ADNOC-COPV3!08!2005 (Ver-1) - Guideline on Occupational Health Risk Assessment (OHRA)

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ABU DHABI NATIONAL OIL COMPANY HEALTH SAFETY AND ENVIRONMENTAL MANAGEMENT MANUAL OF CODES OF PRACTICE VOLUME 3 : OCCUPATIONAL HEALTH

GUIDELINE ON OCCUPATIONAL HEALTH RISK ASSESSMENT( OHRA) ADNOC-COPV3-08

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RECORD OF REVISION Revision No.

Date

Section / Page

Reason

Copyright The copyright and all other rights of a like nature in this document are vested in Abu Dhabi National Oil Company (ADNOC), Abu Dhabi, United Arab Emirates. This document is issued as part of the Manual of HSE Codes of Practice (the “Manual”) and as guidance to ADNOC, ADNOC Group Companies and independent operators engaged in the Abu Dhabi oil & gas industries. Any of these parties may give copies of the entire Manual or selected parts thereof to their contractors implementing HSE standards in order to qualify for award of contracts or for the execution of awarded contracts. Such copies should carry a statement that they are reproduced by permission of ADNOC, and an explanatory note on the manner in which the Manual is to be used. Disclaimer No liability whatsoever in contract, tort or otherwise is accepted by ADNOC or any of its Group Companies, their respective shareholders, directors, officers and employees whether or not involved in the preparation of the Manual for any consequences whatsoever resulting directly or indirectly from reliance on or from the use of the Manual or for any error or omission therein even if such error or omission is caused by a failure to exercise reasonable care.

All administrative queries should be directed to the Manual of HSE Codes of Practice Administrator in:

Environment Health & Safety Division Supreme Petroleum Council, Abu Dhabi National Oil Company, P.O. Box : 898, Abu Dhabi, United Arab Emirates. Telephone : (9712) 6023782 Fax: (9712) 6668089 Internet site: www.adnoc.com E-mail: [email protected]

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CONTENTS PAGE I. PURPOSE ............................................................................................................... 5 II. DEFINITIONS.......................................................................................................... 5 III. EXISTING LAWS .................................................................................................. 11 1. INTRODUCTION................................................................................................... 12 2. PREPARATION .................................................................................................... 16 2.1 Define Management’s Roles and Responsibilities and Allocate Appropriate Resources (Step 1) ................................................................ 16 2.1.1 Draw-up an Occupational Health Risk Assessment Programme 16 2.1.2 Contractors ....................................................................................... 16 2.2 Define Structure for Implementation (Step 2) .......................................... 17 2.2.1 Assessment Units ............................................................................ 17 2.2.2 Assessment Teams.......................................................................... 17 2.2.3 Assessment Team Leader............................................................... 18 2.2.4 Job Types.......................................................................................... 18 2.2.5 Tasks and Hazardous Agents......................................................... 18 2.2.6 Generic Approach ............................................................................ 19 3. IMPLEMENTATION .............................................................................................. 20 3.1 Gather Information (Step 3) ....................................................................... 20 3.1.1 Agents and Their Harmful Effects .................................................. 20 3.1.2 Nature and Degree of Exposure ..................................................... 21 3.2 Screening and Performance Criteria ........................................................ 25 3.2.1 Exposure Limits ............................................................................... 25 3.2.2 Specifications for Engineering Controls ....................................... 27 3.2.3 Specifications for Procedural Controls ......................................... 27 3.2.4 Specifications for Personal Protective Equipment (PPE)............ 27 3.2.5 Specifications for Emergency (Recovery) Measures ................... 27 3.3 Evaluate the Risk to Health (Step 4) ......................................................... 28 3.3.1 Hazard Rating ................................................................................... 28 3.3.2 Exposure Rating............................................................................... 29 3.3.3 Risk To Health .................................................................................. 29 3.3.4 Conclude Evaluation........................................................................ 30 3.3.5 Need for Further Information/Advice ............................................. 30 3.4 Decide on the Remedial Action (Step 5)................................................... 30 3.4.1 Hierarchy Of Controls...................................................................... 30 3.4.2 Additional Measures ........................................................................ 31 3.5 Record the Occupational Health Risk Assessment (Step 6).................. 32 3.5.1 Make a Record .................................................................................. 32 3.5.2 Suggested Record Format .............................................................. 33 3.5.3 Develop a Work History of Employee Exposure........................... 33 3.5.4 Inform Staff ....................................................................................... 34 3.6 Review the Occupational Health Risk Assessment (Step 7).................. 34 3.6.1 Action Items...................................................................................... 34 3.6.2 Review of Occupational Health Risk Assessments ..................... 34 3.6.3 Audit .................................................................................................. 35

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REFERENCES ........................................................................................................... 36 ADDITIONAL DATA SOURCES................................................................................ 36 APPENDIX 1 Competence........................................................................................ 39 APPENDIX 2 Examples of Hazardous Agents and Their Origin .......................... 42 APPENDIX 3 Identifying Hazardous Agents .......................................................... 45 APPENDIX 4 Estimating Exposures Without Quantitative Measurement – Examples of Work Situations ............................................................ 48 APPENDIX 5 Occupational Health Risk Assessment : Example of Record Format .................................................................................................. 51

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I.

PURPOSE Within ADNOC Group Companies many diverse activities are carried out involving processes, operations and materials which, to a greater or lesser extent, can pose risks to health, as well as to safety and the environment. Much is now known about the occurrence and harmful effects of agents hazardous to health present in the work place (e.g. chemicals, dusts, noise, heat, radiation, micro biological agents). It is important to apply this knowledge to ensure that exposure to those hazards is adequately controlled across all ADNOC Group operations. This document provides guidance on a structured approach to identifying health hazards and evaluating the risk in the working environment. This process is known as Occupational Health Risk Assessment (OHRA). The recommendations emerging from Occupational Health Risk Assessment provide the input into the HSE Management System and HSEIAs to ensure ongoing control of health risks and continual improvement in health performance. Factors that affect the psychological well-being of an employee are not addressed in this document.

II.

DEFINITIONS Acute Health Effects Acute health effects are those which occur suddenly and in a short time (seconds to hours) following exposure, generally to higher levels or concentrations of a health hazard. Agents Hazardous to Health See 'Health Hazard' As Low as Reasonably Practicable Means to reduce a risk to a level which is as low as reasonably practicable and involves balancing reduction in risk against the time, trouble, difficulty and cost of achieving it. This level represents the point, objectively assessed, at which the time, trouble, difficulty and cost of further reduction measures becomes unreasonably disproportionate to the additional risk reduction obtained. Assessment Team A group of people selected to carry out Health Risk Assessments within an Assessment Unit. Assessment Team Leader The line manager, or his representative, responsible for co-ordinating the activities of the Assessment Team.

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Assessment Unit A unit comprising a complete operational site, a self-contained segment of a large or complex site, or a group supporting a single business process, so defined as to assist in the management of OHRA within an organisation. Audiometry The measurement of an individual's hearing level using an audiometer. Baseline (Measurement) Survey Quantified personal exposure data obtained to compare against the relevant Occupational Exposure Limit(s) Biological Agents Any micro-organism and their products, cell-culture or human endoparasite, including any which have been genetically modified, which may cause any infection, allergy, toxicity or otherwise create a hazard to human health. Biological Effect Monitoring Biological effect monitoring is the measurement of a reversible biochemical change caused by the absorption of the substance; the degree of change being below that associated with toxic injury and not associated with a known, irreversible pathological effect. Biological Monitoring Biological monitoring involves the measurement of a hazardous substance or its metabolites* in body fluids, usually blood, urine or exhaled breath. *

A metabolite of a substance is either a breakdown product or modified (more soluble) form suitable for excretion by the kidney in the urine or by the liver into the intestine.

Chemical Agent Chemical is a substance with a distinct molecular composition that is produced by or used in a chemical process. Chemical agent is a chemical substance, when exposed to, causes a deleterious effect (harm) on the health of the worker. For example, irritants, carcinogens, systemic poison, sensitisers. They may be present in the working environment as gases, vapours, mists/aerosols, fumes, dusts, liquids or solids. Chronic Health Effects Chronic health effects are those which occur gradually over a long period of time following repeated and prolonged exposure to relatively low levels or concentrations of a hazardous agent. In certain cases, a short term exposure may result in a chronic health effect. Continual Improvement Year-on-year enhancement of overall HSE performance, not necessarily in all areas of activity, resulting from continuous efforts to improve.

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Control See 'Hierarchy of Health Control'. Detailed (Measurement) Survey Carried out if the degree and pattern of personal exposure cannot be reliably determined by a Baseline (Measurement) Survey. Engineering Controls The control of exposure to a hazardous agent by the design of plant and equipment, e.g. containment, exhaust ventilation, mechanical aids. Epidemiology Epidemiology is the study of the distribution and determinants of diseases in human populations. Epidemiological studies in industry, some times referred as Occupational epidemiology, enable us to establish the relationship between work environment and the health, type of illnesses and ultimate causes of death of working people To be effective, epidemiology must be based on accurate data on the occurrence of disease, types of jobs and exposures. The quality of the statistical analysis, and therefore the information produced, improves with (i) larger number of people and (ii) longer follow-up periods. Some diseases, particularly cancers, may take several decades to appear. Ergonomics Ergonomic is the scientific discipline concerned with the understanding of interactions among humans and other elements of a system, and the profession that applies theory, principles, data and methods to design in order to optimise human well-being and overall system performance. Ergonomics draws together the disciplines of occupational physiology, psychology and design. Physical stresses on the body may result in acute (short term) and chronic (long term) damage (musculoskeletal disorders) and lowering of performance (e.g. fatigue). The mental demands of work may cause psychological stresses. Ergonomics seeks to recognise and evaluate these factors. Control can then be achieved by fitting the task to the individual. Where ergonomics has not been taken into account in the design of workstations and tasks, personnel may suffer, for example, discomfort, musculo-skeletal disorders, psychological stress. Exposure Profile Nature and degree of exposure to health hazards. Exposure Rating The chance of over-exposure to a health hazard evaluated as Very Low, Low, Medium, High or Very High.

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Generic Approach & Generic Record Where several operational sites carry out similar activities involving potential exposure to similar health hazards, it may not be necessary to repeat Health Risk Assessments at each site independently. In this situation a 'Generic Approach' to HRAs may be used in which detailed HRAs are only carried out at representative operational site(s) selected to ensure all common activities are covered. The resultant 'Generic Record' is then read across to the other comparable sites. Hazard Any substance, physical effect, or condition with potential to harm people, property or the environment or affect on the company reputation. Health Hazard This is an agent with potential to cause harm to health. These agents may be biological, chemical, physical, ergonomic or psychological in nature. ‘Health hazards' are also known as 'agents hazardous to health' and 'hazardous agents'. These terms are interchangeable. (Health) Hazard Rating This is a measure of the severity of potential health effects based on the hazardous properties of the agent. Health Risk Health risk is the combination of likelihood that harm to health may occur (which is related to exposure) multiplied by the severity of health effects (hazard). Health Surveillance Measures for monitoring the health of the workforce if risk to health cannot reasonably be excluded. This includes symptom review, clinical assessment, medical examination and special investigation of the immune system. Hierarchy of Health Control Measures The means of controlling exposure to health hazards, listed in preferential order as follows:− Elimination − Substitution (alternatives) − Engineering (plant and equipment) − Procedural − Personal protective equipment HSE Management System (HSEMS) The company structure, responsibilities, practices, procedures, processes and resources for implementing health, safety and environmental management. Job Type Jobs with a similar exposure profile.

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Job Type Code A code allocated to individual Job Types to assist in the compilation of a work history of employee exposure. Medical Surveillance Medical surveillance is defined as an assessment of an employee's health using medical or biological procedures (biological effect monitoring) to identify any significant abnormalities attributed to exposure to hazardous agents, at an early stage as possible. The procedures used should be of acceptably high sensitivity, specificity and predictive value in detecting abnormalities related to the nature and degree of exposure. The criteria for interpreting the data should be known and the procedures should be safe, easy to perform, preferably non-invasive and acceptable to employees. Surveillance should only be undertaken if the possible detected changes are reversible or measures are available to prevent their further development. Occupational Exposure Limit (OEL) The airborne concentration of chemical agents and levels of physical agents to which workers may be repeatedly exposed day after day without adverse effect. OELs are based on the best available information from industrial experience, from experimental human and animal studies, and when possible, from a combination of the three. The basis on which the values are established may vary from agent to agent; protection against impairment of health may be a guiding factor for some, whereas reasonable freedom from irritation, narcosis, nuisance or other forms of stress may form the basis for others. Note: ADNOC recognizes the latest ACGIH TLV data as its OEL. Occupational Health Adviser A person who, on the basis of his expertise, assists line management with the development and implementation of the occupational health programme. Occupational health advisers may include occupational health specialists and physicians, medical advisers and occupational health nurses, occupational hygienists, safety advisers, toxicologists, health inspectors and ergonomists. Occupational Health Risk Assessment The systematic identification of health hazards in the workplace and subsequent evaluation of health risks. This process takes existing control measures into account and identifies and recommends further preventive or control actions where appropriate. Occupational Health Risk Assessment Programme The systematic implementation of Health Risk Assessment within an organisation.

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Performance Criterion A standard of performance of an operation, activity or system element, which may include company wide 'Standards' and general applicable Group Guidance documents (e.g. Codes of Practice/Guidelines). A Performance Criterion is bound to be at least as stringent as or more stringent than the respective Screening Criterion. Periodic Exposure Measurement See Routine Exposure Monitoring. Personal Protective Equipment (PPE) The collective term describing clothing and equipment used to protect the individual against agents hazardous to health. Physical Agents For example, noise and vibration, ionising and non-ionising radiation, extreme temperatures, humidity. Procedural Controls These include: supervision, work methods, housekeeping, personal hygiene, information, instruction, training. Risk Risk is the product of the measure of the likelihood of occurrence of an undesired event and the potential adverse consequences which this event may have upon: - People – injury or harm to physical or psychological health - Assets (or Revenue) – damage to property (assets) or loss of production - Environment – water, air, soil, animals, plants and social - Reputation – employees and third parties. This includes the liabilities arising from injuries and property damage to third parties including the cross liabilities that may arise between the interdependent ADNOC Group Companies. Risk = Frequency x Consequences. Routine Exposure Monitoring Exposure measurements carried out on a regular basis to a specified protocol to check if exposure conditions have changed. Screening Criterion 1. a value which should not be exceeded to prevent effects, or 2. a value against which the risk tolerability of the identified hazard or effect can be judged, or 3. a principle or code of practice reflecting a generally accepted quality standard to perform an activity (e.g. every hardware modification will be subject to a plant change procedure).

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A Screening Criterion can be established based on for example legal requirements or scientifically derived limits, or other considerations such as acceptability of risk (probability of occurrence times severity of consequence). Severity The degree to which an agent hazardous to health can cause harm Standard A prescribed set of rules, conditions or requirements. Standard is an allinclusive term denoting specifications, recommended practices, procedures, guidelines, philosophies and handbooks. Walk-Through Survey A walk-through survey is designed to provide an overview of health hazards and associated potential exposures involving a particular working population. Work History of Employee Exposure A record of an employee's exposure profile during his/her working career with the company. At its simplest, it consists of name, employee identification number and a list of Job Type Codes and dates. Worst Case Measurement Quantified personal exposure measurement of events involving potentially high exposure. Further detail on definitions is provided in the document ADNOC Manual of Codes of Practice ‘Guideline on HSE Definitions and Abbreviations’ [Ref. 1].

III.

EXISTING LAWS Current UAE Legislation relevant to the subject of this guideline includes: •

Federal Law No. 8, 1980, Regulation of Labour Relations and Order Issued in Implementation thereof.

[1] ADNOC Manual of Codes of Practice: ‘Guideline on HSE Definitions & Abbreviations’’, ADNOC-COPV1-05.

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1.

INTRODUCTION The ADNOC Code of Practice ‘Framework of Occupational Health Risk Management’ [Ref. 2] provides the framework for managing occupational health in Group Companies with the aims of:•

Protecting the health of employees, contractor personnel and others from agents hazardous to health that may be associated with the working environment, and



Promoting employees' health.

The cornerstone of the first aim is Occupational Health Risk Assessment (OHRA), in which the activities of an operation are reviewed in order to:•

Identify and create an inventory of agents potentially hazardous to health;



Evaluate (assess) the risk to health associated with exposure to these agents against specified screening criteria;



Decide on the control measures required, if any, to remove or reduce the risk to health to a level as low as reasonably practicable. Consider any emergency (recovery) measures needed to mitigate acute and/or chronic health effects, should control measures fail.

When applied systematically within an organisation, OHRA can be used as a management tool to assist in: •

The comprehensive identification of work place health hazards for risk and health impact assessments.



Prioritising the implementation of OHRAs, focussing first on those activities involving the greatest potential risk to health.



Prioritising the implementation of additional control measures, where necessary, to minimise the health risk to a level as low as reasonably practicable.



Including OHRA as an integral component of introducing new, or changes to existing, plants/processes/activities to ensure health hazards are adequately controlled before the new/revised operation commences.



Educating staff on the health hazards, risks and measures of control appropriate to their tasks.



Determining appropriate records on staff exposures to health hazards which, when combined with health surveillance records, can be used to identify health trends and problem areas for action, to fulfil legal requirements and to safeguard the company against unforeseen liabilities.

[2] ADNOC Manual of Codes of Practice: ‘Code of Practice on Framework of Occupational Health Risk Management’, ADNOC-COPV3-01.

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Developing the means for promoting continual improvement in occupational health standards and performance.



Promoting the well-being of the workforce.

The process of OHRA can be conveniently broken down into several steps which are described below: PREPARATION Step 1.

DEFINE MANAGEMENT'S ROLE AND RESPONSIBILITIES AND ALLOCATE APPROPRIATE RESOURCES A programme for implementing Occupational OHRA as part of the Group Companies Occupational Health Management System should be established, in which the roles and responsibilities of line managers, specialist advisers, supervisors and workforce are defined.

Step 2:

DEFINE STRUCTURE FOR IMPLEMENTATION This includes the following activities: •

Divide the organisation into manageable Assessment Units, these being dependent on the size and nature of the operation.



Select and appoint Assessment Teams and Team Leaders to carry out the OHRAs, taking into account competencies required.



Identify job types within the Assessment Units which contain staff groups with similar exposure profiles, e.g. operators, drivers, maintenance personnel.



Identify tasks carried out by each Job Type and all associated hazardous agents so that the nature of exposure to those agents can be assessed during actual operations.



Decide whether a generic approach to OHRA is appropriate, whereby similar operations within a plant or at different locations can be assessed collectively.

IMPLEMENTATION Step 3:

For each Job Type GATHER INFORMATION on: •

Agents and their harmful effects;



Nature and degree of exposure to the agents; and



Screening and performance criteria against which to evaluate the risk to health. These include: exposure limits and specifications for engineering, procedural, personal protective equipment and emergency (recovery) control measures.

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Step 4:

Use the information gathered in Step 3 to EVALUATE THE RISK TO HEALTH. The Assessment Team should make a judgement on: •

Severity of the possible ill-health effect from over-exposure to the agent to give a Hazard Rating. The greater the severity, the more stringent the measures required for controlling exposure.



Chance of over-exposure to the agent to give an Exposure Rating, taking into account the effectiveness of existing control measures.



Risk to health by combining the above Ratings in a matrix. Also take into account the number of people exposed.

The overall conclusion of the OHRA should be recorded indicating whether or not action is necessary to reduce the risk to health. Step 5:

DECIDE ON THE REMEDIAL ACTION resulting from Step 4, including priorities, responsible persons and target dates. Take into account the 'hierarchy of controls' and the concept 'as low as reasonably practicable'. In addition, determine the need for:

Step 6:



Periodic exposure measurement/routine exposure monitoring.



Health surveillance.



Routine maintenance of controls.



Provision of information, instruction and training to ensure staff are familiar with the health hazards, potential risks and measures of control relevant to their tasks.

RECORD THE OCCUPATIONAL HEALTH RISK ASSESSMENT including: •

Information gathered for the OHRA (Step 3).



The conclusions of the OHRA (Step 4).



An explanation of how the conclusions were arrived at to assist persons reviewing the OHRA at a future date.



The remedial action required (Step 5).

In addition: •

Ensure that an individual's Medical Record is linked to the OHRA to create a work history of exposure.



Inform staff of the results and record that the information has been made available.



Ensure that OHRAs are archived when no longer current so that the information is not lost.

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Step 7:

REVIEW THE OCCUPATIONAL HEALTH RISK ASSESSMENT to ensure ongoing control, including: •

Follow-up of action items.



Periodic Assessment Review to ensure that the OHRA remains valid.



Audit of all steps in the process.

The remaining sections of this Guideline provide methodologies for the above steps to OHRA.

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2.

PREPARATION

2.1

Define Management’s Roles and Responsibilities and Allocate Appropriate Resources (Step 1)

2.1.1 Draw-up an Occupational Health Risk Assessment Programme A management representative should be appointed to draw up a programme for implementing the Occupational Health Risk Assessment. Management commitment to, and involvement in, the programme should be visible and include planned follow-up of action items. The OHRA programme should include: − Definition of the role and responsibilities of line managers, specialist advisers, supervisors and work force in implementing the programme. − OHRA of existing operations and new or revised plants/processes/ activities. Infrequent or one-off activities should be included, as should foreseeable emergencies. − The selection of competent persons (Assessors). − The provision of the necessary resources (e.g. manpower, equipment, information, training, time allocation) and support for the Assessors. In addition, decisions should be made on: − The structure for implementing the programme, its co-ordination and review. − The identification of Screening and Performance Criteria against which actual exposures and the performance of control (and recovery) measures for reducing health risks to as low as reasonably practicable are measured. − Prioritising the implementation of OHRAs. − Prioritising the implementation of additional control measures. 2.1.2 Contractors Formal arrangements should be made to ensure that, where appropriate, contractors carry out OHRAs of their operations in a manner compatible with the procedure outlined in this document. Where there is ambiguity in respect of responsibility for carrying out the OHRA for a particular activity, i.e. the Contractor or the Group Company, this should be clearly defined in the terms of the Contract.

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2.2

Define Structure for Implementation (Step 2)

2.2.1 Assessment Units A large or complex site may be broken down into Assessment Units for ease of management, and each assessed as a separate Unit. Assessment Units should, as far as possible, be self-contained, either physically or in terms of the process being carried out. Examples are: − The complete operational site where the activity is well-defined, e.g. distribution terminal, office block, lub-oil blending plant. − Individual processing units within a chemical manufacturing plant or refinery complex. − A group or function supporting a single Business Process, e.g. Exploration and Production drilling, well operational activities. 2.2.2 Assessment Teams Line management, operational staff and specialists all have a role in carrying out OHRAs. Assessment Teams should be formed under the guidance of a Team Leader. The number of Assessors selected for a particular Team and their level of competency is a function of: •

The complexity of the activity being assessed.



The stage in the OHRA process. This progresses from an information gathering exercise in which operational staff have an important input, to the requirement for specialist skills for tasks, such as reviewing the effectiveness of engineering control measures (e.g. ventilation systems), carrying out measurements to quantify exposure to a particular agent, or assessing ergonomic design.

The Team Leader, or his Adviser, must be competent to decide when expert advice is required. See Appendix 1 for guidance on competence. It is recommended that the core members of any Assessment Team include: − Line manager, or his representative, from the Assessment Unit (Team Leader). − Supervisor for the Job Type being assessed. plus, where appropriate: − − − −

Operational staff (see note *) Occupational Health Advisers Technologists/Engineers Other specialists

The OHRA record should reflect input from all members of the Assessment Team.

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Note *: The importance of involving operational staff cannot be over-stated. Not only do they have a detailed knowledge of their tasks which assists in evaluating any potential health risks, their involvement will increase their own appreciation of the hazards and the need for the control measures designated for a particular task. 2.2.3 Assessment Team Leader A Team Leader should be appointed who is responsible for co-ordinating the OHRA programme and for reporting to Management. It is recommended that the Team Leader is a Line Manager from the Assessment Unit in question, or his representative. 2.2.4 Job Types Allocate personnel within each Assessment Unit into common jobs, referred to as Job Types, which have broadly similar exposure profiles. An organisation chart is a useful tool for this purpose. To ensure no Job Types are overlooked, also consider activities carried out by contract staff. Typical Job Types likely to be found within Group Company operations include: − Plant operators (sub-divided by operational group, e.g. production, finished product filling, warehouse). − Road tanker drivers (sub-divided by product(s) distributed). − Maintenance staff (sub-divided by maintenance type, e.g. mechanical, electrical, vehicle, building). − Cleaning staff (plant and/or office). − Laboratory technicians (sub-divide, as appropriate); − Administrators (staff whose tasks are mainly office-based). − Field staff (e.g. exploration personnel, geologists). 2.2.5 Tasks and Hazardous Agents For each Job Type, identify the tasks involved and make an inventory of the hazardous agents to which staff may be exposed whilst carrying out those tasks. Take into account all normal operations, planned loss of containment (e.g. during maintenance, shut down or start up operations), abnormal conditions and foreseeable emergencies, e.g. accidental spillage of a hazardous substance. This is best achieved by drawing on workplace experience, including discussing the activities of a particular Job Type with staff from that group and visiting the work area(s) concerned. This is referred to as a 'walk-through' survey. In addition, plotting activities (vertical axis) against associated hazardous agents (horizontal axis) on a matrix has been found to be a useful tool in identifying tasks with potential exposure.

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2.2.6 Generic Approach For Assessment Units carrying out similar operations for which the hazards to health are also similar, a 'Generic Approach' may be chosen as the most efficient and cost effective method. In this approach, OHRAs are carried out at one or more representative operational site(s), selected to encompass all activities. The resultant 'Generic Record' may then be 'read across' to the other sites within the group of similar Assessment Units, known as the Assessment Unit Group. In selecting this option, it is important that the Generic Record is reviewed by each operational site within the Assessment Unit Group for accuracy and amended, as appropriate, to provide a record specific to the site in question. In some cases, it may be helpful to produce a generic inventory of the hazardous agents which may be encountered within the Assessment Unit Group. Each site within the Group is then left to complete the OHRA for each of the hazardous agents identified for themselves. It is essential to ensure that the sites to be included in the Assessment Unit Group are genuinely comparable. For example, two chemical processing units may produce the same output but use different plant and processing methods. Similarly, two drilling rigs may use the same drilling fluids, but one may have more efficient ventilation in the mud room. In these cases, the OHRA will be different. N.B.

This approach does not relieve site management of their responsibility for the OHRA programme. The Generic Record should be regarded as a template against which OHRAs on their site are compared.

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3.

IMPLEMENTATION

3.1

Gather Information (Step 3) The risk to the individual from a hazardous agent is assessed on the basis of the likelihood of exposure and the severity of the outcome from the exposure. For a particular task the following information is required to assist in the determination of risk: •

Agents and their harmful effects.



Nature and degree of exposure.



Screening and performance criteria against which to assess the adequacy of controls, i.e. acceptance criteria.

A walk-through survey of the Assessment Unit is useful in developing a picture of the number and type of the agents hazardous to health present in the Assessment Unit, together with the groups of workers with similar exposures and risks. It also assists in identifying priorities for implementing detailed HRAs, and may indicate that conclusions drawn for one part of the Assessment Unit are also applicable, perhaps with minor amendment, to other parts, thereby saving time and effort. 3.1.1 Agents and Their Harmful Effects Identify and make an inventory of all agents hazardous to health in the Assessment Unit. For each agent identified, record: •

Its harmful effect(s).



How it acts on the person, which may be via skin or eye contact, inhalation, ingestion, hearing, whole or specific parts of the body.



Whether it causes an acute (short term) and/or chronic (long term) effect.

Then assign a Hazard Rating Appendix 2 gives examples of typical hazardous agents which may be found in Group Company operations, their origin and harmful effect. Appendix 3 lists questions and suggested records which will assist in checking that all potential sources of hazardous agents have been considered. Examples of information sources on health hazards are: − Manufacturer's and supplier's data sheets (MSDS), labels or manuals on products and equipment. − Group Company and service company material (Documentation). − Group Company and service company occupational health advisers.

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− Organisations with knowledge and experience of the activity or operation. e.g. Trade Associations, international health and safety advisory bodies. − Journals and reference literature. 3.1.2 Nature and Degree of Exposure Information is required for each agent identified under 3.1.1 on: •

Who is exposed.



The exposure level.



Related circumstances (work practices, existing controls).

Compare this information against the relevant Screening and Performance Criteria identified for the tasks carried out and apply an Exposure Rating. a)

Who is Exposed Persons potentially exposed to the hazardous agents listed should be identified. This is most effectively achieved by dividing staff into Job Types and identifying tasks involving potential exposure (See 2.2.4 Job Types and 2.2.5 Tasks and Hazardous Agents). In addition to employees, also consider visitors, contractors, or persons present in the vicinity of an activity which involves exposure to agents hazardous to health. In addition, identify any persons who are at increased risk, e.g.: − Pregnant women and nursing mothers. − Untrained or inexperienced staff (e.g. new recruits, temporary workers). − People working in confined or poorly ventilated spaces. − Workers with pre-existing ill-health (e.g. bronchitis, sensitised to the agent concerned, asthmatics, partial hearing loss). − Smokers (Tobacco smoke can modify the harmful effects associated with exposure to certain hazardous agents in the work place, in some cases increasing the risk to health. It is important that this potential for an increased effect is taken into account during the Health Risk Assessment).

b)

Exposure Level The personal exposure level to a particular agent is established by estimating: •

The magnitude of exposure (e.g. breathing zone concentration of the agent, opportunity for skin contact, noise level, strain on musculo-skeletal system) by examining each task involving the agent and evaluating the measures used to control exposure to it.

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Identify the exposure route, i.e. whether via inhalation, skin or eye contact, ingestion, hearing or affecting the musculo-skeletal system.



The frequency of exposure (times per day, week, month, year).



The duration of exposure (minutes or hours per day).



The likelihood of an increased level of exposure during normal operations or resulting from abnormal conditions or foreseeable emergencies.

In the first instance this may be estimated from relevant data and experience and, subsequently, if actual data is required to support the OHRA, by direct measurement. The following guidelines apply: Estimation of exposure level from relevant data, experience and/or modelling. In many cases, a decision on whether exposure is acceptable or unacceptable to a particular agent can be made without taking exposure measurements. This judgement should be made by competent persons who have knowledge of the hazardous agents, their potential to cause harm, and can evaluate the effectiveness of existing measures for controlling exposure. 'Related circumstances (work practices, existing controls)', and examples of when exposure may be deemed 'acceptable' or 'unacceptable' without carrying out quantitative measurement are given in Appendix 4. An example of using artificial intelligence for estimating occupational exposure is a programme named “Estimation and Assessment of Substance Exposure” (EASE) by UK’s Health and Safety Executive. This programme could be used for broad prediction of exposure from occupational environments. In addition to normal operations, also consider the potential increase in exposure to an agent, should control measures fail, e.g. a cracked pipeline allowing product leakage into the work area. What is the potential increase in risk to health, and how effective are the emergency (recovery) measures for minimising exposure to the increased risk? Estimation of exposure level by direct measurement. A quantitative evaluation of exposures by direct measurement of the hazardous agent should be considered to support the OHRA decisionmaking process when: •

There is doubt about compliance with a recognised exposure limit.



Particularly serious effects could result from excessive exposure.



Justification is required for the implementation of control measures to meet acceptance criteria.

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The choice of control measures is dependent on concentration of exposure.



The efficiency of control measures needs to be evaluated.



To alleviate employee concerns.



Legal requirements.

Such measurements should be carried out according to validated methodology and quality control procedures. In general, types of exposure measurement surveys may be divided into the following categories:

c)



Baseline: in order to provide data to support the OHRA decisionmaking process.



Worst Case: where it is possible to identify events of potentially high exposure, e.g. a high emission due to certain working activities, it is possible to select sampling periods containing these events. This may be carried out as part of a Baseline Survey.



Detailed: carried out if the degree and pattern of exposure cannot be reliably determined by the Baseline Survey.



Periodic (usually referred to as Routine Exposure Monitoring) in which exposure measurements are carried out on a regular basis according to a specified protocol decided by the OHRA. This is carried out as a means of checking that control measures remain effective. Information is obtained on trends or changes in patterns of exposure so that action can be taken before excessive exposures occur.

Related Circumstances (Work Practices, Existing Controls) The level of exposure is influenced by the effectiveness of existing control measures and their usage by staff. Controls include: •

Engineering (plant and equipment) e.g. containment, exhaust ventilation, mechanical aids



Procedural e.g. supervision, work methods, housekeeping, personal hygiene, information, instruction and training



Personal Protective Equipment (PPE) In all cases, the use of PPE should be considered only when control measures within the above categories are not practicable, or as a secondary line of defence



Emergency (recovery) measures e.g. medical emergency response, eyewash and shower stations, additional personal protective equipment

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The following will assist in the review of existing control measures and judging their adequacy: •

Draw up checklists identifying recommended measures for control of exposure to particular agents, according to accepted standards against which to evaluate the activity.



Look at what actually happens in the workplace during the task as compared to what is specified by written procedures. Question any differences that occur.



Note aspects of the task which may increase exposure potential, e.g. overtime working or shift patterns increasing exposure time, spillage and leaks, manual decanting of materials, heated products, dusty materials, high ambient temperature in work area, lack of air movement in work area, spraying of liquids, manual movement of materials/equipment, repetitive tasks.



Speak to personnel to seek their knowledge of the task, associated hazards and measure for controlling exposure.



Review non-routine and intermittent activities, e.g. maintenance operations, loading and unloading, changes in production cycles.



Take account of unplanned but foreseeable events, such as interruptions in work activity, potential for accidental exposure.



Are the medical emergency response arrangements adequate, e.g. First aid measures, transfer of victims to specialist facilities?



Consider workers not directly involved in a particular task but present in the vicinity and potentially exposed to the hazard, e.g. workers adjacent to someone using noisy equipment or arc welding, vents, drains, waste disposal.



Check the engineering controls provided. Do they meet recommended criteria to protect against the hazard in question? Have they been adequately maintained? Are they used? If not used, why not? What training has been given?



Check the procedural controls in place, e.g. supervision, written procedures (such as standing instructions and emergency arrangements for controlling normal and abnormal situations), quality of information/instruction/training, housekeeping, quality of records.



Check the personal protective equipment provided. Is it required? Does it provide adequate protection? Is it used? Is it user friendly? Does it create a hazard in itself, e.g. poor visibility, thermal stress, reduced hand dexterity? Is it maintained? Are records kept of issue and maintenance? What training has been given?



Check the amenities for washing, toilet facilities and storage of clothing. Are they adequate for the number of employees and nature of work?

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3.2

Screening and Performance Criteria Screening and Performance Criteria against which actual exposures and control measures are evaluated should be identified prior to the OHRA. These acceptance criteria should not be seen as being absolute; they should be reviewed and revised to take account of advances in technology and knowledge to encourage continual improvement. They should include: •

Exposure limits for health hazards.



Specifications for engineering controls.



Specifications for procedural controls.



Specifications for personal protective equipment.



Specifications for emergency (recovery) measures.

3.2.1 Exposure Limits Exposure limits to be used are those published by the ACGIH [Ref. 3], categorised as follows: − Chemical Agents − Physical Agents − Biological Agents − Ergonomics a) Chemical Agents Personal Exposure: Air Measurement Occupational Exposure Limits (OELs) have been assigned for various chemical agents. In general, the limits comprise:•

A Time-Weighted Average (TWA) exposure: the TWA concentration for a normal 8-hour workday and a 40-hour workweek, to which nearly all workers may be repeatedly exposed, day after day, without adverse effect,



A Short Term Exposure Limit (STEL): this is applied to chemicals with acute effects and, in general, is a maximum allowable exposure over a 15 minute period.



A Ceiling Limit: the concentration that should not be exceeded during any part of the working exposure.

Further information on OELs is provided in the ADNOC Code of Practice ‘Framework of Occupational Health Management’ [Ref. 2].

[2] ADNOC Manual of Codes of Practice: ‘Code of Practice on Framework of Occupational Health Risk Management (OHRM)’, ADNOC-COPV3-01.

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Personal Exposure: Biological Monitoring and Biological Effect Monitoring Biological monitoring and biological effect monitoring are methods for assessing the absorption of certain substances to which individuals may be exposed in the workplace. These techniques are particularly useful because they reflect absorption by all routes, i.e. by skin absorption and ingestion as well as by the more usual airborne route. They have the important advantage of giving additional information about individual risk. Biological monitoring involves the measurement of a hazardous substance or its metabolites in body fluids, usually blood, urine or exhaled breath. A metabolite of a substance is either a breakdown product or modified (more soluble) form suitable for excretion by the kidney in the urine, or by the liver into the intestine. Biological effect monitoring is the measurement of a reversible biochemical change caused by the absorption of the substance; the degree of change being below that associated with toxic injury and not associated with a known, irreversible pathological effect. Biological Limit Values (BLVs) have been set for a number of chemical agents. A BLV is the maximum allowable concentration in body fluids of workers of a chemical, or its metabolite, which does not cause adverse effects. b) Physical Agents Information on physical agents and Occupational Exposure Limits can be found in the following references: Ionising radiation

ADNOC CoPs ‘Guideline on OHRM - Ionising Radiation’ [Ref. 4] and ‘Code of Practice on OHRM - Physical Agents’ [Ref. 5]

Heat stress

ADNOC CoP ‘Code of Practice on OHRM Physical Agents’ [Ref. 5]

Lasers

ACGIH TLV [Ref. 3]

Light (visible) Illumination levels (lux)

ADNOC CoP ‘Code of Practice on OHRM Physical Agents’ [Ref. 5]

Near infra-red radiation

ACGIH TLV, ADNOC CoP ‘OHRM - Code of Practice on Physical Agents’ [Ref. 5]

Noise

ADNOC CoP ‘Guideline on OHRM - Noise Control and Hearing Conservation’ [Ref. 6]

Radio frequency/ microwave radiation

ACGIH TLV [Ref. 3]

Static magnetic fields

ACGIH TLV [Ref. 3]

Sub-radiofrequency (30 kHz and below) and magnetic fields

ACGIH TLV [Ref. 3]

[3] ACGIH Threshold Limit Values (TLVs) and Biological Exposure Indices (revised annually). [4] ADNOC Manual of Codes of Practice: ‘Guideline on OHRM - Ionising Radiation’, ADNOC-COPV3-09. [5] ADNOC Manual of Codes of Practice: ‘Code of Practice on OHRM -Physical Agents’, ADNOC-COPV3-05. [6] ADNOC Manual of Codes of Practice: ‘Guideline on OHRM - Noise Control and Hearing Conservation’, ADNOC-COPV3-10.

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Sub-radio frequency (30 kHz and below) and static electric fields

ACGIH TLV [Ref. 3]

Ultra-violet radiation

ACGIH TLV, ADNOC CoP ‘Code of Practice on OHRM - Physical Agents’ [Ref. 5]]

Vibration - hand/arm (segmental)

ACGIH TLV, ADNOC CoP ‘Code of Practice on OHRM - Physical Agents’ [Ref. 5]

c) Biological Agents The presence of pathogenic biological agents should be controlled to a level as low as is reasonably practicable to prevent infection/disease occurring. A regime of routine treatment of potential breeding grounds for these organisms to prevent their reproduction may be required in risk areas. d) Ergonomics Ergonomic principles in the design of tasks and workplaces should be applied to all work activities to reduce the likelihood of staff suffering from discomfort, musculo-skeletal problems or psychological stress. See ADNOC CoP ‘OHRM – Code of Practice on Ergonomics Factors’ [Ref. 7]. 3.2.2 Specifications for Engineering Controls References to design specifications for engineering controls are extensive sources include, industry, European and international bodies and professional institutions (see References, for examples of relevant bodies). 3.2.3 Specifications for Procedural Controls Standards for procedural controls should be identified to ensure the continuing integrity and effectiveness of the OHRA programme and designated exposure control measures. As far as possible, these should be incorporated into existing HSE management systems and operating procedures and should be compatible with accepted industry standards. 3.2.4 Specifications for Personal Protective Equipment (PPE) All local legislative requirements must be met. In addition, Group Companies must adhere to the requirements of the ADNOC CoP ‘Code of Practice on Personal Protective Equipment’ [Ref. 8]. 3.2.5 Specifications for Emergency (Recovery) Measures Engineering, procedural and personal protective equipment control measures involved in mitigating the effects of control failure should also meet appropriate specifications and comply with relevant ADNOC Codes of Practice.

[3] ACGIH Threshold Limit Values (TLVs) and Biological Exposure Indices (revised annually). [5] ADNOC Manual of Codes of Practice: ‘Code of Practice on OHRM - Physical Agents’, ADNOC-COPV3-05. [7] ADNOC Manual of Codes of Practice: ‘Code of Practice on OHRM - Ergonomic Factors’, ADNOC-COPV3-06. [8] ADNOC Manual of Codes of Practice: ‘Code of Practice on Personal Protective Equipment’, ADNOC-COPV4-04.

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3.3

Evaluate the Risk to Health (Step 4) Using all the information obtained in Step 3, the Assessment Team should evaluate the risk to health by making a judgement on:•

the severity of the possible ill-health effect from over-exposure to the agent to give a Hazard Rating;



the chance of over-exposure to give an Exposure Rating;



the risk to health by combining the above Ratings in a Potential Matrix.

Based on above, conclude the evaluation by identifying whether or not action is required. It may be necessary to seek additional information/advice before a judgement can be made. 3.3.1 Hazard Rating The severity of the potential ill-health effect is based on the hazardous properties of the agent. As a guide, and with reference to ADNOC Group Guideline ‘HSE Risk Management’ [Ref. 9], apply a Hazard Rating to each identified agent as follows: HAZARD RATING

1

DEFINITION (in terms of potential to cause 'Harm to People) Slight Injury/Illness: Not affecting work performance or causing disability. - Agents which are not hazardous to health.

2

Minor injury/illness: Affecting work performance, such as restriction of activities (Restricted Work Case), or a need to take a few days to fully recover (Lost Workday Case). - Agents which have limited health effects which are reversible, e.g. irritants, many food poisoning bacteria.

3

Major injury/illness: Resulting in a Permanent Partial Disability or affecting work performance in the longer term, such as a prolonged absence from work. - Agents which are capable of irreversible damage without serious disability, e.g. noise, poorly designed manual handling tasks.

4

Permanent total disability or fatality (small exposed population): - Agents which are capable of irreversible damage with serious disability or death, e.g. corrosives, known human carcinogens.

5

Multiple Fatalities (large exposed population) - Agents with potential to cause multiple fatalities, e.g. chemicals with acute toxic effects (e.g. hydrogen sulphide, carbon monoxide), known human carcinogens

[9] ADNOC Group Guideline : ‘HSE Risk Management’, March 2000.

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3.3.2 Exposure Rating Estimate the chance of over-exposure from the evaluation of the nature and degree of exposure and apply an Exposure Rating as follows: EXPOSURE RATING

DEFINITION

Very Low (A)

Exposures are negligible.

Low (B)

Exposures are controlled and likely to remain so in accordance with screening and performance criteria.

Medium (C)

Exposures are currently controlled to meet screening and performance criteria, but control cannot be assured.

High (D)

Exposures are not adequately controlled to meet screening and performance criteria and continuously/ regularly exceed Occupational Exposure Limits.

Very High (E)

Exposures are excessive and will almost certainly result in health damage to persons exposed.

3.3.3 Risk To Health With reference to ADNOC Group Guideline ‘HSE Risk Management’ [Ref. 9], as a helpful tool in the evaluation, the above Ratings can be combined in a matrix to judge the risk to health. This will also be influenced by the number of people exposed; the greater the population exposed the greater the likelihood that the ill-health effect will occur and hence the risk. Potential consequence of exposure to the hazardous agent as determined by the HAZARD RATING RATING

HARM TO PEOPLE

Measure of exposure as determined by the EXPOSURE RATING VERY LOW (A)

LOW

MED

HIGH

(B)

(C)

(D)

VERY HIGH (E)

5

Multiple fatalities

MR

HR

HR

HR

HR

4

Permanent total disability/fatality

MR

MR

HR

HR

HR

3

Major injury/illness

MR

MR

MR

MR

HR

2

Minor injury/illness

LR

MR

MR

MR

MR

1

Slight injury/illness

LR

LR

LR

MR

MR

[9] ADNOC Group Guideline : ‘HSE Risk Management’, March 2000.

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The risk matrix is divided into three risk categories as defined below: High Risk (HR) Unacceptable This level of risk exposes the Company to intolerable losses to People. The hazard should be eliminated or its work reduced to tolerable levels immediately. Medium Risk (MR) Acceptable but must be managed at ALARP The hazards must be managed to reduce the frequency and/or the severity of the hazardous events to ALARP. Low Risk (LR)

Acceptable without required further action.

Correction(s) may be applied as resources allow. 3.3.4 Conclude Evaluation Identify whether or not action is necessary to reduce risk to health. The Potential Matrix will indicate the level of risk and can therefore assist in determining priorities for appropriate control measures (see Step 5 - Decide on the Remedial Action). 3.3.5 Need for Further Information/Advice The Assessment Team may not be able to reach a judgement owing to insufficient information being available, or because the appropriate competency is not available amongst team members. In either of these cases, action should be taken to seek the additional information and/or advice before a decision on items 3.3.1 – 3.3.4 above, or Step 5 - Remedial Action, is made. 3.4

Decide on the Remedial Action (Step 5) Where action to reduce risk to health is identified, a decision on what control measures are to be selected is necessary. Priorities, responsible persons and target dates should be identified.

3.4.1 Hierarchy Of Controls Where the need for additional control measures is identified, a systematic review of all control options, known as the 'hierarchy of controls', should be made with a view to controlling exposure to a level as low as reasonably practicable. The hierarchy of controls is as follows: •

Elimination of the hazard.



Substitution (alternatives) e.g. replace with a less hazardous substance, use a wet method instead of dry, introduce a non-dusting powder for one that is friable.



Engineering (plant and equipment) ventilation, mechanical aids

e.g.

containment,

exhaust

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Procedural e.g. supervision, work methods, housekeeping, personal hygiene, information, instruction and training



Personal Protective Equipment (PPE). In all cases the use of PPE should be considered only when control measures within the above categories are not practicable.

Where the risk is unacceptable, control options that can be implemented immediately should be addressed first, e.g. eliminate by stopping the activity, or introduce appropriate personal protective equipment, whilst substitutes (alternatives) or engineering solutions are investigated. If improvements in engineering controls are considered appropriate, but it is not practicable to implement these measures immediately, a programme of work should be drawn up which takes into account plans for future new plant or equipment. Such a programme will demonstrate a commitment to continual improvement. 3.4.2 Additional Measures In addition to determining control options, the need for measures to monitor their continuing adequacy may also be appropriate and may include: •

Routine Exposure Monitoring - See Section 3.1.2 Exposure Level (b) for a general description.



Health Surveillance - where risk to health cannot be excluded, employees' health should be monitored. Health surveillance is designed to: − Assess the health of the individual. − Assist in checking the effectiveness of control measures. − Collect data for the detection and evaluation of agents hazards to health. Health surveillance may include keeping records on individual exposures, the use of questionnaires, disease surveillance and medical surveillance. The content and frequency of health surveillance should be determined by the task specific hazards as evaluated by the Health Risk Assessment. Advice on health surveillance should be obtained from the Group Company medical advisor.



Maintenance of Controls - control measures will only remain effective if they are properly and regularly maintained, i.e.: − Engineering controls: implement a regime of preventive maintenance including routine inspections, examinations and tests to ensure plant and equipment continues to operate at design specification.

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− Procedural controls: implement procedures that will assist in ensuring adequate maintenance of controls, e.g. record systems, personnel information, instruction and training, supervision, safe systems of work, emergency arrangements, etc. − Personal protective equipment (PPE): as with engineering controls, reusable PPE also requires routine inspection and maintenance to ensure it continues to provide satisfactory protection. − Emergency (recovery) measures: all plant and equipment required for use in emergencies must be routinely inspected and maintained in good working order. In addition, regular emergency exercises should be carried out to test effectiveness of emergency arrangements and as a staff training aid. •

Information, Instruction and Training - education of the workforce through the provision of information, instruction and training on workplace health hazards and the measures provided for the control of those hazards is imperative for the success of the OHRA programme. Education should be devised to meet the needs of each employee group (Job Type) and designed to ensure clarity of message. For example, on-the-job training, posters, summary cards and reminders on work sheets have greater impact than detailed manuals located in supervisors' offices. As an aid to gaining the commitment within the organisation to the OHRA programme, it should be emphasised that the driving force behind the exercise is to ensure that people are not exposed to health risks at work.

3.5

Record the Occupational Health Risk Assessment (Step 6)

3.5.1 Make a Record A written record of all OHRAs should be kept. The record should: •

Be readily retrievable when required, e.g. for internal/external audits, for local or national authorities, for periodic review.



Meet legal requirements.



Be kept for a minimum of 30 years to aid epidemiological studies (refer to the Framework COP on Occupational Health Management and Health Risk Assessment and also item 3.5.3 below). In this connection, arrangements should be made for archiving records which are no longer current.



Contain sufficient information to ensure future clarity on how the conclusions were reached.

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3.5.2 Suggested Record Format The following comprises the recommended content for OHRA record. suggested format is given in Appendix 5 as follows:

A

Appendix 5a: Job Type details: •

The Assessment Unit and Assessment Team Members.



Staff numbers, hours worked and work pattern.



Summary description of the job and tasks.



Hazardous agent inventory, their harmful effects, relevant occupational exposure limit(s) and Hazard Rating.

Appendix 5b: Task details: •

List of tasks with exposure risk identified and the work area(s).



For each task identify the agent, exposure route and form, frequency, duration and magnitude.



Exposure Rating;



Summary of the nature of exposure, existing control, including emergency (recovery), measures and comment on their effectiveness.

Appendix 5c: Recommendations and Review: •

Recommendations for action including responsible person(s) and target date(s).



Signatures of staff responsible for reviewing the OHRA and supporting the recommendations including, e.g.: − Assessment Team Leader − Management involved in the OHRA review − Occupational Health Adviser(s)

Where a 'Generic Approach' to carrying out this process has been selected, one common report may suffice. However, management at the relevant sites should review such reports to ensure that they are accurate with respect to their own activity. Where differences occur which could have significant impact for health, they should amend the 'Generic Report' to reflect their own situation. Where the Assessor(s) finds no significant differences between the generic model and the actual activity, this conclusion should be reported and the generic report appended. 3.5.3 Develop a Work History of Employee Exposure For maximum benefit from the process of Occupational Health Risk Assessment, the record system should allow for linking of individual OHRAs to the relevant employee's Medical Record. In this way, an exposure profile to agents hazardous to health can be developed for employees covering their

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working career with the company. This data will assist epidemiological surveys of workers in the ADNOC Group Companies. Confidentiality of personal details can be assured by the use of Job Type Codes. As a member of staff moves from one Job Type to another, his/her Job Type Code should be changed accordingly. At its simplest, a work history would consist of name, employee identification number and a list of Job Type Codes and dates. 3.5.4 Inform Staff Group Companies should ensure that personnel are involved in the OHRA programme as far as possible and, in any event, informed of the results of all OHRAs carried out for their particular Job Type in an appropriate manner. 3.6

Review the Occupational Health Risk Assessment (Step 7) In order to ensure the continuing validity of OHRAs and the ongoing control of personnel exposure to hazardous agents, the Occupational Health Risk Assessment process should be subject to planned review, including: •

Action items



Review of Occupational Health Risk Assessments



Audit

3.6.1 Action Items

Initial Action of OHRA Recommendations Action items arising from the OHRAs should be listed for ease of reference as an Appendix to the Occupational Health Risk Assessment record and entered into a follow-up system. The action point(s), together with the responsible person and target date for completion, should be identified.

Follow-Up of Actions A plan for executing the action items should be drawn up, and progress tracked.

Review Effectiveness of Actions Following the implementation of actions arising from the OHRAs, a further review of the task should be carried out to assess effectiveness/adequacy of the recommendations. 3.6.2 Review of Occupational Health Risk Assessments In addition to reviewing the effectiveness of actions arising from initial OHRAs, the further requirement to review an OHRA will be triggered by: •

Significant changes in the work processes and patterns, or in the appreciation of hazards and risk.

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An agreed schedule for the review of all Assessments. A period of 5 years maximum lapsed time between Assessments is recommended with 1 year maximum for those involving agents which may cause irreversible adverse health effects.

Group Companies should ensure systems are in place for the automatic implementation of Occupational Health Risk Assessment. 3.6.3 Audit An evaluation of the OHRA programme should be included in the audit programme of any facility. This programme should be audited with specific attention being given to: − organisation of the programme − resources available to conduct the programme − quantity and quality of OHRA records − areas of non-compliance with occupational exposure limits − results from health surveillance programmes − remedial actions taken following recommendations arising from the Assessments − maintenance of controls − maintenance of employee work history

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REFERENCES 1.

ADNOC Manual of Codes of Practice: ‘Guideline on HSE Definitions & Abbreviations’, ADNOC-COPV1-05.

2.

ADNOC Manual of Codes of Practice: ‘Code of Practice on Framework of Occupational Health Risk Management (OHRM)’, ADNOC-COPV3-01.

3.

ACGIH Threshold Limit Values (TLVs) and Biological Exposure Indices (revised annually); consult latest publication.

4.

ADNOC Manual of Codes of Practice: ‘Guideline on OHRM - Ionising Radiation’, ADNOC-COPV3-09.

5.

ADNOC Manual of Codes of Practice: ‘Code of Practice on OHRM - Physical Agents’, ADNOC-COPV3-05.

6.

ADNOC Manual of Codes of Practice: ‘Guideline on OHRM - Noise Control and Hearing Conservation’, ADNOC-COPV3-10.

7.

ADNOC Manual of Codes of Practice: ‘Code of Practice on OHRM Ergonomic Factors’, ADNOC-COP3-06.

8.

ADNOC Manual of Codes of Practice: ‘Code of Practice on Personal Protective Equipment’, ADNOC-COPV4-04.

9.

ADNOC Group Guideline ‘HSE Risk Management’, March 2000.

ADDITIONAL DATA SOURCES 1.

CEFIC: European Council of Chemical Manufacturers Federations, Av. E. van Nieuwenhuyse 4, Box 1, B-1160 Brussels, Belgium.

2.

CONCAWE: The Oil Companies' European Organisation for Environmental and Health Protection Madouplein 1, B-1030, Brussels, Belgium.

3.

ECETOC: European Centre for Ecotoxicology and Toxicology of Chemicals, Av. E. van Nieuwenhuyse 4, Box 1, B-1160 Brussels, Belgium.

4.

E&P FORUM: The Oil Industry International Exploration & Production Forum, 25/28 Old Burlington Street, London, England, W1X 1LB.

5.

HSE: Health and Safety Executive, UK, HSE Books, PO Box 1999, Sudbury, Suffolk, England, CO10 6FS.

6.

NIOSH: National Institute of Occupational Safety and Health, USA, GPO - US Government Printing Office, Superintendent of documents, Washington, DC 20402.

7.

OSHA: Occupational Safety and Health Administration, USA, 200 Constitution Ave., N.W. Washington, D.C. 20210.

8.

ACGIH: American Conference of Governmental Industrial Hygienists, USA, Kemper Woods Centre, 1330 Kemper Meadow Drive, Cincinnati, OH 45240.

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9.

AIHA: American Industrial Hygiene Association, USA, Support Services, 2700 Prosperity Avenue, Suite 250, Fairfax, VA.

10.

BOHS: British Occupational Hygiene Society, U.K. Suite 2, Georgian House, Great Northern Road, Derby, England, DE1 1LT.

11.

ICOH: International Commission on Occupational Health Dept. of Community, Occupational and Family Medicine, National University Hospital, Lower Kent Ridge Road, Singapore 0511.

12.

IOHA: International Occupational Hygiene Association, secretariat located at IOH, see 13 below.

13.

IOH: Institute of Occupational Hygienists, UK, Suite 2, Georgian House, Great Northern Road, Derby, England, DE1 1LT.

14.

Fundamentals of Industrial Hygiene, National Safety Council, USA. Third edition 1988 - ISBN 0 87912-082-7.

15.

Handbook of Occupational Hygiene, Croner Publications Ltd, UK., Loose-leaf book updated quarterly - ISBN 1 85524 031 9.

16.

Monitoring for Health Hazards at Work, Frank S. Gill & Indira Ashton. 2nd edition 1992. Publisher: Blackwell Scientific Publications, UK - ISBN 0 632 02984 6.

17.

Patty's Industrial Hygiene and Toxicology, Publisher John Wiley & Sons Inc.: Volume 1 General Principles, parts A and B. 4th edition 1991. ISBN 0471-50197-2 and ISBN 0-471-50196-4

18.

Patty's Industrial Hygiene and Toxicology, Publisher John Wiley & Sons Inc.: Volume 2 Toxicology: parts A (1993), B (1993) and C (1994). 4th edition. ISBN 0-471-54724-7. ISBN 0-471-54725-5 and ISBN 0-471-54726-3.

19.

Patty's Industrial Hygiene and Toxicology, Publisher John Wiley & Sons Inc.: Volume 3 Theory and Rationale of Industrial Hygiene Practice. 3rd edition 1993. ISBN 0-471-53066-2.

20.

Dangerous Properties of Industrial Materials. Sax NI. Publisher Van Nostrand, Reinhold, NY. 8th edition 1992.

21.

NIOSH Pocket Guide to Chemical Hazards. Current issue June 1990. Also available on CD ROM, up-dated quarterly.

22.

Refer to documents listed under Section 1, Internal Publications, and Section 2.1, General External Publications, in the first instance.

23.

Control of Communicable Diseases in Man, Abram S. Benenson (editor) American Public Health Association, 15th Edition 1990, ISBN 0-87553-170-9. (Includes references to non-communicable diseases).

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24.

The Microbiological Hazards of Occupations. C.H. Collins and J.M. Grange. Occupational Hygiene Monograph No. 17, 1990. ISBN: 0-905927-23-0. Publisher: Science Reviews Ltd in association with H&H Scientific Consultants Ltd.

25.

Guidance on Legionnaires' Disease and its prevention. CONCAWE Special Interest Report 87/51.

26.

Ergonomics for Beginners - a quick reference guide, J. Dul and B. Weerdmeester. Ninth entirely revised edition 1993 (Publisher Taylor & Francis).

27.

Manual Handling - Guidance on the Manual Handling Operations Regulations 1992 (provides guidance on health risk assessment of manual handling tasks). U.K. Health and Safety Executive 1992, ISBN 0 11 8863355.

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APPENDIX 1 Competence

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APPENDIX 1 - COMPETENCE Individuals who are nominated to be involved in carrying out Occupational Health Risk Assessments must have a level of knowledge, skill and experience appropriate to: 1. Understanding the process of Occupational Health Risk Assessment 2. Gathering information systematically and being able to make judgements on hazards, exposures and risks to health Obtaining the information required calls for the ability to: − Observe, in order to appreciate readily what is going on and the significance of what they see, particularly if it diverges from written procedures. − Predict possible departures from observed practice and realise their significance. − Ask relevant questions of supervisors, managers, staff, advisers etc. and realise the implications of the responses. − Undertake simple diagnostic tests, e.g. use of a smoke tube for testing air movement, simple sound level meter, colorimetric tubes for an indication of air concentration of a particular substance. − Identify and review relevant technical literature. − Draw all the information together in a systematic way to estimate likelihood and consequences. − Form valid and justifiable conclusions about exposures and risk. − Pursue fundamental questions about whether there is a probability for any exposures to occur. − Have an appreciation of the range and limitation of possible control measures and the measures to sustain control, and the relative reliability of each. − Look critically at existing arrangements. − Identify in broad terms the types of changes needed. (Certain aspects may then need to be referred to relevant specialists.) 3. Understanding their own limitations The Assessor(s) must know or be made aware of the areas of expertise that might need to be involved in an assessment and at what stage to call upon the knowledge and skills of others. For example, carrying out exposure monitoring for the health hazard in question should only be done by people who have been trained in the techniques and procedures, whilst the planning of a monitoring strategy requires further, higher level, professional training.

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Examples of professions which may assist are: occupational hygienists / health physicians / nurses, chemists, ergonomists, toxicologists, safety practitioners, ventilation engineers, chemical engineers, etc. 4. Making a record The Assessor(s) must be able to communicate the Assessment findings as a written record from which recommended actions can be easily extracted and the information used in evaluating the risk to health easily retrieved. 5. Engaging expertise from outside the Company Where consultants are used the main obligations are to: •

Review the consultant for competency to carry out the work.



Make the consultants know precisely what they are being employed to do. Specify exactly what is required.



Liaise with the consultants rather then leave them to do the task in isolation.

Also consider calling on the expertise from, for example: •

Trade associations.



International bodies (e.g. the U.K. Health and Safety Executive).



Learned societies and professional bodies (e.g. British Occupational Hygiene Society, American Industrial Hygiene Association, International Occupational Hygiene Association, Faculty of Occupational Medicine of the Royal College of Physicians, London).

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APPENDIX 2 Examples of Hazardous Agents and Their Origin

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EXAMPLES OF HAZARDOUS AGENTS AND THEIR ORIGIN HAZARDOUS AGENT

EXAMPLES OF SOURCE

ROUTE

POTENTIAL HEALTH EFFECT

Chemical Agents Asbestos

Materials containing asbestos e.g. Insulation, gaskets, brake linings.

Inhalation

Chronic: Asbestosis, mesothelioma, lung cancer

Benzene

Benzene processes. Platformers. Mogas handling/distribution. Condensate handling/distribution.

Inhalation

Acute: Central Nervous System Effects Chronic: Leukaemia

Skin

Acute: Defatting of the skin. Chronic: Dermatitis

Carbon monoxide (CO)

Waste streams; exhaust gas from petrol engines or generators.

Inhalation

Acute: Chemical asphyxiation

Dusts (corrosive)

Lithium/potassium/sodiu m hydroxide in crystalline form used in soap manufacture for greases

Inhalation

Acute: Severe irritation of respiratory tract. May lead to pulmonary oedema (fluid on the lungs)

Skin

Acute: Corrosive

Iron oxide from welding mild steel. Paper dust. Catalysts containing alumina.

Inhalation

Acute: Irritation to the respiratory tract.

Hydrogen sulphide (H2S)

Waste gas streams; crude oil; condensates

Inhalation

Acute: Chemical asphyxiation

Isocyanates

Manufacture of polyurea grease; paints

Inhalation

Acute: Irritation to the respiratory tract. Respiratory sensitiser. May promote asthmatic attacks.

Dusts (nuisance)

Chronic: Loss of lung function

Chronic: Impairment of lung function Skin

Acute: Irritation Chronic: Dermatitis

Metal oxide fumes

Mineral oil

Acute: Metal fume fever.

Welding operations. e.g. Cadmium oxide (silver solder)

Inhalation

Zinc oxide (galvanised steel).

Inhalation

Acute: Metal fume fever

Lub oils used by maintenance staff and vehicle mechanics, luboil blending.

Inhalation

Chronic: Lung Fibrosis

Pulmonary oedema

(oil mist) Skin

Acute: Defatting of the skin Chronic: Dermatitis

Acute Chronic

= Effects after short term, usually high, exposure = Effects after long term, usually low, repeated exposure

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EXAMPLES OF HAZARDOUS AGENTS AND THEIR ORIGIN HAZARDOUS AGENT

EXAMPLES OF SOURCE

ROUTE

POTENTIAL HEALTH EFFECT

Silica dust (crystalline)

Refractory materials containing crystalline Silica.

Inhalation

Chronic: Silicosis

Used Mineral oil (containing polycyclic aromatic hydrocarbons PCAs)

Vehicle mechanics draining engine oil.

Skin

Chronic: Dermatitis, Possible skin carcinomas

Under belly and wings of a 747 jet during refuelling 85-108 dB(A). Diesel engine room 100-110 dB(A). Adjacent to steam leaks - 95 - 100 dB(A)

Hearing

Acute: Temporary threshold shift

Typical process plant 8090 dB(A).

Hearing

Chronic: Some hearing loss at higher noise levels.

Heat

High ambient temperatures / humidity e.g. tank cleaning; fin-fan cowls in air cooling systems; around flares

Whole body

Acute: Heat stress. Heat stroke

Ultra-violet radiation

Arc welding, sunshine

Skin (Caucasian skin types)

Acute: skin burn

Eye

Acute: Kerato-conjunctivitis (arc eye/welder's flash); headache

Chemical Agents cont’d

Physical Agents Noise

Chronic: High hearing loss

Chronic: skin cancer

Biological Agents Mosquitoes carrying the parasite plasmodium

Tropical areas - stagnant water

Skin

Malaria - chills, fever and anaemia. Potentially fatal.

Legionella species of bacteria (in particular Legionella pneumophila)

Cooling water towers

Inhalation of water aerosol/mist

Legionnaires' Disease - influenza-type symptoms which may lead to pneumonia. Pontiac Fever - influenza-type symptoms which do not lead to pneumonia.

Ergonomics Poor task/workplace design

Acute Chronic

Poor access/egress, restricted workspace, lifting/carrying, repetitive movements, lack of movement

Whole or part body

Musculo-skeletal disorders

= Effects after short term, usually high, exposure = Effects after long term, usually low, repeated exposure

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APPENDIX 3 Identifying Hazardous Agents

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APPENDIX: 3 - IDENTIFYING HAZARDOUS AGENTS 1.

LOOK AT THE WORKPLACE - obtain an overview of operations Chemical Agents - for example:− What feed stocks are used? − What products, catalysts, intermediates, by-products and wastes (gaseous, liquid or solid) are produced? − What proprietary chemical products are used? − Where are the emission points to atmosphere for chemical agents, e.g. ventilation exhaust points, production vessels, drainage points, tank vent points, sampling points? − Are ventilation fresh air inlets located close to ventilation exhaust points? − What potentially hazardous building construction materials have been used, e.g. insulation and fire retardant materials such as asbestos and man-made mineral fibres; lead pipes; leaded paint? Physical Agents - for example:− What noisy fixed plant is present, e.g. compressors, boilers, machinery? − What noisy portable equipment is used, e.g. pneumatic tools, grinders? − Are lighting levels adequate for the tasks required? − Are there distracting glare sources or reflections at workstations? − Is any equipment used which emits ionising radiation, e.g. level gauges, xray equipment? − Are there any working areas where extremes of thermal environment (heat or cold) are present or may occur? − Do staff have to carry out heavy manual tasks which may lead to heat stress in a hot environment, e.g. tank cleaning? − Are there any tasks which require staff to be in a cold environment, e.g. working in a freezer room? Biological Agents - for example: − What water systems are present? What is the potential for the growth of disease/illness causing bacteria, e.g. legionnella, pneumophila? − Are there air conditioning systems? What is the potential for growth of disease/illness causing bacteria and other organisms e.g. dust mites? − In catering establishments, what is the potential for the growth of food poisoning bacteria?

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Ergonomics - for example:− Is the design and layout of the workplace such that no excessive stresses are placed on staff musculo-skeletal systems? For example, bending and stretching, lifting and carrying, pushing and pulling, repetitive movements using the same muscle groups? − Do environmental factors of the work place affect worker comfort? For example, noise, vibration, lighting, climate (see also physical agents) 2.

LOOK AT THE TASK - do any tasks create health hazards? For example: − cutting and welding, brazing, soldering: these processes emit gases, fumes, non-ionising radiations (ultra-violet and/or infra-red) and noise, depending on the type of cutting/welding activity; − impact noise emissions from manual handling of containers e.g. empty barrel handling, LPG cylinder movement; − tasks that change the physical form of a chemical product e.g. activities that create a dust from a solid such as grinding, sanding, sawing; liquid to an aerosol such as spray painting, applying liquid chemicals using a spray lance; − are there any specialist tasks, e.g. sub-aqua diving, entry into confined spaces?

3.

LOOK AT RECORDS - to identify plant specifications, past incidents and actions For example: − Plans and drawings for plant specifications; − Incident/injury reports - identify, e.g. back injuries, chemical burns, dermatitis, chemical splashes in eyes, product spillages. − Occupational illnesses. − Plant and equipment fault reports. − Maintenance records for control measures, e.g. personal protective equipment, local exhaust ventilation. − Health surveillance records, e.g. audiometry results, biological monitoring results, dermatitis. − Sickness absence reports, is any absence the result of working conditions/incidents? − Health and safety surveys/inspections. − Minutes of health and safety committee meetings. − Previous occupational hygiene surveys e.g. noise dosimetry, plant noise contour plans, exposure measurements to airborne agents.

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APPENDIX 4 Estimating Exposures Without Quantitative Measurement – Examples of Work Situations

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APPENDIX: 4 - ESTIMATING EXPOSURES WITHOUT QUANTITATIVE MEASUREMENT - EXAMPLES OF WORK SITUATIONS 1. Exposure may be acceptable when:•

quantities or rate of use of a chemical agent or the level of a physical agent are too small to constitute a risk under foreseeable circumstances, even if controls break down, e.g.: − a small office photocopier sited in a separate room generates ozone. General ventilation from the air-conditioning system is relied upon to disperse the gas and is sufficient to disperse the ozone. (Note that while this may be the case for incidental use of this type of photocopier, it may not be so for a photocopying room where personnel are exposed to day long ozone generation from a number of constantly working machines.) − the noise level is so low on a plant that it allows conversation at normal voice level.



operations are strictly in accordance with well documented information provided about the process and operating conditions by the suppliers of the plant/equipment, in which they give a valid assurance that the operation will not give rise to risks to health, e.g.:− the use of a purpose-designed mobile local exhaust ventilation system with built-in filtration to remove welding fume/gases from the operator's breathing zone and prevent re-emission into the workplace. Maintenance systems in place to ensure the unit continues to operate to specification and staff are trained in its correct operation.



previous exposure measurements have been taken of the process, inhouse or elsewhere, including 'worst case' situations, which confirm that exposure is not a risk to health at any time, and conditions now are demonstrably still the same;



the process is conducted exactly to the same standards, or better, as in upto-date guidance on good practice that carries valid assurance of insignificant exposure, e.g.:− the treatment of wet cooling towers to prevent the growth of the bacterium which causes Pontiac Fever and Legionnaires' Disease, in accordance with latest recognised standards. The standards should include a management system to ensure continuing compliance.

2. Exposure may be unacceptable when:•

there is evidence of fine deposits on people or surfaces;



fumes or particles are visible in the air (e.g. in light beams);



there are broken, clearly defective or badly maintained control measures;



there is an absence of, or departure from, recognised good practice (e.g. eating and drinking in the workplace, incorrect or non-use of personal

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protective equipment where procedures require its use, visibly poor hygiene conditions in kitchens or wash rooms); •

complaints are made of discomfort or excessive odour. These are often channelled through employee representatives and should be taken seriously, especially in situations where management have limited direct contact with the workers;



if ill health linked to exposure has been reported or detected during health surveillance. Health surveillance can vary from simple questions from trained supervisors to comprehensive medical supervision. It is important that equal importance is attached to adverse reports from all types of health surveillance.

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APPENDIX 5 Occupational Health Risk Assessment : Example of Record Format

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APPENDIX: 5 - OCCUPATIONAL HEALTH RISK ASSESSMENT: EXAMPLE OF RECORD FORMAT 5a. Job Type Details OCCUPATIONAL HEALTH RISK ASSESSMENT: EXAMPLE OF RECORD FORMAT (Note: the space allocated in this example may not be sufficient in practice) COMPANY: ASSESSMENT UNIT (A.U.): WORKSITE/LOCATION:

ASSESSMENT IDENTIFICATION NO:

ASSESSMENT TEAM MEMBERS:1.

e.g. Line Manager or his/her Representative of A.U. (Team Leader).

2.

e.g. Supervisor for Job Type.

3.

e.g. Operational Staff

4.

e.g. Occupational Health Advisers.

5.

e.g. Technologists/Engineers.

6.

e.g. Other specialists as required.

JOB TYPE

NUMBER PER SHIFT

BASIC HOURS

WORK PATTERN

DESCRIPTION OF JOB AND TASKS Note: include a broad brush description to give an overview of the job and tasks involved.

JOB TYPE HAZARDOUS AGENT INVENTORY AGENT

HARMFUL EFFECT

OCCUPATIONAL EXPOSURE LIMIT 8 hr TWA/15 min STEL/Other Note: include source

1 2. 3. 4. 5. 6.

HAZARD RATING Note: make a judgement for each agent on the severity of its potential illhealth effect

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5b. Task Details OCCUPATIONAL HEALTH RISK ASSESSMENT: EXAMPLE OF RECORD FORMAT (Note: the space allocated in this example may not be sufficient in practice) TASKS WITH EXPOSURE RISK IDENTIFIED WORK AREA 1. 2. 3. 4. 5.

TASK APPRAISAL – complete for each task with exposure risk identified TASK NO.................................. TASK NAME ........................................................... AGENT

EXPOSURE ROUTE & FORM

FREQUENCY

DURATION

MAGNITUDE

EXPOSURE RATING

RISK TO HEALTH

Note 1: make a judgement on the chance of overexposure to give an Exposure Rating Note 2: make reference to exposure measurements and other relevant documentation

Combine the Hazard Rating and Exposure Rating on a Potential Matrix to give the Risk

Description of task (nature of exposure): Existing control measures Engineering: Procedural: Personal Protective Equipment: Emergency (Recovery) measures: Comment on effectiveness of control measures:Inhalation: Skin contact: Eye contact: Other e.g. Hearing (noise) Musculo-skeletal system (e.g. lifting and handling) ASSESSOR(S):

DATE:

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5c. Task Details: Recommendations and Review OCCUPATIONAL HEALTH RISK ASSESSMENT: EXAMPLE OF RECORD FORMAT (Note: space allocated in this example may not be sufficient in practice) RECOMMENDATIONS TASK NO:......................................

TASK NAME: ........................................................

FURTHER INFORMATION REQUIRED? Give Details:Responsible Person:

Target Date:

ELIMINATION/SUBSTITUTION Responsible Person:

Target Date:

ENGINEERING CONTROLS Responsible Person:

Target Date:

PROCEDURAL CONTROLS Responsible Person:

Target Date:

PERSONAL PROTECTIVE EQUIPMENT Responsible Person:

Target Date:

EMERGENCY (RECOVERY) MEASURES Responsible Person:

Target Date:

ASSESSMENT REVIEWED BY:Signature of e.g.:- Manager involved in HRA review - Assessment Team Leader - Occupational Health Advisers

Date:

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