EHS-005 Hazardous Chemical Substance Management

This procedure is designed for Hazardous Chemical Substances Management.  It is also designed to ensure that any potential risks associated with the use of such materials are controlled and employees who use them are aware of the health risk and safety precautions for use.

Procedure

1.            New Chemical – Approval for Use

1.1.         Persons wishing to introduce new chemical substances into the Business, whatever their intended purpose, shall obtain a current Material Safety Data Sheet (MSDS) from the supplier.  The MSDS shall comply with the regulatory format and contain all necessary information relevant to the chemical.

1.2.         A ‘Request for New Chemical Approval’ form refer to Form-420, shall be completed by the person making the request and attach a copy of the current MSDS.  Both documents shall be forwarded to the EHS Manager.

1.3.         Upon receipt of the forms, the EHS Manager shall convene a meeting and forward copies of the documents to each member of the EHS Committee prior to the meeting.

1.4.         At the meeting the committee members will assess the chemical substance in accordance with the manufacturers instructions for use, requirements of local regulations.

1.5.         At the completion of the assessment, the EHS Manager shall notify the person making the request in writing that:

Approval has been granted conditional to any necessary controls being put in place, using the ‘New Chemical Approval Certificate” – see Form-470;

Or

Approval has not been granted, citing the reasons why the decision was reached – using “New Chemical Rejection Advice” form, see Form-480.

1.6.         If approved, the chemical substance cannot be used until all necessary controls are in place and all personnel who will use or be exposed to the chemical substance are advised of the results of the assessment and any necessary precautions.  A copy of the New Chemical Approval Certificate shall be sent to the relevant Line Manager, where applicable and the Procurement Manager for registering on their list.

1.7.         If approval is not granted, the person requesting approval has the opportunity to discuss the need for the chemical substance at a further meeting with the EHS committee.  Other internal and outside experts such as Occupational Physicians, Occupational Hygiene Consultants, and appropriate Engineers may be required at this stage to help in any further assessment.

1.8.         If the chemical substance is approved, it shall be assigned an approval number and entered into the Chemical Substance Approval Register by the EHS staff.

1.9.         All documentation of the assessment process shall be kept in the Chemical Substance Assessment Register.

2.            Assessment Process for Hazardous Chemical Substances

2.1.         Personnel

2.1.1.    The EHS Manager shall co-ordinate the assessment programme and the EHS committee will assist in conducting work place assessments.  Other members of the assessment team include the Laboratory Manager or their delegate and any other person(s) deemed appropriate by the EHS committee.

2.1.2.     All persons nominated to conduct an assessment shall be appropriately trained and qualified.

2.2.         Registry

2.2.1.     A register of all chemicals and hazardous chemical substances shall be prepared and maintained by the EHS staff.  This shall include raw materials, finished products, consumable chemicals, aids to manufacture, wastes and laboratory chemicals. The register should identify the location where the material is used.

2.2.2.     A list of chemicals to be found in each work area shall be prepared (and maintained).

2.2.3.     MSDS’s of each hazardous chemical substance shall be readily accessible to all employees who may reasonably use or come into contact with the chemical substance.

2.2.4.     The register shall contain details of the assessment; identify the location of the material and when an assessment was completed.

2.3.         Assessment

2.3.1.     Assessments may be based on proposed or existing individual chemical substances or by process. Where assessments are based on a process, the most toxic chemical substance used in that process shall be used as the model throughout the assessment.

2.3.2.     There shall be a formal process of assessment for all tasks and areas using hazardous chemical substances. This assessment will evaluate the physical, chemical and toxicological properties after consideration of the proposed or likely use.

2.3.3.     Where an identical process or procedure using the chemical substance is undertaken in a number of locations, a single generic assessment may be done and the controls then introduced in all locations.

2.3.4.     Where an examination of the MSDS and the workplace using the chemical substance concludes there is no risk to health, then it shall be recorded as a “simple and obvious” assessment and documented in the Hazardous Chemical Substance Register.

2.3.5.     Where the assessment is not a “simple and obvious” outcome then the assessment maybe undertaken with the assistance of the “Hazardous Substance Checklist” Form, see Form-525. Copies of all completed risk assessments are to be provided to the EHS staff for record keeping.

2.3.6.     Where the assessment finds there is evidence of either acute or chronic health effects as a result of the current exposure level to hazardous chemical substances, or the assessor is unsure, a quantitative evaluation shall be made by a Consultant Occupational Hygienist.

2.3.7.     Assessments shall be reviewed at least every five years, or when new toxicological information is received, or when the process is changed.

2.3.8.     The EHS committee shall advise of any chemicals requiring priority assessment.

2.4.         Controls

2.4.1.     The design and implementation of all controls shall be in accordance with SOP EHS-010 and follow the strategy of the Controls Treatments.

2.4.2.     There shall be routine inspection and maintenance of all Hazardous Substances control systems.

2.4.3.     Standard Operating Procedures shall contain specific instructions for exposure control that are consistent with the assessment and requirements of the chemical substance.

2.5.         Records

2.5.1.     All records of assessments indicating the need for atmospheric monitoring or health surveillance, and records of the results of any atmospheric monitoring or health surveillance shall be kept for 30 years from the last entry date in the assessment record.

2.5.2.     Where the assessment does not indicate the need for exposure monitoring or medical surveillance, they shall be kept for five years.

2.5.3.     All records of induction or other Hazardous Substances training given to persons potentially exposed to workplace hazardous chemical substances and their Managers shall be kept for at least 5 years from the training date.

2.6.         Training

2.6.1.     All assessors shall undertake appropriate training.

2.6.2.     All persons potentially exposed to workplace hazardous chemical substances and their managers shall receive training and instruction on the chemical substances and the necessary controls.  This shall occur at induction, job transfer or when a change in chemical usage occurs / new chemical is introduced.

2.6.3.     Re-training of personnel associated with the process shall occur when:

New toxicological information is available;

New MSDS is published;

Changes are made to materials handling equipment;

New control measures are installed, (e.g. Local Exhaust ventilation).

Significant changes in chemical usage occurs or when a new chemical is Introduced.

3.            Material Safety Data Sheet Management

3.1.         Register

A list of chemicals used in the workplace and copies of MSDS shall be available at the workplace from an MSDS Register.

3.2.         MSDS Preparation

MSDS should be prepared in the following priority order.

3.2.1.     All MSDS shall conform to the local regulatory Code of Practice for the preparation of Material Safety Data Sheets.

3.2.2.     The classification of substances shall conform to the local regulatory Code of Practice for the Control of Workplace Hazardous Substances and approved criteria for classifying hazardous substances.

3.2.3.     A MSDS shall be available for every product and intermediate product listed on the designated hazardous substances register traded or produced by Site.

3.2.4.     A MSDS shall be prepared for all materials that are relabelled, or repacked, and/or sold as a product.

3.2.5.     A MSDS, which conforms to this procedure, should be available to all employees for all raw materials used in the workplace.

3.2.6.     A MSDS shall be prepared for all listed hazardous wastes handled by employees, contractors, or to which the general public may become exposed

3.2.7.     A MSDS, which conforms to this procedure, shall be available to employees for all consumable chemicals, aids to manufacture, catalysts or laboratory chemicals.  Where the supplier’s MSDS does not conform to this procedure, then an MSDS shall be prepared.

3.3.         MSDS Maintenance and Records

3.3.1.     All MSDS shall be no more than five years old.

3.3.2.     MSDS shall be available in a MSDS Register.

3.3.3.     All superseded MSDS records shall be kept for at least 10 years.

3.4.         MSDS Supply to Customers and Authorities

3.4.1.     MSDS for manufactured products (hazardous and non-hazardous) shall be supplied to customers as legally required.

4.            Elements of a Hazardous Substance Induction & Training Programme

An induction and training programme to meet the requirements of the handing Hazardous Chemical Substances must include the following elements.  This training must be provided to:

Those employees whose work potentially exposes them to hazardous chemical substances;

Those employees who are managing others who are using hazardous chemical substances at work.

The elements of the training should include the following:

(a)    The labelling of containers of hazardous chemical substances, the information that each part of the label provides and why the information is being provided;

(b)   The availability of MSDS for hazardous chemical substances, how to access the MSDS and the information that each part of the MSDS provides;

(c)    Information about hazardous chemical substances to which employees are or may be exposed too in the course of their work (information should include the nature of the hazards, risks to health arising from exposure.  The degree of exposure and routes of entry of the hazardous chemical substances into the body);

(d)   The assessment programme and how the employee can contribute;

(e)    The work practices and procedures to be followed in the use, handling, processing, storage, transportation, cleaning up and disposal of hazardous chemical substances;

(f)    The measures used to control exposure to hazardous chemical substances, including any information that the employee requires for the correct use and maintenance of control measures;

(g)   The proper use and fitting of personal protective equipment;

(h)    The procedure to be followed in case of emergency involving hazardous chemical substances, including any decontamination procedures to be followed;

(i)     First-aid incident reporting procedures to be followed in case of injury or illness;

(j)     The nature, and reasons for, any monitoring required and access to the results of monitoring;

(k)    The nature of, and reasons for, any health surveillance required in order to detect the effects of exposure to a hazardous chemical substance;

(l)     Employees are to be advised of the intention to use a new hazardous chemical substance where there is a risk of exposure during the course of their work. Employees are to also be consulted in the process of assessing a hazardous chemical substance;

(m)   Suppliers, employers and employees duties under the Hazardous Chemical Substances Regulations.