Purpose of this fact sheet

To provide an overview to employers and employees in the Commonwealth jurisdiction  on the risk management approach to hazardous substances. It outlines how to identify, assess, control and review risks to health from exposure to hazardous substances in the workplace.

This fact sheet is one of a series which describes the provisions of the hazardous substances regulations, codes of practice and guidance material.

Why a risk management approach to hazardous substances is needed?

The purpose of a risk management approach to hazardous substances is to determine whether a person’s health is, or could be, at risk from exposure to hazardous substances used or produced in the workplace. It also provides a framework to help decision making on appropriate control measures to prevent or minimise existing exposure to hazards. The objective is to provide a platform on which a risk management program for hazardous substances can be built upon and maintained.

The need for the systematic management of OHS hazards and their attendant risks applies to all organisations and all activities and functions within an organisation.

Hazard, risk and exposure

The management of risks arising from hazardous substances in the workplace is fundamental to understanding the differences between the concepts of hazard, risk and exposure.

Hazard is the potential to cause harm. Anything that may cause harm or an adverse health effect on a person is hazardous.

Risk is the likelihood that a hazard will cause harm, through injury or ill health, to anyone at or near a workplace. The level of risk to health increases with the severity of the hazard and the duration and frequency of exposure to the hazard.

Exposure occurs when a person comes into contact with a hazard.

Hazardous substances regulations

The hazardous substances regulations are the Occupational Health and Safety (Safety Standards) Regulations Part 6: Hazardous Substances.

Who is responsible for risk management

The employer has the legal responsibility to ensure that a suitable risk management program is in place for the risks to health created by any work involving potential exposure to hazardous substances.

A risk management program is based on a thorough understanding of what happens, or might happen, in the workplace. Sometimes outside consultants need to be called in to help. However, where appropriate, assessments should be done in-house.

Guidance on risk management approach to hazardous substances

The following guidance on a risk management approach to hazardous substances can be found on Comcare's website:

• National Code of Practice for the Control of Workplace Hazardous Substance [NOHSC:2007 (1994)]
• Guidance Note for the Assessment of Health Risks Arising from the use of Hazardous Substances in the Workplace [NOHSC:3017 (1994)]
• SRCC Booklet Occupational Health and Safety Risk Management in Commonwealth Agencies. Identifying Hazards, Managing Risks (1999).

Risk management, a four step process

Risk management approach is a four step process:

• identify the hazard
• assess the risks associated with the hazard
• control the risks
• review the process.

Identification of hazardous substances

The first and most important step in reducing the likelihood of an accident is the hazard identification. This is the process of identifying all workplace hazardous substances used or produced at work that could give rise to the potential of injury or illness. (See fact sheet What is a Hazardous Substance?)

To identify hazardous substances:

• check if there is a Material Safety Data Sheet (MSDS) from the supplier. The MSDS should say if the substance is ‘hazardous’ according to the NOHSC Approved Criteria for Classifying Hazardous Substances. The health hazard section of the MSDS should describe the health effects
• check the NOHSC List of Designated Hazardous Substances or obtain expert advice if the substances are produced at the workplace
• check the supplier’s label. Look for signal words, for example ‘warning’, ‘poison’, ‘dangerous poison’, ‘hazardous’ and risk phrases that indicate the type of health hazard
• check if the substance is listed in Schedules 1A, 1 or 2 of the Occupational Health and Safety (Safety Standards) Regulations 1994.
  

The hazardous substances register is a list of all of hazardous substances used or produced at the workplace accompanied by their respective MSDS. The employer must ensure that a register is kept and readily accessible to employees, supervisors and health and safety representatives.

Assessment of the risks arising from hazardous substances

The assessment of the risks arising from identified hazardous substances is the second step in a risk management program and involves the collection of relevant information to enable decisions about control measures.

It is important to consider the extent of the harm or consequence from a hazard and the likelihood of harm occurring. Then, where an unacceptable risk to health and safety has been identified, controls must be introduced to reduce the risk to an acceptable level.

Further information can be found on the:

• National Code of Practice for the Control of Workplace Hazardous Substance [NOHSC:2007 (1994)]
• Guidance Note for the Assessment of Health Risks Arising from the use of Hazardous Substances in the Workplace [NOHSC:3017 (1994)]
• SRCC Booklet Occupational Health and Safety Risk Management in Commonwealth Agencies. Identifying Hazards, Managing Risks
• Guidance Note on the Interpretation of Exposure Standards for Atmospheric Contaminants in the Occupational Environment [NOHSC: 3008 (1995)].

The primary source of information will be the MSDS which should provide information about the health hazards of the substance if it is breathed in, swallowed or if there is contact with the skin or eyes. The MSDS should also advise on precautions for the safe use of the hazardous substance. If a MSDS has not been provided, request one from the supplier. Labels, information guides and other health and safety reference sources may also be used.

If there is no MSDS for products or emissions produced at the workplace, information about health hazards and recommended control measures should be obtained from health and safety references or from a suitable expert.

If a job involves the use of an inorganic lead substance, determine whether the job is a lead-risk job. The Occupational Health and Safety Code of Practice 2008 provides guidance on how to determine if a job is a lead-risk job.

This step in assessments is to inspect the work to find out whether people might be exposed to the hazardous substances by either breathing in fumes or dust or swallowing them from contaminated hands or face or by skin or eye contact.

The inspection should also look at what control measures are used, if they are effective in controlling exposure, and whether they are properly used and maintained.

If exposure to hazardous substances is not under control, then it will be necessary to decide what control measures are needed to prevent or minimise exposure.

For some work a more detailed assessment may be needed. This is likely if:

• it is possible that an employee can be exposed to a carcinogenic substance listed in schedule 1A of the hazardous substances regulations
• a job involves the use of inorganic lead or a substance listed in schedule 2 of the hazardous substances regulations
• there are complex chemical processes or exposures
• there is the possibility of a significant risk to health, for example because of high levels of exposure or the nature of the health hazard is very serious
• after completing the three basic assessment steps there is still uncertainty about the risk to health and what control measures are needed

Record of assessment

Assessment reports should reflect the detail of the assessment, including sufficient information to show why decisions about risks and precautions were made.

A copy of relevant assessment reports must be provided to an employee on the termination of their employment where that person has been, or the employer suspects the person has been, exposed to a carcinogenic substance listed in Schedule 1A of the hazardous substances regulations.

Comcare will request the assessment records when conducting an investigation or monitoring compliance.

Control of the risks arising from hazardous substances

Where an unacceptable risk to health and safety is identified, controls must be introduced to reduce the risk to an acceptable level.

The best way to control the risks arising from hazardous substances is to eliminate the hazard. However, this is not always possible. This concept has led to the development of a hierarchy of control that starts with the elimination of the hazard as the preferred solution. Control measures generally fall into three categories. These are:

• eliminate the hazard
• minimise the risk, and
• 'back-up' controls (when all other options in the previous categories have been exhausted).

Adequate control may be achieved by using more than one type of control measure:

• elimination
• substitution
• isolation
• engineering controls
• safe work practices
• personal protection

When making decisions about appropriate control measures the hierarchy of control measures should be applied. This means that a hazardous substance should be eliminated if that is practicable. If elimination is not practicable, then substitution should be considered. If substitution is not practicable then other control measures should each be considered in turn and applied as far as practicable until exposure to the hazardous substance is adequately controlled.

Further information on the hierarchy of control is in the

• Occupational Health and Safety Code of Practice 2008
• National Code of Practice for Control of Workplace Hazardous Substances [NOHSC: 2007 (1994)]

Personal protective clothing 

The employer must not rely on using personal protective clothing or equipment (PPE) such as respirators or gloves to protect employees. Personal protection should only be used to provide extra protection, where other control measures are not practicable, for example, during maintenance or emergency operations.

For some hazardous substances, exposure standards have been set. These apply where a substance is a contaminant in workplace air (for example dust, fume or gas). The level of hazardous substance in workplace air, when monitored for an appropriate time period, must not exceed the relevant exposure standard.

The exposure standards are listed in Exposure Standards for Atmospheric Contaminants in the Occupational Environment [NOHSC: 1003 (1995)] and its amendments and should be in the supplier’s MSDS. If it is practicable to achieve levels of exposure lower than those specified in the exposure standards, then this should be done.

Some substances listed in the schedule 1 of the hazardous substances regulations as prohibited substances are not be handled at work. However, the regulations may specify particular circumstances of work where these substances might be used.

All control measures must be regularly maintained. This includes the regular testing of control measures, for example exhaust ventilation, to check that they are working effectively and repaired as necessary.

If PPE is used, it should be maintained on a regular basis and properly cleaned and checked before it is used again.

For some hazardous substances it may be necessary to monitor the amount of the substance in the workplace environment. This is to check that control measures are effective, and employee exposure to hazardous substances is minimised.

Two ways of monitoring exposure are through atmospheric monitoring and health surveillance.

Further information can be found in the:

• Occupational Health and Safety Code of Practice 2008
  
• National Code of Practice for the Control of Workplace Hazardous Substances [NOHSC: 2007 (1994)]
• Adopted National Exposure Standards for Atmospheric Contaminants in the Occupational Environment [NOHSC:1003(1995)]
• Guidelines for Health Surveillance [NOHSC: 7039 (1995)]

The results of any monitoring exposure must be recorded and the records must be available for the employee and kept for a period of 30 years.

Review of the risk management process

Finally, it is essential that systems are established and maintained whereby regular evaluation and review procedures can be undertaken. Evaluation involves ensuring that the control measures adopted have eliminated or reduced the risks while not introducing new hazards. The review system applies to the overall risk management process and is designed to check that the process is working effectively to identify hazards and manage risks.

The risk management program must be reviewed:

• if there is a significant change to the work
• if there is new information about health hazards
• if adverse health effects are reported or detected in health surveillance
• if monitoring shows inadequate control of exposure
• if improved control measures become available
• at least every 5 years.

Additional information

• Occupational Health and Safety Code of Practice 2008 

• Information on the Hazardous Substances Regulations, Codes of Practice and Guidance Material - No. 17a
• What is a Hazardous Substance? - No. 17b
• Material Safety Data Sheets for Hazardous Substances - No. 17c
• Labelling of Hazardous Substances - No. 17d
• Information Employers Must Obtain and Provide about Hazardous Substances - No. 17e
• Information Manufacturers and Suppliers Must Provide about Hazardous Substances - No. 17f
• Risk Management Approach to Hazardous Substances - No. 17g
• Training Employees Should Have about Hazardous Substances - No. 17h

• Australian Safety and Compensation Council website ascc.gov.au or telephone: 02 6121-5317

For further information about this fact sheet, or others in the series, please contact Comcare on the General Enquiry Line 1300 366 979 or visit our internet website on comcare.gov.au