Chemicals Risk Assessment
The identification of hazards, the evaluation of their risks and the putting in place of control measures to secure the health and safety of employees is a major element for managing health and safety under the Safety, Health and Welfare at Work Act, 2005.
The Chemical Agent Regulations 2001 and 2015 point out the specific requirements necessary to complete a Chemical Agents risk assessment of the chemical agents used in the work place. A generic assessment is unlikely to meet the requirements of the legislation.
The Risk Assessment steps:
- Identify the chemical hazards.
- Consider who might be affected and how they might be harmed.
- Evaluate the risks- what are you doing now and what further precautions are needed?
- Document and implement your findings.
- Update and review as required.
The first step in risk assessment is to identify the chemical hazards. A chemical inventory can be useful. When recording all potential chemical hazards, look beyond the obvious. As well as considering the use of chemical agents, look at chemicals or substances that may be produced by a process, for example welding fumes, respirable crystalline silica etc.. Evaluate the internal transport, storage and the quantities of chemicals being stored as well as waste disposal and emergencies e.g. spill or leak. Consider all materials and mixtures, for example, items like glues, food stuffs, cosmetics, materials used by maintenance such as oils, gardening materials, water treatment and cleaning materials. It may be possible to group chemicals into specific tasks and complete a task or activity based chemical risk assessment.
Check to see whether any of your chemicals are subjected to any Restrictions or Authorisations under the REACH regulation. Again, a chemical inventory can be useful here. Your chemical supplier can supply you with this information and must supply you with a safety data sheet, (SDS) which should be provided with each hazardous material. The SDS is a primary source of health and safety information. For example the SDS may have your use included in the attached exposure scenarios (ES). It will include occupational exposure limits where they exist or it may have derived no effect levels (DNELs). (See SDS information)
The second step is to consider who (groups of employees) might be affected and how the material/chemical might harm them. Recognise that some employees may need special consideration, for example, language needs of non-national workers, potential exposure of pregnant employees etc. The different routes of exposure need to be considered e.g. dermal exposure, absorption, inhalation, ingestion and injection. While the employer is responsible for carrying out the risk assessment, employees should be involved.
The third step is evaluating the risks and deciding on precautions. Write down what precautions you are already taking and apply the principles below in the following order to determine what additional precautions are required:
- Eliminate the substance or substitute a less hazardous chemical
- Prevent exposure, for example, by containment and use of local exhaust ventilation (Engineering controls)
- Organise work to reduce the number of employees that might be exposed. Challenge how processes are carried out. Are there smarter ways of carrying out an activity so that the potential for exposure is eliminated or reduced.
- Select, provide training and issue personal protective equipment (this may be required immediately)
- Provide welfare facilities (first-aid and washing facilities to remove contamination)
The fourth step is to document and implement your findings. Write down your findings and discuss them with your employees. Consultation with your employees is necessary at every step and especially when implementing the findings of your chemicals risk assessment. Be specific with precautions such as PPE e.g. "wear half face mask with A2P2 filter". You may need to draw up an action plan, detailing who is responsible, for what action and when will it be carried out.
As no workplace remains the same, the fifth step is to review your risk assessment at least once per year, and update if necessary. When changes such as new employees, machinery, equipment or materials occur in the workplace it is necessary to review the risk assessment. Change in work patterns such as overtime or shift work, the needs of pregnant/nursing employees and those with special needs must also be included.