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Understanding Exposure
1. Understanding
Exposure
Suzanne Broadbent
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Suzanne Broadbent Slide Number: 1
2. Exposure to chemicals
Is there a GAP in NZ?
Do companies comply with exposure
standards?
Do they care?
Is there any consequence if they don’t?
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Suzanne Broadbent Slide Number: 2
3. What do we have?
Legal Technical Checks
Risk Test
HSNO
Assessment Certification
Occ Hygiene ACC audits/
HSE
DoL Inspect
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Suzanne Broadbent Slide Number: 3
4. This Paper
Legal requirements
The substance – HSNO
The workplace - HSE
Technical –
occupational hygiene
Risk assessment
Why are there problems?
Ways forward
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5. Two Angles
The SUBSTANCE
HSNO HSNO
MSDS
Lifecycle
The Workplace
Hazards
How it is used
HSE RMA
Exposure and Risk
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Suzanne Broadbent Slide Number: 5
6. HSNO – so what is it
about?
The SUBSTANCE
Risk assessment
New products
Test certification
DoL
NZIHSM
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7. HSNO extra bits
Regulations
Transfer gazettes
Approvals for specific substances
Group standards
Industry guidance
Chemical Safety in the Workplace
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Suzanne Broadbent Slide Number: 7
8. HSNO - exposure
No mention of occupational hygiene
No mention of monitoring of exposure
Group standard and regulations and specific
substance approvals include:
Reference to exposure standard
NO requirement to carry out monitoring or
assessment of whether standard is met
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Suzanne Broadbent Slide Number: 8
9. Risk and chemicals
AS/NZS ISO 31000: Risk Management
Likelihood
Consequences (severity)
Qualitative/quantitative
ERMA/EPA guideline (workplace chemical
risks) focuses on this
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10. GAP 1
No requirement to carry out monitoring of
exposure under HSNO (although exp stds)
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12. Magnitude/severity
Level Description
Minimal Short term, reversible, effects very people
Minor Short term, reversible, small group of people
Moderate Minor, irreversible effects to individuals or reversible
effects to larger group (hospitalisation)
Major Significant irreversible effects to individuals
(hospitalisation). Reversible effects to community.
Massive Significant irreversible effects to community and/or
death(s).
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13. The Substance –
Severity?
Properties of the chemical normally used to
consider types of effects and severity
HSNO classifications (simple)
WES
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14. Likelihood
Level Description
Highly improbable Almost certain will not occur
Very unlikely Only occur in very unusual circumstances
Unlikely Could occur, but not during normal operation
(occasional)
Likely Good chance it will occur (normal operation)
Highly likely Almost certain
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Suzanne Broadbent Slide Number: 14
15. EPA Small Business
Guide
Chemical Safety in the Workplace for Small
Businesses
Very simple guidance for small business to do
risk assessment
No links to exposure assessment, occupational
hygiene or monitoring of exposure
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Suzanne Broadbent Slide Number: 15
16. Risk and chemicals
A bit mixed up with chemicals
One chemical (just one…)
Various potential effects
Various possible severities
Various likelihoods – many based on exposure
levels
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17. Toluene in a wkplce
Effect Severity Likelihood
From
mixing
Dizziness
CNS From use
Memory Ongoing
loss exposure
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18. HSNO Risk Assessment
in Workplace?
Logical, Standard, sensible approach
Looks quite simple
Actually extremely complex
Not clear about assessing exposure
Not linked in any way to exposure standards
No links with requirements under HSE
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19. Is risk assessment done
for workplace exposure
Rarely
We do sometimes, but most clients find it
confusing – esp if we need to do monitoring as
well
If we are looking at HSNO compliance
(inventory etc)
EPA small business guide
Terminology not consistent with Occupational
Hygiene
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20. Gap 2
No real guidance on how to carry out health
risk assessment under HSNO
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21. HSNO – how does it
ENSURE assessment of
risks in workplace
Mostly through test certification processes
Sites are only required to be certified for
storage and use of flammable substances
Sites on budget
Do requirements for flammables FIRST
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22. Gap 3
No prioritisation of health risks as no test
certificate required
No checking of compliance
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23. HSE
Workplace
Hazards
Assessment is about consequence (serious
harm)
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24. Gap 4
Our workplace – HSE legislation does not
include assessment of risks
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25. HSE Act
Is occupational hygiene required under HSE
Is exposure monitoring?
Section 10, (2) c:
“monitor the employees’ exposure to the
hazard”
Interpretation issues
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26. HSE Act – other
requirements
WES 2011
MOSHH - 1997
Good, clear guidance and links to exposure
monitoring and occupational hygiene
Unclear whether current
Most employers never heard of these
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27. Gap 5
Misinterpretation of requirements under HSE
for monitoring and lack of awareness of extra
information
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28. How is compliance with
HSE encouraged?
Information
Inspections
ACC audits (indirect)
Incident investigations
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29. Gap 6
Limited checks on compliance with HSE
requirements for monitoring significant
hazards
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30. Occupational Hygiene
Based on risk assessment principals
Identification, evaluation and control of health
risks in the workplace
Focus on exposure with clear links to exposure
standards (where relevant)
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31. Occ Hyg basis in risk
assessment
Hazard identification
Dose response relationship (and
establishment of exposure guideline)
Exposure assessment (usually monitoring)
Assessment of health risk
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32. Occupational Hygiene
NZOHS
International profession re-enforced by clear
legal requirements
Not so much in NZ
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33. Gap 7
Occupational hygiene is not really a
recognised profession in NZ
ZERO occupational hygienists at ERMA/EPA
Few at DoL
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34. Summary
Occupational hygiene and exposure standards
are simpler than full risk assessment
Simplistic risk assessment process does not
give any realistic assessment of exposure
(guesswork)
Hazard assessment not useful
Current systems emphasis hazardous
properties and not exposure
Performance based legn needs checks
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35. What do we have?
Legal Technical Checks
Risk Test
HSNO
Assessment Certification
Occ Hygiene ACC audits/
HSE
DoL Inspect
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36. The positive?
Lots of information/legal requirements -
confusing
Great system for identify types of hazards
(HSNO classifications)
MOSHH (the old one)
Test certification for flammables
Training of approved handlers under HSNO
Commitment to improve (DoL), agenda
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37. The gaps
Nothing in ANYTHING that people understand
as clearly requiring exposure assessment
HSNO - risk, HSE - workplace
Limited checks in place under HSNO or HSE to
establish level of compliance
Profession (occupational hygiene) not well
developed with very limited training
opportunities
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38. The Real NZ
Number eight wire
If it is not clearly legally required, we don’t
have to do it (Tamahere)
If it is not checked in any way, it is not a
priority (Pike River)
If our competitor doesn’t do it..
Especially if it costs money…
If it is not a priority, it doesn’t get done
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39. Is there any hope for our
HS workers?
New initiatives - DoL
HSNO - first ever (known) case of a substance
with test certification requirements for a
substance that was not flammable (toxic)
Push by certifiers to include toxics (tho not
occupational hygiene)
Can we get some sort of certification for
exposure assessment?
NZOHS working on growth
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40. How does HaS Expertise
do stuff
Risk based approach – using dose-response
and exposure estimate to determine
where/what to monitor
Links to control banding methodology,
severity linked to NZ HSNO classifications
Occupational hygiene, exposure standards and
monitoring
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41. How to move forward
NZOHS
Closer alignment with Australia
Training course development
New strategies/action planning with DoL
Need for closer links with ERMA/EPA and test
certifiers
Working together to eliminate the gaps and
overlaps
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42. Test Cert for Class 6?
Emergency plan
Signage
Notification for new facilities
Restricted access + AH
Separation to boundary
Equipment
PPE available
WES are monitored and complied with
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43. Case studies
Workplaces
Timber treatment site (one chemical)
Bakery (flour, hydroxide
mist, chlorine, ammonia, noise)
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44. NZ HaSNO Exposure
Assessment
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