanding
Exposure
Suzanne Broadbent

Powerpoint Templates
Prepared for OHSIG conference Oct 2011 by Exposure
Suzanne Broadbent Slide Number: 1

Exposure to chemicals
Is there a GAP in NZ?
 Do companies comply with exposure
standards?
 Do they care?

 Is there any consequence if they don’t?


What do we have?
Legal Technical Checks

Risk Test
HSNO
Assessment Certification

Occ Hygiene ACC audits/
HSE
DoL Inspect


This Paper
 Legal requirements
 The substance – HSNO
 The workplace - HSE
 Technical –
 occupational hygiene
 Risk assessment

 Why are there problems?
 Ways forward

Two Angles
 The SUBSTANCE
 HSNO HSNO
 MSDS
 Lifecycle
 The Workplace
 Hazards
 How it is used
HSE RMA
 Exposure and Risk


HSNO – so what is it
about?
 The SUBSTANCE
 Risk assessment
 New products

 Test certification
 DoL
 NZIHSM


HSNO extra bits
 Regulations
 Transfer gazettes
 Approvals for specific substances
 Group standards

 Industry guidance
 Chemical Safety in the Workplace


HSNO - exposure
 No mention of occupational hygiene
 No mention of monitoring of exposure
 Group standard and regulations and specific
substance approvals include:
 Reference to exposure standard
 NO requirement to carry out monitoring or
assessment of whether standard is met


Risk and chemicals
 AS/NZS ISO 31000: Risk Management
 Likelihood
 Consequences (severity)
 Qualitative/quantitative

 ERMA/EPA guideline (workplace chemical
risks) focuses on this


GAP 1
 No requirement to carry out monitoring of
exposure under HSNO (although exp stds)


Risk Assessment
Slightly Harmful Extremely
Harmful Harmful
Highly Trivial Tolerable Moderate
Unlikely Risk Risk Risk
Unlikely Tolerable Moderate Substantial
Risk Risk Risk
Likely Moderate Substantial Intolerable
Risk Risk Risk


Magnitude/severity
Level Description

Minimal Short term, reversible, effects very people

Minor Short term, reversible, small group of people

Moderate Minor, irreversible effects to individuals or reversible
effects to larger group (hospitalisation)
Major Significant irreversible effects to individuals
(hospitalisation). Reversible effects to community.
Massive Significant irreversible effects to community and/or
death(s).


The Substance –
Severity?
 Properties of the chemical normally used to
consider types of effects and severity

 HSNO classifications (simple)
 WES


Likelihood
Level Description

Highly improbable Almost certain will not occur

Very unlikely Only occur in very unusual circumstances

Unlikely Could occur, but not during normal operation
(occasional)
Likely Good chance it will occur (normal operation)

Highly likely Almost certain


EPA Small Business
Guide
 Chemical Safety in the Workplace for Small
Businesses
 Very simple guidance for small business to do
risk assessment
 No links to exposure assessment, occupational
hygiene or monitoring of exposure


Risk and chemicals
 A bit mixed up with chemicals

 One chemical (just one…)
 Various potential effects
 Various possible severities
 Various likelihoods – many based on exposure
levels


Toluene in a wkplce
Effect Severity Likelihood

From
mixing
Dizziness
CNS From use

Memory Ongoing
loss exposure

HSNO Risk Assessment
in Workplace?
 Logical, Standard, sensible approach
 Looks quite simple
 Actually extremely complex

 Not clear about assessing exposure
 Not linked in any way to exposure standards
 No links with requirements under HSE


Is risk assessment done
for workplace exposure
 Rarely
 We do sometimes, but most clients find it
confusing – esp if we need to do monitoring as
well
 If we are looking at HSNO compliance
(inventory etc)
 EPA small business guide
 Terminology not consistent with Occupational
Hygiene

Gap 2
 No real guidance on how to carry out health
risk assessment under HSNO


HSNO – how does it
ENSURE assessment of
risks in workplace
 Mostly through test certification processes

 Sites are only required to be certified for
storage and use of flammable substances
 Sites on budget
 Do requirements for flammables FIRST


Gap 3
 No prioritisation of health risks as no test
certificate required
 No checking of compliance


HSE
 Workplace
 Hazards
 Assessment is about consequence (serious
harm)


Gap 4
 Our workplace – HSE legislation does not
include assessment of risks


HSE Act
 Is occupational hygiene required under HSE
 Is exposure monitoring?

 Section 10, (2) c:
 “monitor the employees’ exposure to the
hazard”
 Interpretation issues


HSE Act – other
requirements
 WES 2011
 MOSHH - 1997

 Good, clear guidance and links to exposure
monitoring and occupational hygiene
 Unclear whether current
 Most employers never heard of these


Gap 5
 Misinterpretation of requirements under HSE
for monitoring and lack of awareness of extra
information


How is compliance with
HSE encouraged?
 Information
 Inspections
 ACC audits (indirect)
 Incident investigations


Gap 6
 Limited checks on compliance with HSE
requirements for monitoring significant
hazards


Occupational Hygiene
 Based on risk assessment principals
 Identification, evaluation and control of health
risks in the workplace
 Focus on exposure with clear links to exposure
standards (where relevant)


Occ Hyg basis in risk
assessment
 Hazard identification
 Dose response relationship (and
establishment of exposure guideline)
 Exposure assessment (usually monitoring)
 Assessment of health risk


Occupational Hygiene
 NZOHS
 International profession re-enforced by clear
legal requirements
 Not so much in NZ


Gap 7
 Occupational hygiene is not really a
recognised profession in NZ
 ZERO occupational hygienists at ERMA/EPA
 Few at DoL


Summary
 Occupational hygiene and exposure standards
are simpler than full risk assessment
 Simplistic risk assessment process does not
give any realistic assessment of exposure
(guesswork)
 Hazard assessment not useful
 Current systems emphasis hazardous
properties and not exposure
 Performance based legn needs checks

What do we have?
Legal Technical Checks

Risk Test
HSNO
Assessment Certification

Occ Hygiene ACC audits/
HSE
DoL Inspect


The positive?
 Lots of information/legal requirements -
confusing
 Great system for identify types of hazards
(HSNO classifications)
 MOSHH (the old one)
 Test certification for flammables
 Training of approved handlers under HSNO
 Commitment to improve (DoL), agenda

The gaps
 Nothing in ANYTHING that people understand
as clearly requiring exposure assessment
 HSNO - risk, HSE - workplace
 Limited checks in place under HSNO or HSE to
establish level of compliance
 Profession (occupational hygiene) not well
developed with very limited training
opportunities


The Real NZ
 Number eight wire
 If it is not clearly legally required, we don’t
have to do it (Tamahere)
 If it is not checked in any way, it is not a
priority (Pike River)
 If our competitor doesn’t do it..
 Especially if it costs money…
 If it is not a priority, it doesn’t get done

Is there any hope for our
HS workers?
 New initiatives - DoL
 HSNO - first ever (known) case of a substance
with test certification requirements for a
substance that was not flammable (toxic)
 Push by certifiers to include toxics (tho not
occupational hygiene)
 Can we get some sort of certification for
exposure assessment?
 NZOHS working on growth

How does HaS Expertise
do stuff
 Risk based approach – using dose-response
and exposure estimate to determine
where/what to monitor
 Links to control banding methodology,
severity linked to NZ HSNO classifications
 Occupational hygiene, exposure standards and
monitoring


How to move forward
 NZOHS
 Closer alignment with Australia
 Training course development
 New strategies/action planning with DoL
 Need for closer links with ERMA/EPA and test
certifiers
 Working together to eliminate the gaps and
overlaps

Test Cert for Class 6?
 Emergency plan
 Signage
 Notification for new facilities
 Restricted access + AH
 Separation to boundary
 Equipment
 PPE available
 WES are monitored and complied with

Case studies
 Workplaces
 Timber treatment site (one chemical)
 Bakery (flour, hydroxide
mist, chlorine, ammonia, noise)


NZ HaSNO Exposure
Assessment


Understanding Exposure

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