Review of relevance of legislation
Small to medium sized companies have difficulty understanding how the HSNO legislation might effect them over the next few years. To help save them the time and expense of wading through all of the legislation and transfer information, we have developed a basic advisory service. The fee of $100 covers a 1 hour visit (Auckland region only) which includes a HaS Expertise consultant coming out to the site and considering the chemicals stored and used. We can then discuss with the manager(s) the likely current and future requirements for compliance. We can also advise on the most efficient and cost-effective options.
Identification, Inventories and Initial Assessment
The first step in the management of chemicals is the complete identification of chemicals used and stored on site. HaS Expertise has developed a number of effective templates to ensure that the inventory can be audited, useful and easily updated.
The OSH Code of Practice (Management of Substances Hazardous to Health) is used as a basis for an initial assessment of chemicals on site. This may also link into the assessment of classification under HSNO regulations.
· We use a standard inspection tool to ensure systematic identification of chemicals stored
· We have standard inventory templates
· We also check labelling, compatibility, segregation and leakage
· We record details for the client in the form of an inventory and an action plan
Following initial identification, a chemical risk assessment or classification of chemicals can be carried out.
To request further information regarding this service please contact us.
Risk assessment is carried out using methodology developed on a case-by-case basis. The basic principals of the Australia/New Zealand Standard (AS/NZ 4360) and in accordance with the OSH Code of Practice for the Management of Substances Hazardous to Health.
Generally, semi-qualitative measures of exposure and severity are established (in some cases linking to exposure monitoring - see occupational hygiene). These factors are linked, taking into consideration existing control measures, with a calculated total risk for each chemical.
Risk assessment is carried out primarily to prioritise control measures - i.e., to establish which chemicals present the highest risk and therefore should be prioritised in terms of implementation of new controls. Risk assessment can also be used as a tool when deciding whether or not to substitute a particular chemical in a process.
HaS Expertise generally carries out risk assessment in a very consultative manner - the users of various chemicals are one of the most important sources of information. Of course, it is also an area in which expertise relating to potential chemical effects is required.
Classification of Chemicals under HSNO
The control of chemicals under HSNO is dependent on the classifications – as defined in the HSNO regulations. There are over 100 different classifications, all with different controls associated.
The classification of some products can be simple, but for most, it requires a basic chemical knowledge, and in some cases extensive expertise in chemical properties. The classifications can be estimated at this time, although the exact classification will not be known until ERMA finalise the transfer for the specific product(s).
Estimating the classification of different products is particularly important for larger companies/sites who may need greater lead time to make changes necessary to comply with HSNO when their substances are transferred.
Note: Classifications for defined dangerous goods and scheduled toxic substances have been published by EPA (www.epa.govt.nz)
Once the classifications have been estimated (or obtained from ERMA transfer documents), then the controls that may apply can be found. Generally, this would mean working through the various regulations and considering the relevance of them to the classification and the storage/use at the site..
(Material) Safety Data Sheets and Labelling
Material Safety Data Sheets (MSDSs or SDSs) and labelling requirements will change significantly for many products that are transferred to HSNO control. Some companies are addressing this by updating all of the MSDSs and labels now to ensure compliance.
HaS Expertise has developed a standard 16 section format for MSDSs which conforms to the requirements of the HSNO Regulations. The format is also aligned to the latest Australian National Code of Practice for Preparation of Material Safety Data Sheets (NOHSC 2011:2003) and the Draft NZCIC Code of Practice (to be approved by ERMA).
Use of this format helps to save clients time and money and ensure consistency in the provision of quality information.
Training Requirements under HSNO
Staff handling certain chemicals will need to be certified as competent to handle that chemical. These people will be known as "approved handlers". Training to ensure that staff are competent is likely to be a new requirement for a number of industries.
Approved Handler Qualifications
An approved handler must know and be able to explain:
· the hazard classifications of the hazardous substances for which he or she is to be an approved handler
· the adverse effects that could be caused by each of the substances
· the controls which may be imposed under the Act for the substances
· his or her obligations and liabilities under the Act, including the purpose and principles of the Act; the offence provisions of the Act; the penalties and liabilities imposed by, the Act; and the effect of a compliance order
· which Regulations apply to the phases of the lifecycle of the substances and where those Regulations can be obtained
· any conditions of his or her test certificate as an approved handler
· the precautions required to prevent injury to a person or damage to the environment by any of the substances;
· the procedures to adopt in an emergency involving those substances.
An approved handler must know and be able to demonstrate a working knowledge of the operating equipment (including personal protection clothing and equipment) and procedures necessary to manage the hazardous substances for which he or she is an approved handler.
Two HaS Expertise consultants are currently being assessed to become "test certifiers" under HSNO. Hence, when the defined dangerous goods and scheduled toxic substances are transferred in early 2004, we will be able to assess premises and approved handlers with the goal of providing test certification.
Emergency plans taking into consideration the chemicals stored will be required for sites storing large quantities of hazardous substances. The requirements for emergency planning are also linked to the classifications and trigger levels.
The emergency procedures are comprehensive, and expert advice is normally required.
It is particularly important to consider emergency planning requirements as additional works or equipment may be required. In particular, requirements for secondary containment (or bunding) may take some time to meet.
To ensure ongoing compliance and an efficient system for managing chemicals, some documentation of processes is required. This will include processes for selecting/ purchasing new chemicals, seeking expert advice, consultation, regular inspections and disposal.
HaS Expertise have carried out numerous audits of systems to review potential conformance to HSNO and related legislation. These audits include review of procedures as well as storage and use facilities. Clients include: NZ Refinery Company (Marsden Point), BOC Gases, Montana.
HaS Expertise has also developed a chemical inspection tool. This includes review of items like compatibility, leakage, labelling and provision of emergency equipment, as well as checking of the inventory. For a number of clients, HaS Expertise provides an annual inspection service (e.g., Auckland Airport).