EVALUATION Audit OSHMS Requirements (FIRST REVISION) is a Malaysian Standard that provides requirements on OSHMS (and basis for the development OSH systems in an organization) 42
ACTION FOR IMPROVEMENT Process safety management Process Safety Management (PSM) is a regulation issued by the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA). The regulation is designated as OSHA 1910.119, Process Safety Management of Highly Hazardous Chemicals. Its purpose is to prevent or minimize the consequences of releasing hazardous chemicals in a facility or the environment surrounding a facility. Hazardous chemicals are those that may be toxic, reactive, flammable, explosive, or a combination of these properties. Industries handling hazardous chemicals are required to develop an effective PSM program that protects employees, contractors, and visitors of the facility Figure 2.8 PSM Element 43
Formative Question • BUILT MIND MAP OSHMS 44 EXAMPLE
45 CHAPTER 3 Chemical Safety Learning Objectives: At the end of this chapter, you should be able to: • Explain Chemical regulations under Act 514 • Discuss Safety data sheet of hazardous chemicals • Describe Register of chemicals hazardous to health in workplace Author: Mohamad Fikhri bin Nor Azman
3.1 Chemical Regulation Under Act 514 • CLASS Regulation 2013 • USECHH Regulation 2000 Where to download?? 1. Go to Official Website DOSH Malaysia 2. Click Legislation 3. Click Regulation 4. Click Regulation Under Occupational Safety and Health Act 1994 (ACT 514) 5. Click view CLASS Regulation 2013 & USECHH Regulation 2000 Figure 3.0 DOSH Website 46
• These Regulations shall apply to chemicals supplied for use at a place of work • These Regulations shall not apply to (refer Part I Section 2) : i. Radioactive Chemical ii. Schedule Waste iii. Cosmetic Product iv. Chemical used for scientific research and development, or trial v. Manufactured item, other than a fluid or particle CLASS Regulation 2013 47
CLASS Regulation 2013 (Supplier Responsibilities) Supplier Responsibilities Classification Packaging Safety Data Labelling Sheet Confidential Business Information Figure 3.1 Chemical Hazard 48
• Supplier shall classify a chemical as a hazardous chemical in accordance with the list of classified chemicals specified in Industry Code of Practice (Part 1 & 2) • The classification must be recorded. CLASS Regulation 2013 (Classification) Figure 3.2 Industry Code Of Practice 49
Packaging Requirements • (a) if the packaging is a container, the container shall be so designed and constructed so as to ensure that the hazardous chemical cannot escape unless a safety device is fitted to the container; • (b) the packaging and its fastening shall be strong and able to retain the hazardous chemical to meet the normal stress and strain handling; • (c) the materials constituting the packaging and fastening shall not be susceptible to adverse attack by the hazardous chemical or liable to form harmful or dangerous compounds with the hazardous chemical; and • (d) if the packaging is a container fitted with replaceable fastening devices, the fastening devices shall be so designed so as to ensure that the packaging may be repeatedly fastened without the hazardous chemical escaping. Seal of Packaging • A supplier shall ensure that every packaging of a hazardous chemical is initially closed with a seal in such a way that once the packaging is opened, the seal is broken and cannot be repaired CLASS Regulation 2013 (Packaging) Figure 3.3 Packaging 50
• Hazardous Chemical Labelling Information (a) the product identifier; (b) the supplier identification; (c) the signal word; (d) the hazard statement; (e) the hazard pictogram; and (f) the precautionary statement. CLASS Regulation 2013 (Labelling) • Hazardous Chemical Labelling Information (container ≤ 125ml) (a) the product identifier; (b) the supplier identification; (c) the signal word; (d) the hazard pictogram, if applicable; and (e) a statement which reads “read Safety Data Sheet before use”. 51
• Requirement For Hazard Pictogram (a) consist of a black symbol on a white background and a red border with sufficient width to be clearly visible; (b) be in a diamond shape with the sides tilted at forty-five degrees to the horizontal; and (c) be in the size of one fifteenth of the surface area of a label but not less than 100 mm². CLASS Regulation 2013 (Labelling) Figure 3.4 Hazard Pictogram 52
• A supplier may omit the information required under subregulation 13(2) or 14(3) CLASS Regulation 2013 in a Safety Data Sheet or an inventory of hazardous chemicals CLASS Regulation 2013 (Confidential Business Information) 3.2 CLASS Regulation 2013 (Safety Data Sheet) • A supplier shall furnish a Safety Data Sheet to a chemical recipient for (a) each hazardous chemical supplied; and (b) any chemical mixture containing hazardous substance at the concentration exceeding the cut-off value of concentration for the relevant hazard class as specified in the Fifth Schedule. 53
Table 3.0 Hazard Class 54
• Safety Data Sheet Information: 1) identification of the hazardous chemical and of the supplier; 2) hazard identification; 3) composition and information of the ingredients of the hazardous chemical; 4) first-aid measures; 5) fire-fighting measures; 6) accidental release measures; 7) handling and storage; 8) exposure controls and personal protection; 9) physical and chemical properties; 10) stability and reactivity; 11) toxicological information; 12) ecological information; 13) disposal information; 14) transportation information; 15) regulatory information; and 16) other information CLASS Regulation 2013 (Safety Data Sheet) 55
• Safety Data Sheet Revision: ✓new information on a particular hazardous chemical becomes available; ✓more than five years have elapsed since the last date of preparation or revision of the Safety Data Sheet; or ✓so directed by an officer. CLASS Regulation 2013 (Safety Data Sheet) 56
Formative Task (SDS) • Form group of maximum 4 members • Select one sample of any chemicals in Makmal Kimia, JKPK • Verify the packaging, labelling and SDS of selected chemical based on CLASS Regulation 2013 • Prepare presentation slides (maximum 5 slides) 57
• These Regulations shall apply to all places of work which are within the jurisdiction of the Act where chemicals hazardous to health are used except chemicals which are - (a) defined as radioactive materials under the Atomic Energy Licensing Act 1984 [Act 304]; (b) foodstuffs; (c) hazardous to health solely by virtue of their explosive or flammable properties, or solely because they are at a high or low temperature or a high pressure; and (d) pharmaceutical products. USECHH Regulation 2000 58
USECHH Regulation 2000 (Employer Responsibilities) Employer Responsibilities Chemical Register Employer Permissible Exposure Limit Risk Assessment to Health Action to Control Exposure Labelling & Information, Relabelling Instruction & Training Monitoring of Exposure Health Surveillance Program Medical Removal Protection Warning Sign Record Keeping 59
• Chemical Register Information 1) a list of all chemicals hazardous to health used; 2) the current Chemical Safety Data Sheet for each of the chemicals hazardous to health except for pesticides which shall have information as specified in Schedule III; 3) the average quantity used, produced or stored per month or per year whichever is applicable for each of the chemicals hazardous to health; 4) the process and work area where the chemicals hazardous to health are used; and 5) the name and address of the supplier of each of the chemicals hazardous to health. 3.3 USECHH Regulation 2000 (Chemical Register) 60
Chemical Register Section A 61
Chemical Register Section B & C 62
Formative Task (Chemical Register) • Form group of maximum 4 members • Download Guidelines For The Preparation Of A Chemical Register at DOSH Website • Identify chemical used in Process Lab, JKPK • Prepare the chemical register at Process Lab according to guideline 63
• Ceiling Limit - An employer shall ensure that the exposure of any person to any chemical hazardous to health listed in Schedule I at no time exceeds the ceiling limit specified for that chemical in that Schedule. • Eight-Hour time-weighted average - An employer shall ensure that the exposure of any person to any chemical hazardous to health listed in Schedule I in any eight hour work shift of a work week does not exceed the eight-hour timeweighted average airborne concentration specified for that chemical in that Schedule. • Respirator - The degree of protection afforded by the respirator for the periods during which the respirator is worn shall be taken into account. USECHH Regulation 2000 (Employer Permissible Exposure Limit) 64
• The written assessment shall contain : (a) potential risks to an employee as a result of exposure to chemicals hazardous to health; (b) method and procedures adopted in the use of the chemicals hazardous to health; (c) nature of the hazard to health; (d) degree of exposure to such chemicals hazardous to health; (e) the risk to health created by the use and the release of chemicals from work processes; (f) measures and procedures required to control the exposure of an employee to chemicals hazardous to health; (g) the measures, procedures, and equipment necessary to control any accidental emission of a chemical hazardous to health as a result of leakage, spillage, or process or equipment failure; (h) necessity for employee exposure monitoring programme; (i) necessity for health surveillance programme; (j) the requirement for the training and retraining of employees as required under regulation 22. USECHH Regulation 2000 (Risk Assessment to Health) 65
• The employer shall control chemicals hazardous to health through the following control measures: (a) elimination of chemicals hazardous to health from the place of work; (b) substitution of less hazardous chemicals for chemicals hazardous to health; (c) total enclosure of the process and handling systems; (d) isolation of the work to control the emission of chemicals hazardous to health; (e) modification of the process parameters; (f) application of engineering control equipment; (g) adoption of safe work systems and practices that eliminate or minimise the risk to health; or (h) provision of approved personal protective equipment. USECHH Regulation 2000 (Action to Control Exposure) Figure 3.5 Hierarchy Of Hazard Controls 66
• An employer shall ensure that all chemicals hazardous to health supplied or purchased used in the place of work are labelled and that the labels are not removed, defaced, modified or altered. • When the labels are removed, defaced, modified or altered while the chemical is being used at the place of work, the employer shall re-label the chemical. • When a chemical hazardous to health is transferred to another container the employer shall ensure that the container is relabelled. USECHH Regulation 2000 (Labelling & Relabelling) 67
• Why needed?? To enable employer to know ✓risk to health created by such exposure ✓precautions which should be taken USECHH Regulation 2000 (Information, Instruction & Training) • What shall include in information?? ✓information on the results of any monitoring of exposure at the place of work ✓information on the collective results of any health surveillance program • When to review training?? ✓at least once in two years ✓if there is a change in the hazard information on the chemicals hazardous to health, safe work practices or control measures ✓each time employees are assigned to new tasks or new work areas where they are exposed or likely to be exposed to chemicals hazardous to health. 68
• When employer need to monitor chemical exposure?? 1. Where an assessment of risk to health indicates that monitoring of exposure is required or it is requisite for ensuring the maintenance of adequate control of the exposure of employees to chemicals hazardous to health 2. If an employee is exposed or likely to be exposed to chemicals hazardous to health listed in Schedule II, the monitoring of exposure of employees shall be repeated at intervals of not more than six months or at such shorter intervals as determined by the assessor (hygiene technician) • How long employer need to keep the monitoring record?? 1. personal exposure record of a person exposed to any chemical hazardous to health, for at least thirty years 2. in any other case, for at least five years USECHH Regulation 2000 (Monitoring of Exposure) 69
• When employer need to carry out a health surveillance programme?? 1. Where an assessment indicates that health surveillance is necessary for the protection of the health of employees exposed or likely to be exposed to chemicals hazardous to health 2. If an employee is exposed or likely to be exposed to chemicals hazardous to health listed in Schedule II, the health surveillance shall include medical surveillance conducted at intervals of not more than twelve months or at such shorter intervals as determined by the occupational health doctor or an occupational safety and health officer who is also a medical practitioner. USECHH Regulation 2000 (Health Surveillance Program) 70
1. The employer shall not permit an employee to be engaged in and shall remove him from any work that exposes or likely to expose him to chemicals hazardous to health on each occasion that the medical finding, determination or opinion expressed by an occupational safety and health officer 2. A pregnant or breastfeeding employee need to remove from chemical hazardous area USECHH Regulation 2000 (Medical Removal Protection) 71
For chemical hazardous workplace, the employer shall ensure that - ➢warning signs are posted at a conspicuous place at every entrance of the area to warn persons entering the area of the hazards; and ➢other relevant information are given to persons who may be or are likely to be at risk of being affected by the chemicals hazardous to health. USECHH Regulation 2000 (Warning Sign) Figure 3.6 Warning Sign 72
(1) Whenever an employer ceases to carry on business and another person succeeds him, the employer ceasing business shall hand over, and the successor employer shall retain, all records to be maintained under regulations 13, 19, 22, 26 and 27. (2) Whenever an employer ceases to carry on business and no person succeeds him, the employer shall transmit the records required to be maintained under regulations 13, 19, 22, 26 and 27 to the Director General. (3) At the expiration of the retention period for the records required to be maintained under regulations 13, 26 and 27 the employer shall give the Director General at least three months notice in writing that he intends to dispose of such records, and he shall transmit those records to the Director General, if requested to do so within that period. USECHH Regulation 2000 (Record Keeping) 73
74 CHAPTER 4 Hazard Identification, Risk Assessment and Risk Control (HIRARC) Learning Objectives: At the end of this chapter, you should be able to: • Define hazard, risk and danger • Categorize types of hazard • Express risk assessment • Write risk control Author: Mohamad Fikhri bin Nor Azman
What is HIRARC ?? • Hazard Identification • Risk Assessment • Risk Control Where to download HIRARC Guidelines?? 1. Go to Official Website DOSH Malaysia 2. Click Legislation 3. Click Guidelines 4. Download HIRARC Guidelines 2008 75
4.1 Definition • Hazard - a source or a situation with a potential for harm in terms of human injury or ill health, damage to property, damage to the environment or a combination of these. • Risk - a combination of the likelihood of an occurrence of a hazardous event with specified period or in specified circumstances and the severity of injury or damage to the health of people, property, environment or any combination of these caused by the event • Danger - Relative exposure to hazard 76
4.1 Definition • Hazard - a source or a situation with a potential for harm in terms of human injury or ill health, damage to property, damage to the environment or a combination of these. • Risk - a combination of the likelihood of an occurrence of a hazardous event with specified period or in specified circumstances and the severity of injury or damage to the health of people, property, environment or any combination of these caused by the event • Danger - Relative exposure to hazard 77
• General duties as prescribed under the Occupational Safety and Health Act 1994 (Act 514) for the employer to provide a safe workplaces to their employees and other related person • Gives organization effective way to manage the hazard HIRARC Purpose 78
Categories of Hazards Example of Potential Source of Hazard Physical Hazard Hazards that cause the body to become physically stresses ex: Moving and rotating equipment, hot and cold Biological Known as biohazards, refer to biological substances that pose a threat to the health of living organisms, primarily that of humans. Ex: Bacteria and fungus Chemical Pose a wide range of health hazards (such as irritation, sensitization, and carcinogenicity). Ex: Carcinogens chemical and corrosive materials Ergonomics Ergonomic hazards refer to workplace conditions that pose the risk of injury to the musculoskeletal system of the worker.Ex: Wrong design of workstation and unusual movement Psychological Related to mental and personal well-being. Ex: Stress, sexual harassment and violent at work 4.2 Hazard Categories 79
• Identify hazard based on below situation Formative Task (Hazard Identification) 1 2 3 4 5 80
• Risk can be presented in variety of ways to communicate the results of analysis to make decision on risk control. • For risk analysis that uses likelihood and severity in qualitative method, presenting result in a risk matrix is a very effective way of communicating the distribution of the risk throughout a plant and area in a workplace. • Risk formula: L x S = Relative Risk L = Likelihood S = Severity 4.3 Risk Assessment 81
Likelihood of an Occurrence (Table A) • This value is based on the likelihood of an event occurring. You may ask the question “How many times has this event happened in the past?” Assessing likelihood is based worker experience, analysis or measurement. Table 4.0 Likelihood 82
Severity of Hazard (Table B) • Severity can be divided into five categories. Severity are based upon an increasing level of severity to an individual’s health, the environment, or to property. Table 4.1 Severity 83
Risk Matrix (Table C) • Severity can be divided into five categories. Severity are based upon an increasing level of severity to an individual’s health, the environment, or to property. Table 4.2 Likelihood Vs Severity 84
Risk Matrix (Table D) Table 4.3 Risk Matrix 85
4.4 Risk Control • Definition: Control is the elimination or inactivation of a hazard in a manner such that the hazard does not pose a risk to workers who have to enter into an area or work on equipment in the course of scheduled work Figure 4.0 Hierarchy of Controls 86
Type of Risk Control • Elimination - Getting rid of a hazardous job, tool, process, machine or substance is perhaps the best way of protecting workers. • Substitution - Sometimes doing the same work in a less hazardous way is possible. For example, a hazardous chemical can be replaced with a less hazardous one. • Engineering Control - Redesign, isolation, automation, barrier, dilution • Administrative Controls - Safe work procedure, supervision, training, job rotation, hazard labelling • Personal Protective Equipment (PPE) - used when other controls measures are not feasible and where additional protection is needed. Workers must be trained to use and maintain equipment properly. T 87
• Identify type of risk control based on below situation Formative Task (Risk Control) 88
HIRARC Process Figure 4.1 Flowchart of HIRARC 89
HIRARC Form 1. HAZARD IDENTIFICATION 2. RISK ANALYSIS 3. RISK CONTROL NO WORK ACTIVITY HAZARD EFFECT EXISTING CONTROL L S RISK RECOMMENDED CONTROL MEASURES PIC DUE DATE/ STATUS 90
1. Form a group (3-4 members) 2. Select one (1) equipment in JKPK Process Lab 3. Develop HIRARC based on SOP of the equipment selected Formative Task (HIRARC) 91