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CHEMICAL RISKS AND THEIR CONTROL Report on a Workshop held during 3rd IOHA International Scientific Conference Crans Montana, Switzerland 17 September 1997 International Occupational Hygiene Association Contents Summary
Chemical Risks and their Control in Small and Medium-sized Enterprises (SMEs) Proceedings of a Workshop held on 17 September 1997 during the 3rd International Scientific Conference organised by the International Occupational Hygiene Association, Crans Montana, Switzerland SUMMARY Within the many small and medium-sized industrial and other business activities carried on throughout the world, there appears to be a need for simple guidance to help employers select appropriate measures to control those risks to health which arise from the use of chemical substances. The vast majority of such SMEs lack in-house expertise to make judgements on likely exposures and risk and few would know form where to seek advice on such matters. Hazard data are however widely available on labels and in Materials Safety Data Sheets (MSDSs), although their quality is sometimes less than adequate. It is suggested that suppliers might be persuaded to supplement hazard information with some advice on suitable control measures, the advice being tailored to typical potential applications of the chemicals. The user would then have to choose from a relatively limited number of alternative measures, using his own information on the nature and scale of the activity to help make the selection. One example of this approach is being developed in the UK and it was agreed that, if judged successful in its pilot phase, the approach could form the basis of guidance world-wide applicability. Chemical Risks and their Control 17 September 1998 Chairman:
Keynote speakers:
Contributors to discussion:
Sponsors:
The Problem in Europe: SMEs' Need for Guidance on Control Selection Ron Haigh (European Commission DGV) opened the workshop presentation by pointing out that small and medium-sized enterprises (SMEs, defined as companies employing 50 or fewer persons) made up some 98% of the 33000 chemical companies in Europe. Some 23% of all employees are exposed to chemical vapours, fumes and dusts and the total cost of industrial accidents and work-related ill health is estimated at about 1.5 and 4% of gross domestic product (GDP). Legislation is in place in the European Union to protect the workers and others who might otherwise be affected by work activities and is continually being updated. A draft of the new Directive on chemicals includes a requirement for the assessment of occupational risks to health and defines general principles for the prevention or control of such risks. Attention is drawn to the design and organisation of systems of work, the provision of suitable equipment, introducing suitable working procedures for the safe storage, handling and disposal of chemicals, reducing numbers of exposed persons, reducing the duration and intensity of exposure and reducing the quantities of chemicals in the workplace. In addition, the draft Chemicals Directive provides for the Commission to develop guidance to assist in its implementation. It is the intention of DGV to address this particularly to the needs of SMEs and so the advice must be simple yet comprehensive, useful and practicable. Some years ago, Haigh had suggested the adoption of a banded approach to occupational exposure limits (OELs) which could be linked to a colour coded system of hazard ranking, for example using red, yellow and green to denote decreasing hazard ratings. This could be developed to link hazard with control, but how? The Global Problem: A world-wide need for control Berenice Goelzer (World Health Organisation) gave an overview of the distribution of SMEs. There are small scale enterprises in all types of work from agriculture to the manufacture of goods and the provision of services and these are found in every country. However, the concept of scale depends not only on the number of workers but also to the nature of the work itself. For example, 20 employees would represent a small foundry operation but a big hairdresser shop. More importantly, small numbers may result from technological development which enables complex manufacturing processes to be operated by a few persons in distant control rooms, thus avoiding exposure to the chemicals involved. Thus a better definition of the real problem would relate not just to small numbers but to those companies with limited resources to tackle the often serious occupational health hazards which are inherent in their activities. Such SMEs are to be found everywhere but the problems of the workplace are aggravated in developing countries by conditions such as poor housing, inadequate water supplies, under nutrition and lack of basic sanitation. WHO has seen many examples of toxic chemicals being handled in domestic premises with little or no control, often using obsolete second-hand equipment and improvised tools. Many of these operations are beyond the reach of preventive occupational health services and much disease is probably undetected and thus unreported until some unusually large number of cases is observed. In small enterprises it often happens that hazardous materials are handled without proper precautions being taken. Not surprisingly, cases of severe intoxication and mortality occur in these circumstances. A survey in Thailand (World Bank, 1993) showed 22% of workers in enterprises with less than 50 employees had lead poisoning. 27% had diseases of the upper respiratory tract and 6% had chronic obstructive airways disease. The Indian National Institute of Occupational Health has studied small scale and cottage industries including ceramic and pottery manufacture, slate pencil cutting, glass and stone grinding. Working conditions were poor and the prevalence of occupational diseases very high (Saiyed, 1997). In another Indian study (Durvasala, 1990) reported a silicosis prevalence of some 30% amongst workers in small potteries where measured levels of respirable dust were in excess of 25 times the ACGIH TLV. Eero Priha (Regional Institute for Occupational Health, Tampere, Finland) found similarities between the problems he discovered in artists' studios and those described for workplaces in developing countries. Many studios had little information on health hazards, facilities for control of exposure were inadequate and housekeeping standards were generally poor. Although traditional painting techniques posed relatively few risks, spray painting could be a problem. Many paints were bought ready mixed but some were prepared by the artist using toxic pigments, the toxicity of which could be hidden behind a common or trade name. Many standard works on particular processes are old and recommend procedures based on substances which are today considered too hazardous for such purposes. For example, benzene is recommended as a good solvent in the reference text on printing. Guidance on hazards and control measures would be best incorporated in updated versions of such texts as these are widely read amongst the artists concerned. It is important that the health information is provided in a way that fits into the practices of the workplace. Saeed Pervaiz (TRIKEM, Maceio) described how a Brazilian chemical company tackled the problem of worker exposure to asbestos fibres. Exposures were reduced over a period of a few months from unacceptable to tolerable levels using a combination of engineering and procedural controls, backed by a comprehensive worker information, instruction and training programme. Although such a programme could not easily have been planned and implemented in many SMEs, its underlying concepts of hazard identification, risk assessment and control selection are an essential feature of all health risk management procedures irrespective of the nature and scale of the business activities. It is therefore necessary to find a means of providing SMEs with sufficient information to enable them to implement appropriate arrangements. In the case of the example cited, there was substantial support provided by the business association, an important player in setting acceptable standards for the industry. What are the real difficulties for SMEs? Steve Fairhurst (HSE, UK) highlighted the vital importance of the Materials Safety Data Sheet (MSDS) which with the product label was often the only source of information available to the user on the hazards of the substance. Sadly, despite much prescriptive legislative detail in many different countries, many MSDS leave much to be desired. For SMEs, perhaps their most important drawback is their inherent unfriendliness to the lay reader, often the key messages being obscured by relatively unimportant detail and unfamiliar language. Several speakers supported the view, notably Tom Spee (Arbouw, Amsterdam) who said that legislative requirements for data which were of interest only to specialist advisers often lead to MSDS which were unintelligible to the average worker. In his view, the MSDS was a necessary tool for the professional but something else was needed to convey information on hazards, risks and means of control to the user. Such information needed to be in the language of the user and was best developed in collaboration with him or her. Ron Haigh advised that the legislative requirement for MSDS need not prevent suppliers or employers producing their own information sheets tailored to their particular needs. Saskia Wanders confirmed the variable quality of MSDS and notes the Norwegian requirement for defined competence in persons who are preparing such information. Isaac Obadiah (ILO) drew attention the IPCS chemical data cards which were designed specifically with the needs of SMEs in mind. Some 1400 cards are currently available and more are in preparation, including some for mixtures such as gasoline. Steve Fairhurst further explored the problem of SMEs and drew attention to the risk assessment requirement common to much national legislation. In order to manage the risk associated with the use of a particular chemical, employers needed to obtain data on the nature of the hazard, make a judgement on the likely exposure and thus determine the risk to health before deciding what should be done. Suppliers have duties to provide the necessary information, users have duties to understand what they are given, decide if more data are required and if so, obtain them, estimate if significant exposures are likely to occur and what the consequences of such exposures might be and then decide what control measures are required and put them into place. Questions on hazard information in MSDS and on labels might involve its comprehensiveness (have all the hazards been identified?), its relevance (have the data been interpreted in relation to humans and likely routes of exposure?) and its clarity and utility for potential recipients (is the information understandable and helpful?). In terms of exposure estimation and risk assessment, do SMEs have the necessary resources to make these judgements? Are they able to draw appropriate conclusions from the risk assessments and set up and maintain suitable control systems? Very few, if any, will have in-house capability although some may be prepared to seek help from consultants. How can we reduce the need for the SME to make this provision? Berenice Goelzer said that some SMEs provided occupational health care facilities but still failed to prevent ill health in their employees. Analysis of similar failures (Antonsson, 1991) leads to recognition of a ladder in the decision-making process. Steps on this latter are:
Many SMEs fail at the first step in that they have no perception of a problem or, if they do, they have no idea of its cause. Failures at later stages often lead to the erroneous conclusion that prevention of ill health is not applicable in SMEs. Examples of such failures include unrealistic or impracticable proposals for control measures which may be expensive or unacceptable to the workforce. Hugh Dalrymple (ICL, UK) questioned the nature of the problem, reminding us that many SMEs were extremely successful businesses and thus were likely to be well managed and probably receptive to an appropriate message. Paul Oldershaw (HSE, UK) supported this view and stressed the limited time such managements had available. This necessitated the provision of information which was brief, 'owned' the solution and was committed to it. The problems of risk management in SMEs can thus be summarised as:
Possible Solutions Tom Spee stressed the importance of offering a solution when approaching SMEs about the problem. Few would be interested in helping develop ideas, most would be interested in a practicable approach to health risk manage. Isla Brooke (HSE, UK) emphasised the need to get the right information in the right way to the right people, not always achievable by any one means such as MSDS. Different groups have different requirements and these can only be met by specific information tailored to the circumstances. Not only must the words and phrases used be familiar to the reader, so also must be the underlying concepts and arguments involved. This view was strongly supported by Berenice Goelzer who also drew attention to the need for mechanisms to disseminate the information as "a brilliant document in a drawer has no value". Information must actually reach those in the SMEs who can implement the necessary controls and they in turn must ensure that suitable information reaches those who are potentially exposed. The World Health Organisation (WHO) has initiated a programme to identify and disseminate information on practicable measures to control workplace risks to health. aimed particularly at the needs of SMEs, the PACE (Prevention and Control Exchange, WHO 1995) initiative includes raising awareness of health hazards, collecting examples of successful control measures from small scale activities throughout the world and developing and sharing means to get the information into the workplace. Ron Haigh advised that the new European Agency for Health & Safety at Work is intended to provide a more structured approach to the provision of information. Its objective is to provide "technical, scientific and economic information of use in the field of safety and health at work". Its role is to collect and disseminate such information, to promote co-operation and exchange of information and to establish an information network. The Council of Ministers has been asked to support a programme of Safety Actions for Europe (the SAFE programme) which is designed to improve work practice by the provision of various incentives, particularly targeted to the needs of SMEs. It is possible that the development of suitable guidance on the selection of controls might be funded through this programme. Although the problem of inadequate hazard data can be remedied fairly readily and some action is already in hand, education of the SMEs in health risk management is much more difficult. Isla Brooke referred to the many SMEs having a poor understanding of hazards and likely exposures and suggested that a better approach might be to reduce their need for expertise in this area. Could we not change the balance between supplier and user, seeking to involve the supplier more in advice on controls appropriate to the risk? This would require either some assumptions on circumstances of use and thus on likely exposures or, better, some guidance to the user on what controls would be appropriate in his particular circumstances. This latter would demand some guidance on which factors were significant in determining exposures. The UK Health and Safety Executive are currently developing a scheme aimed at the provision of such guidance, particularly applicable to SMEs but no less valid for any work activities involving potential exposure to toxic chemicals. The scheme depends on hazard banding which, when considered against potential exposure categories, leads to the identification of a control strategy appropriate to the risk. Although the initial proposals relate only to airborne concentrations of chemicals and thus inhalation as a route of entry, the concept can be extended to cover aspects such as skin contact. The scheme operates on the basis of the classification of substances according to their toxicological properties, a legal requirement in the EU and an essential component of the regulatory approach for chemicals in many parts of the world. Indeed, there is an OECD initiative underway to standardise substance classification globally. Within the EU classification system, substances meeting specified criteria for classification are assigned one or more risk phrases - "R-phrases", signifying their toxicological hazards. Under the HSE's scheme, five hazard bands have been developed, each relating to a cluster of particular R-phrases. Associated with each hazard band is a specific target airborne concentration, representing the level to which one would want exposure to be controlled for a substance possessing the particular hazardous properties signified by the R-phrase(s) pertaining to that hazard band. The user would then decide on the potential of the substance to become airborne (low, medium or high against easily recognisable criteria for both liquids and solids) and on the scale of use (mg, kg or tonnes). A simple chart then leads the user to the most appropriate of four control strategies (no special arrangements, local exhaust ventilation, containment or the need for specialist advice), the use of which would result in securing control of exposure to the target airborne concentration range for the substance, given its toxicological hazards/classification." During discussion it was agreed that the scheme offered a pragmatic solution with a good chance of success as it demanded little technical expertise from the SMEs. Success would however depend on co-operation from the suppliers and much practical detail needed to be worked out. Isla Brooke said that consultation with interested UK parties was planned for 1998 with a view to implementation in 1999. Documentation had been prepared using EU hazard classification and thus the scheme could readily be adopted within the EU. Global application of the concept was possible now but would be aided by global harmonisation of hazard classification. Conclusions and the way ahead Harry Wilson (Shell, UK) summarised the discussion as finding
In supporting these conclusions Jerry Sherwood (OH Consultant, UK) reminded the meeting that the best way to achieve success was to build on some element of existing practice. SMEs readily recognise the benefits of first aid and medical facilities and occupational hygiene advice and services can be developed from such beginnings. Nurses could be trained in basic occupational hygiene and their skills used to introduce preventative measures. Such an approach is applicable to both developed and developing countries as it recognises the close links between public health and occupational health. Ken McDonald (CHEMOCH, Melbourne) suggested that larger companies could consider informal partnerships with SME neighbours, helping them identify and manage their occupational health problems. Similarly, co-operation between developed and developing companies should be encouraged, IOHA being an ideal vehicle to promote such partnerships. There was much to be done. The Chairman undertook to present a brief report on the workshop to the IOHA Board and seek support for the following action:
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