CHEMICAL HEALTH RISK ASSESSMENT – EXPERIENCING MALAYSIAN REGULATION 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 risk. 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.