Example (FINLAND): How to select the target of inspection and use of the method of inspection in the chemical industry Antero Vahapassi* * This presentation is based on Mr. Hannu Alen’s presentation in Nanjing, November 2013 WORKSHOP ON WORK SAFETY RESPONSIBILITY SYSTEMS WITHIN OSH INSPECTION SYSTEMS 15 – 16 APRIL, 2014, IN GUOLIN HOTEL, BEIJING

Chemical agents “Inspections are aimed to the workplaces where there exists considerable exposure or where it is otherwise appropriate to visit” (large-scale handling of chemicals, etc…) – Target to inspect Risk assement, risk management measures (RMM) Handling of chemicals, work environment inspections (shop floor) SDS´s and labelling, classification (at least 3 – 5 random substances or chemical products/inspection) SDS= Safety Data Sheet, also MSDS= Material Safety Data Sheet

Chemical agents Taking into consideration the background of the inspectors, we try to concentrate our efforts into carrying out projects of different kinds of chemical risks: – Surface handling in metal industry (in 2007) – Reinforced plastics/boat industry (in 2008) – CMR substances (in 2009) – Allergens (sensitizers) (in 2011) CMR regulations (= Carcinogenic, Mutagenic or toxic to Reproduction)

General model of an inspection visit 1. The choice of workplaces to be inspected 1.1Sector(s) to be considered: NACE-code, the Finnish registry of workplace inspections + public registries of enterprises used, or Registry of workers exposed to Carcinogens 1.2 A sample of the enterprises is chosen 1.3 A letter including a self-evaluation questionnaire is sent to the enterprises 1.4 The response percentage commonly varies between 30 – 60 %, the answers are analyzed, and those who did not answer, are taken into consideration in order to find the workplaces which are most likely to have bad working environments 1.5 Every inspector taking part in the project has 10 – 20 workplaces to inspect

General model… 2. Inspection visit 2.1 Risk management measures (RMM), documents 2.2 Working environment, shop floor inspection 2.3 Safety Data Sheets (3 of them will be inspected) 2.4 Labels and packages (of the same substances or mixtures as SDS inspected ) 2.5 Debriefing of what was found after the visit 2.6 A written report to the workplace within one month including written advice and improvement notices (possibly good advice, too) - check-lists for 2.1 – 2.4

Check-list for 2.1 Risk management measures (typically 8-11 questions) PPE´s (4 - 6 questions) Information and training of workers (4-5 questions) OSH health services (4-5 questions) First aid (4 questions) Emergency measures (3 questions) – Number of questions varies project by project, tailored – Inspection can be finished usually within 2 – 4 hours – Answers yes/no (are the legal requirements filled) – If the question is useless leave empty (but don’t forget), remarks possible if needed – Criteria for yes/no decision is based on the law (several sub-criteria in the manual)

3. Chemical safety profiling By using the check-lists and counting the safety indexes (RMM´s, working environment, SDS´s and labelling) we can profile: – A single company´s safety profile – The safety profile of an industrial sector – Follow up the development of safety – (the maximum index shall be 100 % because criteria is based on requirements of law)

B. INSPECTION OF WORK ENVIRONMENT Production facilities YesNoNotes 1. Are chemicals stored in safe and durable packages? 1. Is there a general ventilation system with efficient and sufficient air movement? 1. Are there local ventilation systems needed? 1. Are the containers of chemicals marked with safety signs? 1. Are the possibities of chemical leaks taken into consideration? 1. Do the workers use PPE´s needed? Order and tidiness YesNoNotes 1. Are the shelves, worktables, floors and so on clean and free of unnecessary articles? 1. Are there enough trash cans? 1. Are the gangways free and correctly marked? 1. Is there a suitable place to store PPE´s? Chemicals storeYes NoNotes 1. Is there a safe room for chemicals, equipped with exhaust ventilation? 1. Is the safety on moving chemicals, articles and people taken into considertion? 1. Are the packages of chemicals marked / labelled correctly? 1. Is there a safe way of handling chemical wastes? First aid and emergency measures YesNoNotes 1. Are the safety equipment ready available? 1. Is there an emergency shower and devices for rinsig eyes? 1. Are the emergency exits marked and free? 1. Is there fire extinguishers ready available?

After the inspection the total number of yes and no answers are counted and the company´s chemical safety indexed by counting as follows: yes RRM´s index = x 100 (%) yes + no yes Work environment index = x 100 (%) yes + no total yes Safety index = x 100 (%) total yes + total no B. INSPECTION OF WORK ENVIRONMENT

The inspector’s report After the inspection the findings are reported to the workplace on site, without delay A written report is sent to the workplace within one month – It may contain Written advice with time limits Improvement notices with time limits (a list of deficiencies found: obligatory) If obviously non-compliance continues or the matter doesn’t allow for delays, the inspector may submit the matter to L.I. Office immediately -> a decision by L.I. Office A temporary prohibition notice -> a decision by L.I. Office

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