Control Banding Options AIHA Alberta Local Section March 14, 2013

Current Control Banding Models France (Risk Potential Hierarchy) The Netherlands (Stoffenmanager) Norway (KjemiRisk) Belgium (Regetox and SOBANE) Singapore (SQRA) Korea (KCT) Germany (Chemical Management Guide) ENFORM Guide and E-tools

France (Risk Potential Hierarchy) Chemicals are assigned to categories based on: hazard classification and labelling (I–V), frequency of use (I–IV), and quantity used (I–V). Quantity and frequency of use scores are combined to create a classification by potential exposure (I–V, based on expert opinion). The scores for hazard and potential exposure are combined to give an overall product score and priority classifications (A=elevated, B=middle, and C=weak) French only.

The Netherlands (Stoffenmanager) www.stoffenmanager.nl Web-based tool for SMEs for working safely with chemical substances Gives qualitative risk score; allows employer to select various control measures based on score (similar to COSHH Essentials) Can provide expert analysis using its quantitative exposure assessment score (requires expert user) The program does both inhalation and skin risk assessments Accessible in English

Norway (KjemiRisk) https://chemirisk.ohs.no Chemicals are grouped into one of five health hazard categories based on R- and S-phrases Developed for Norwegian (offshore) oil industry KjemiRisk application the asks user: about common tasks & handling of the chemical its physical state duration and frequency of use potential for exposure the appropriateness of controls in place In hands of hygienist can be an expert analysis tool If used buy others provides rough qualitative (Red, Orange and Green risk ranking) English accessible

Belgium (Regetox and SOBANE) www.regetox.be www.sobane.be Regetox uses the French Risk Potential Hierarchy approach to first rank hazards and then uses the COSHH Essential model to develop recommended controls for highest risk exposures (Available in French and Dutch) SOBANE uses a screening approach to identify main problems and solve simple ones immediately, then observation process is used to solve more complex ones with the help of experts (Available in French and Dutch)

Singapore (SQRA) and Korea (KCT) www.kosha.or.kr Both are recently developed systems similar to COSHH Essentials and are based on the International Chemical Control Toolkit (ILO) The Korean tool is only open to members while the Singapore SQRA is paper based tool and can be found at: http://www.mom.gov.sg/Documents/safety-health/factsheets-circulars/A%20Semiquantitative%20Method%20to%20Assess%20Occupational%20Exposure%20to%20Harmful%20Chemicals.pdf

Germany (Chemical Management Guide) Two part chemical management scheme: Module 1 – Identifying Hot Spots Module 2 – Making a Comprehensive Inventory Paper based and available in English Uses ILO and COSHH Essentials classification process to rank hazards into control bands in Module 2

Control Banding Models Summary All attempt to provide a qualitative assessment of risk with the aim of getting employers to take action now rather than waiting until they get monitoring results Most use processes similar to COSHH Essentials to group chemicals into similar control bands based on R-phrases Some can be used for quantitative risk assessment with the addition of more data by experts All are quite conservative in assigning control bands and in the recommendation of controls Validation exercises have shown that the models recommend controls that are equal to or greater than those recommended by hygienists in 85 to 90% of cases.

Control Banding Models Summary Problems have occurred mostly in the adequacy of controls that were implemented. In some cases, particularly those involved with LEV use for dusts, controls failed to bring exposure down below OELs (i.e. hygiene monitoring is still required to validate effectiveness of controls) All models have problems dealing with complex exposure situations. They tend to default frequently to calling in an expert. North American adoption has been slow because of the lack of R-phrases on MSDS.

Control Banding Models Summary Where they have been implemented user acceptance has been quite high (80%) and most (>50%) have implemented controls as a result of using the models. Models all show great promise in motivating non-experts to take action on control of chemicals.

http://www2.gtz.de/dokumente/bib/07-0702.pdf

“Better be roughly right than precisely wrong”

A Two Part Chemical Management Scheme Module 1 – Identifying Hot Spots Module 2 – Making a Comprehensive Inventory

Module 1

Module 1 – Step 1 Fact finding & Identification of possible “hot spots” Draw a ground plan of the company and use it on a site walk through to identify areas where: waste, loss, contamination or expiry of a substance potential hazards created in the way that chemicals are stored, mixed, transported and used Look for strong chemical smells, spills, dust clouds, spoiled or expired chemicals, places where workers complain about health effects or created makeshift controls

Example: Beautiful Printing Inc.

Module 1 - Step 2: Analysis of effects related to costs, hazards and environmental impacts

Module 1 - Step 3: Analysis of causes – Why are chemicals being wasted, why do risks exist?

Module 1 - Step 4: Development of measures Minimise the number of workers exposed Minimise the duration and intensity of exposure Reduce the quantity of chemical agents Appropriate hygiene measures Provide suitable equipment and establish safe maintenance procedures Design and organisation of processes, layouts and workplaces Suitable safe work procedures Chemical emergency procedures

Module 1 - Step 5: Action/implementation of measures (chemical management action plan)

Create a system of continuous improvement: Module 1 - Step 6: Evaluation and integration into the company structure Create a system of continuous improvement: evaluate the actions undertaken to determine if the set objectives were achieved communicate and reward results monitor results to ensure that improvements are maintained establish new targets and areas for action in order to make further improvements in the company’s operations.

Module 2

Module 2 - Step 1: Fact finding/inventory of chemicals

Module 2 - Step 2: Risk and cost assessment Obtaining R and S – Phrases: Take them from a GHS compliant MSDS or If not available you can find them for most commonly used chemicals on International Chemical Safety Cards: http://www.ilo.org/public/english/protection/safework/cis/products/icsc/dtasht/a_index.htm

Use R phrases to get ILO hazard classification

Use R phrases to get skin hazard group

Estimating amount in use

Estimating dustiness - solids

Estimating volatility - liquids

Determining control approach

Control approaches

Determining skin control approach

Skin control approaches

Module 2 - Step 3: Analysis of causes Firstly, identify the most costly and most hazardous chemical substances as well as the most dangerous situations occurring in your company. Then ask: Is too much of the substance kept at once in stock? How are substances spilled and wasted in the production process? Are there different forms of this substance (e.g. granular or liquid instead of fine powder) on the market which are less hazardous?

Module 2 - Step 4: Development of measures Do the simple things first: Minimise the number of workers exposed Minimise the duration and intensity of exposure Reduce the quantity of chemical agents Appropriate hygiene measures

Module 2 - Step 4: Development of measures Compare existing controls against those recommended by your analysis Determine how your workplace can be modified to implement the recommended controls Bring in specialists to develop specific recommendations for substances that require Control Approach 4 or Special Control Measures for skin.

Module 2 - Step 4: Development of measures Require eye protection if there is any danger from splashing chemicals or flying particles or if MSDS has the R phrases R 36, R 41, R 34 and/or R 35 Require RPE if recommended controls are Control Band 2, 3 or 4 and the control is not available.

Module 2 - Step 5: Action/Implementation of measures

Create a system of continuous improvement: Module 2 - Step 6: Evaluation and integration into the company structure Create a system of continuous improvement: Evaluate the actions undertaken to determine if the set objectives were achieved Use list of chemical substances to consider how your entire operating context and production process could be improved Find cheaper and safer alternatives

Group Exercise – Applying Model to Chrome Plating Shop http://www.youtube.com/watch?v=f89_ZxVFn1w

Chrome Plating Room Diagram

Chrome Plating Process Flow Diagram

Chemicals used Sodium Hydroxide in Water Sulphuric Acid in Water Chromic Acid mixed with Sulphuric Acid pH Inhibitor (sodium metabisulfite and sulphuric acid solution)

Chrome Plating Cell

Chrome Plating Reactions Chrome plating half reaction: Cr2O72- + 14H+ + 6e- => 2Cr3+ + 7H2O Neutralization of hex chrome with bisulphite: Na2S2O5+H2O => 2NaHSO3 3NaHSO3+2H2CrO4+3H2SO4=>Cr2(SO4)+3NaHSO4+5H2O

Part 1 Use the GTZ tool (Module 1) to come up with a Chemical Management Action Plan to deal with “hot spots” based on what you saw in the video and the chemicals that you observed.

Part 2 Use the GTZ tool (Module 2) to complete a site chemical inventory What additions will you make to the Chemical Management Action Plan you developed in Part 1 as a result of this analysis?

Questions?