The Health and Safety Executive (HSE) has recently completed an open consultation on the implementation of new and revised Workplace Exposure Limits (WELs) for 31 hazardous substances. The proposed new limits will look to better protect workers from the potential ill-health effects of working with the substances and, should the proposal be accepted, will be put into effect in August 2018, becoming immediately legally binding.
Now that the 31 substances and their proposed new exposure limits are known, Catherine Hare, Alcumus Sypol’s Monitoring Services Operations Manager has provided practical advice on how you can effectively adhere to these new or revised WELs to ensure you comply with legislation and keep your people safe from the risks of exposure.
Five practical steps to reduce the risk of ill health
To ensure that exposure limits aren’t exceeded, workplace monitoring should be conducted by a monitoring services expert or occupational hygienist. Air monitoring will assess levels of exposure via inhalation of these substances and can be used to allow quantitative assessment of the levels your staff are experiencing and establish a baseline. If it is found that your workers are exposed to a substance approaching or above the WEL then control measures will need to be implemented to suitably keep your workers safe from the risks that the substance poses to their health. In fact, for some substances such as carcinogens, mutagens, reprotoxins and respiratory sensitisers, there is a duty on employers to ensure that exposure is at a level which is as low as reasonable practicable and in any case below the WEL.
Following the COSHH hierarchy of control, the first and most effective control method to be considered is that of elimination. Can the work be completed without using the hazardous substance? If yes, then this control method should be implemented ahead of any other as it completely removes the hazard and risk to employees.
As substances often hold properties unique to a process, elimination is not always possible. When this is the case, the second most effective control method to be considered is that of substitution. This involves identifying a hazard-free or less hazardous substance to perform the relevant task. Another form of substitution is to not replace the substance completely, but substituting the process in which the original substance is used so it is used less dangerously or released in a less hazardous form. Where the substitute substance or method still carries a hazard, regular monitoring will still be required to ensure that workers aren’t being put at risk and that a new hazard is not being unwillingly created.
The next most effective control measure is engineering controls. This involves making physical changes to the workplace that enables the hazardous substance to be removed at source before workers encounter it. Engineering controls avoid the need to rely on worker behaviour and/or PPE and examples include local exhaust ventilation (LEV) systems such as fume hoods, glove boxes or biosafety cabinets. Again, if such controls are implemented then regular monitoring such as LEV testing is required to ensure that they are working as intended and providing adequate levels of protection for staff. Air monitoring can also be used as a way of demonstrating effective control is being achieved.
The fourth control method in the hierarchy of control is administrative controls. These controls do not remove the hazard but are aimed at changing the behaviour of workers to minimise their exposure. Examples of typical administrative controls include procedural change, training and safety and warning signage and labelling. These need to be periodically reviewed to ensure that they are both relevant and fit for purpose.
The final and least effective control method is the provision of Personal Protective Equipment (PPE). PPE should only be considered as a last resort control measure if the other four are not feasible, the hazard isn’t controlled, or the exposure isn’t sufficiently reduced following implementation. This is because any failures or damage to PPE could render them ineffective as a ‘last line of defence’, leading to exposure and potential ill health complications to staff. Examples of PPE when dealing with hazardous substances include gloves, respirators and safety goggles/glasses and all equipment should be both suitable for the task and the person using it. Ill-fitting PPE can prove to be ineffective in preventing exposure, so fit testing should be carried out with employees to make sure the PPE fits appropriately and the hazard is mitigated. An example of this would be face fit testing for tight fitting respirators. Regular checks and examination of the PPE should also be conducted to help identify any damage or wear and tear that means that the PPE no longer protects its user adequately.
The importance of regular monitoring and assessment
The effective implementation of one or more of these control measures should enable you to keep your staff safe by meeting the new WELs that are set to come into immediate effect in August 2018. However, monitoring is initially needed before controls are implemented to establish your current exposure. This should be followed by testing at regular intervals to ascertain whether the controls put in place are working effectively and to make sure that the new limits for that substance are being complied with.
Alcumus Sypol provide a comprehensive range of workplace monitoring services to help you to adhere to workplace exposure limits and to keep your staff safe and healthy. You can find out more here.