Document Sample
              By: Mr Chang Miau Sin andIr. Ahmad Nordeen Salleh
                      ESQ Consultancy Services Sdn Bhd

Mr. Chang Miau Sin

Holder of a Bachelor of Science in Chemical Engineering, Mr Chang is a registered
Safety Officer (Singapore & Malaysia) and an Accredited Safety Auditor with ILCI
(International Safety Rating System, ISRS). His other professional qualification
includes: Certified Competent Person by DOSH, Malaysia and also certified Hazardous
Materials Executive (CHME) of World Safety Organisation, Certified Safety
Professional (CSP) of American Society of Safety Engineers, member of International
Safety Council, USA (ISC-USA), member of the Malaysia Institute of Chemistry,
Process Safety Management (PSM) Auditor and EARA Environmental Auditor. He has
also been President, Vice- President, Vice-Chairman of various National and Local
Societies and Councils.

Mr Chang has more than 20 years of working experience with multinational companies
in the development, management, implementation and administration on all matters
related to Environment, Health and Safety (EHS) and Fire. He has provided many
auditing services to numerous chemical, petrochemical and other process industries in
the Asia Pacific region. He has also translated EHS and other production information
for multinational companies‟ projects in China, Hong Kong and Taiwan.

Ir. Ahmad Nordeen Salleh

Holder of a Bachelor of Science in Chemical Engineering, Ir. Ahmad Nordeen Salleh is
a Chartered and Professional Chemical Engineer. He was a member of National
Council for Occupational Safety and Health (1995-2000). Ir. Ahmad Nordeen Salleh
was also the President of Malaysia Society for Occupational Safety and Health (1991-
1999). In 1996, he was awarded “Tokoh Negera” by the Minister of Human Resource
Malaysia for his contributions to the nation on Occupational Safety and Health (OS&H).
He is experienced in the analysis, development and integration of OS & H systems and
culture. He has more than 25 years of working experience in Chemical, Petrochemical,
Oil and Gas industries, thus well exposed to OS & H risks and controls in these
industries. He has conducted numerous OS & H training in many disciplines and has
had a long-term hands-on involvement in environmental and safety auditing, accident
investigation and risk analysis.
1. Introduction

In Malaysia, we have enacted Occupational Safety& Health Act in 1994 to deal with the
proper management of OS&H at the workplace. The Government of Malaysia
emphasized that employers who created risks and employees who work with the risks
at the workplace must work together through the concept of „self-regulation‟ to manage
OS&H. Such act will create an objective to reduce or eliminate occupational accidents
and diseases at the workplace. Recently, Malaysian Government implemented many
regulations such as Safety and Health of workers who handle (use, store, ore transport)
hazardous substances. These regulations related to Safety and Health were gazetted
on 1997 and 2000 as listed below :

       (1) The OSH (Classification, Packaging and Labelling) Regulations 1997
           (OSH-CPL Regulations 1997), and
       (2) The OSH (Use and Standard of Exposure of Chemicals Hazardous to
           Health) Regulation 2000 (OSH-USECHH Regulations 2000).

         While the OSH-CPL Regulations 1997 provides the legal framework for
classification, packaging and labelling of hazard information provision for hazardous
chemical supply including Material Safety Data Sheet (MSDS/CSDS). The OSH-
USECHH Regulations 2000 provides the legal framework for the managing chemical
hazardous to health at the place of work. In addition, the Regulation could assist to:

       (a) Promote excellence in the management of those chemical
           substances hazardous to health, and
       (b) Set up workplace exposure standards so as to protect the health of
           persons at work.

       The following are the objectives of the Regulations

       1) To prevent the occurrence of occupational diseases, poisoning or adverse
          health effects from the use of hazardous chemicals at the place of work,
       2) To provide the minimum standard on the safe use of chemicals hazardous
          to health at the place of work, and
       3) To stipulate the maximum allowable exposure standard for occupationally
          exposed personnel.

        Under the Regulations, the duty to perform an assessment of health risks,
arising for the use of chemical hazardous to health at workplace is mandatory whereby
employers and employees are not permitted to use any chemical hazardous to health
unless an assessment has been conducted. And such assessment can only be
conducted by a competent assessor registered with the Dept of Occupational Safety
and Health and is referred to as Chemical Health Risk Assessment, or in short, CHRA.

2. The Objectives of the CHRA

The CHRA has the following objectives:

       (a) To identify the hazards to health posed by each chemical substance used,
           stored, handled or transported within the place of work,
       (b) To evaluate the degree of exposure of employees to the chemicals
           hazardous to health, either through inhalation, skin absorption or ingestion,
       (c) To evaluate the adequacy of existing control measures,
       (d) To conclude on the significance of the health risk posed by the chemicals
           hazardous to health, and
       (e) To recommend further appropriate control measures to prevent or reduce

3. Identification of Hazardous Chemicals

        The identification of chemical substances hazardous to health is necessary
before any detailed CHRA assessment or control measures can be instituted. The
employer is expected to register all chemicals hazardous to health that is being used,
stored, produced, handled or transported in their workplace.

The chemical register together with the Chemical Safety Data Sheets for each
chemical constitutes the workplace should be kept by the employer.

       The information of the chemical register includes:

       (a) Names of product, names of chemical content and the average usage
           quantity of all chemical hazardous to health.
       (b) Process and work area where the chemicals are used;
       (c) Name and address of the suppliers; and
       (d) Hazard information in the form of Chemical Safety Data Sheets.

It is essential to cover a complete assessment of all work units where employees could
be exposed to chemicals hazardous to health. There are :

       1)   Production employees
       2)   Support employees-maintenance crew, cleaners, laboratory staff
       3)   Contractors on site
       4)   Supervisors and managers
4. Permissible Exposure Limits

        Permissible exposure limits (PEL) are employee exposure limits that must not
be exceeded by any employee over the specified time limit. These limits denote
concentration levels above which exposure to chemicals hazardous to health must be
controlled and protected against chronic health effects of chemicals. The limits set are
based on eight hours time-weighted average values. Ceiling limits are set for chemicals
causing acute and chronic effects, which can not be exceeded at any time during the
work shift. These are the important information that the assessor needs to consider
during the assessment period.

5. Assessment Considerations

       The purpose of assessment is to gather and review relevant information so that
decisions about the risks and the appropriate precautions can be made, such as:

       (a) Which chemicals are in use and the nature of their hazards, i.e.; whether
           they may present a risk of acute or chronic ill health by entry through
           inhalation, skin absorption, ingestion;
       (b) The methods and procedures adopted in the processing, use, handling,
           storage, transportation and disposal of the chemicals hazardous to health;
       (c) The degree of exposure, which may include measured levels of the
           chemicals hazardous to health in the workplace environment, or absorbed
           by employees and the exposure time for relevant employees;
       (d) The potential for harm to occur in the use of those chemicals, by their
           Hazard Rating (as shown in Table 1);
       (e) The measures and procedures necessary to eliminate, isolate or minimise
           the exposure of employees (see Table 2); and
       (f) The measures, procedures, and control equipment necessary to control
           any accidental release of a chemical hazardous to health as a result of
           leakage, spillage from process or equipment failure.

6.   Assess the Measures and Equipment used to Prevent &
     Control Health Risk

        Assessment conducted will normally reveal inadequacies in the control
measures that require urgent attention. The aim of having control measures is to
protect employees against the risk of injury or disease from chemicals hazardous to
health. The underlying principles of assessment of Preventive & Control Measures is
as follows:

       (a) Identify & evaluate the measures and procedures for preventing or
           controlling exposure;
       (b)   Identify measures, procedures and equipment used to prevent or control
             any accidental emission of chemicals hazardous to health;
       (c)   Evaluate the design, installation and operation of the control measure &
             equipment to ensure the facility is designed Installed and supervised by
             Professional Engineer (P.E.) with proper Government recognized
             standard & requirement;

7. Workplace Monitoring

        The purpose of monitoring at the workplace is to assess employees‟ exposure
and to ensure proper maintenance of control equipment. The necessity for monitoring
will depend on the degree of exposure, toxicity, hazard phase and safety phase of the
chemical used. The assessor should thoroughly evaluate the situation and give
comment to carry out type and place of monitoring to be carried out by a qualified
Industrial Hygiene Technician. The competent Hygiene Technician must registered
with Department of Occupational Safety and Health (DOSH), Ministry of Manpower.

8. Health and Medical Surveillance

        Health surveillance means any examination which may be necessary to detect
early biological effects, responses and symptoms. The surveillance is required to
review the records and occupational history and illness record of an individual worker
for the purpose of identifying changes in health status due to occupational exposure to
chemicals hazardous to health.

       The purposes of such surveillance are:

       (a)    To identify individuals at significant risk of an identifiable disease or
              adverse effect so that actions can be taken to protect their health and/or
              inform them of the adverse effect; and
       (b)    To establish the adequacy of control measures in use so that both
              individuals and groups can be better protected if this is found necessary.

        Under this Regulation medical surveillance is required to be under-taken for 34
chemicals/under schedule II in the OSH – USE CHH Regulation 2000. Employees with
certain medical diseases such as having Lead poisoning, heart problem or asthma
should be protected by having them removed from the hazardous atmosphere and be
placed in a conducive workplace so as not to aggravate their medical condition. They
would be allowed to return to work at the same work place, only when their medical
examination shown their health is back to normal.
9. Assessment Report

       The OSH-USECHH Regulations 2000 stipulate that the assessor to submit to
the employer within one month after the completion of the assessment. The report
should be monitored in good order and condition for a period of not less than 30 years.

The CHRA Report includes :-

-      Register Chemical which is Hazard to Health
-      Determinate degree of hazards, risk phases and safety phases
-      Review and inspect the workplace environment
-      Assess adequacy of preventive control measure / equipment
-      Review the result record of Health & Medical Surveillance
-      Analysis exposure risk with existing data or monitoring data
-      Identify all the risk with Risk Matrix Table
-      Conclusion of Assessment with recommendation and action to be taken

10. Conclusions

        CHRA indeed can save lives, it is hoped that all companies or factories which
fall under the requirement should conduct the act. Such act can reduce employees or
workers being exposed to chemicals hazardous to health. It is mandatory for
employers to create a safer and healthier working environment for their employees as
well as their children and family. Experiencing Malaysian Regulation : The Chemical
Health Risk Assessment can be used as an epitome for many developing countries.
Table1: Hazard Rating (HR)

HR                      Health Effects                             Hazard Category
 5    Local: Injury to the skin, eyes or mucous membranes       *Very Toxic Chemicals:
      of sufficient severity to threatens life by a single      LD50<25 mg/kg (oral)
      exposure.                                                 LD50<50 mg/kg (skin)
      Systemic: Severe irreversible effects (eg central         LC50<0.5 mg/litre
      nervous system effects, kidney necrosis, liver lesions,
      anemia or paralysis) after a single exposure.

      Known human carcinogens, mutagens or teratogens.          *Category 1 carcinogen,
                                                                mutagen & teratogen.

  4   Local: Injury to the skin, eyes or mucous membranes       *Very Corrosive (R35:
      of sufficient severity to cause permanent impairment,     Causes severe burn)
      disfigurement or irreversible change from single or       *Toxic Chemicals:
      repeated exposure.                                        LD50: 25-200 mg/kg (oral)
      Systemic: Very serious physical or health impairment      LD50: 50 –400 mg/kg (skin)
      by repeated or prolonged exposure.                        LC50; 0.5-2 mg/litre

      Probable human carcinogens, mutagens or                   *Category 2 carcinogen,
      teratogens based on animal studies.                       mutagen & teratogen.
HR                    Health Effects                        Hazard Category
3    Local: Serious damage to the skin, eyes or mucous   *Corrosive (R34: Causes burn)
     membranes from single or repeated exposure.         *Irritant-serious eye damage
     Systemic: Severe effects after repeated or          *Harmful chemicals:
                                                         LD50: 200-500 mg/kg (oral)
     prolonged exposure.                                 LD50: 400-2000 mg/kg (skin)
                                                         LC50; 2-20 mg/litre

     Possible human or animal carcinogens or             *Category 3 carcinogen,
     mutagens, but for which data is inadequate.         mutagen & teratogen.

2    Local: Reversible effects to the skin, eyes or      *Skin sensitizers
     mucous membranes not severe enough to cause         *Skin irritants
     serious health impairment.
     Systemic: Changes readily reversible once
     exposure ceases.

1    No known adverse health effects.                    Not classified as hazardous.