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SIMPLE RISK
ASSESSMENT AND
CONTROL FOR
CHEMICALS
(SiRAC)Rusnah Bt Nanyan
Chemical Management Division
DOSH, Headquarter, PUTRAJAYA
Session Objectives
State the legal requirements for SiRAC
Explain the differences between CHRA
and SiRAC
State the scope and application of SiRAC
Concept and Steps of SiRAC
Legal Requirements
Sub-Regulations 10(1) of
USECHH Regulations 201X
“An employer shall not carry out any work which may expose or is likely to expose any employee or any other person to any chemical hazardous to health unless he has made a written assessment of the risks created by the chemical to their health.”
Sub-Regulations 11(1) USECHH
Regulations 201X
“The employer MAY conduct a simple assessment for a chemical hazardous to health, if-
a) The chemical is listed in the register stipulated under sub-regulation 6(1); and
b) The chemical is NOT classified as carcinogenicity category 1, mutagenicity category 1 or respiratory sensitizer category 1 as specified in the Occupational Safety and Health (Chemical Classification, Labelling and Safety Data Sheet) Regulations 2013
Sub-Regulations 11(2) USECHH
Regulations 201X
Simple assessment shall contain the
following-
1. the nature of the hazard to health;
2. the exposure potential arising from the use
of chemical hazardous to health; and
3. the measures and procedures required to
control the exposure of an employee to
chemicals hazardous to health.
Sub-Regulations 13(2) USECHH
201X
“The employer may appoint a trained
person to carry out a simple assessment
pursuant to sub-regulation 11(1)”
Types of Assessment
Types of Assessments
Full Assessment
Chemical Health Risk Assessment (CHRA)
Generic Assessment (GCHRA)
Simple Assessment
Simple Risk Assessment and Control (SiRAC)
9
Identify chemical used in particular
work unit and its hazard
taMeet criteria in subreg 11(1)
USECHH 20xx & required
information available?
Conduct Chemical Health Risk Assessment (CHRA)
Develop action plan
Implement action plan
Conduct simple Assessment (SiRAC)
NO
YES
Control approach 1,2 or 3?
YES
NOSeek specialist advice
CHRA and SiRAC
10
Who to Conduct SiRAC?
Trained Person1. Knowledge, training and expertise in understanding hazard
and risk;
2. Ability and authority to collate all necessary and relevant
information;
3. Knowledge, skills and experience to make the right
decisions about risks and the necessary precautions;
4. Knowledge on the SiRAC manual
5. How the work activity uses chemicals hazardous to health;
6. How to interpret SDS; and
7. Basic requirements of OSHA, USECHH, relevant guidelines
SiRAC Methodology
SiRAC Methodology
SiRAC is based on the control banding
approach
Other control banding approaches:
COSHH Essentials (HSE of United Kingdom)
ILO Control Toolkit (ILO)
KOSHA Toolkits (Korea)
Stoffenmanager (Dutch)
Scope & Application
Application of SiRAC By default, USECHH 201X requires full
assessment (CHRA) to be conducted for every place of work where chemicals hazardous to health are used (Reg. 10(1))
SiRAC is an option given to employer who uses chemicals meeting the following criteria:
a) chemical is listed in the mandatory register ;
b) chemical is NOT classified as carcinogenicity category 1, mutagenicity category 1 or respiratory sensitizer category 1 as specified in the CLASS Regulations 2013
Application of SiRACEven though legally SiRAC is an option given to employer who uses chemicals meeting the criteria in sub-regulation 11(1), there is also a limitation in applying SiRAC for the following chemicals:
Process generated dusts and fumesE.g. wood dusts, fume released from molten metal
Organic dustE.g. grain dust, cotton dust, paddy husk dust
Gases
E.g hydrogen sulphide, ammonia Scheduled wastes as listed EQ (Scheduled Wastes)
Regulations 2005
Routes of Entry
Routes of Entry-SiRAC Inhalation Skin/Eyes Contact
Concepts and Steps
CHEMICAL
RISKS?
Probability of harm, injury, illness or disease from
overexposure to chemicals
Risk = Hazard x Exposure
Hazard is determined from chemical classification
Exposure is determined by the quantity of chemical
used and its ability to become airborne
Routes of exposure considered in SiRAC is
inhalation, dermal contact and absorption
Chemicals
causing harm
when airborne
Chemicals capable
of causing harm if in
contact with
skin or eyes
+
Group A
Group B
Group C
Group D
Group S
HAZARD DETERMINATION
HAZARD DETERMINATION
Hazards are grouped into 4 groups (for
chemicals causing harm when airborne):
Group A (least hazardous)
Group B
Group C
Group D (most hazardous)
23
HAZARD
DETERMINATION
Group Schemicals capable of
causing harm if in contact with eyes or skin
H-CODE
H-code or the hazard statement code describes the nature of the hazards of the chemicals as specified in First Schedule of the CLASS Regulations 2013
It is assigned to each of the hazard statement
used for reference purposes
not part of the hazard statement text and shall not be used to replace it.
Examples of H-code:
H301: Toxic if swallowed
H310: Fatal in contact with skin
H317: May cause an allergic skin reaction
Direct Advice
Specific CGS (based on task performed)
for work activities or industries covered are :
Pest Control (Table 3.8)
Soldering (Table 3.9)
Cleaning Services
(Table3.10)
Lithography Printing (Table
3.11)
EXPOSURE DETERMINATION
Magnitude of
Exposure
Scale of Use
&
Ability to Become
Airborne
+ Frequency &
Duration
Per Operation/Batch
Or
Per Day
Total Duration >
15 minutes per day
EXPOSURE DETERMINATION
1. Scale of use
Determine the way chemical is handled and how much employees are exposed
Amount used per batch/operation or per day (continuous operation) can be described as
SMALL , MEDIUM, LARGE
Quantity Solid Liquid
Weight Typically received in Volume Typically received in
Small Grams Packets or bottles Millilitres Bottles
Medium Kilograms Kegs or drums Litres Drums
Large Tonnes Bulk Cubic metres Bulk
EXPOSURE DETERMINATION
2. Ability to become airborne
Physical form of the chemical affects how likely it is
to get into the air.
For solids - determined by its dustiness
Depends on its physical form-the finer the solid the more
likely for it to become airborne
For liquids-determined by its volatility
Volatility depends on its vapour pressure - the higher the
vapour pressure, the more volatile the chemical
Volatility also depends on the operating temperature - the
higher the operating temperature, the more easily vapour
will be formed and become airborne
Level Descriptions Example
Low Pellet like solids that don’t break up. Little dust is
seen during use.
PVC pellets, waxed
flakes
Medium Crystalline, granular solids. When used, dust is seen,
but settles out quickly. Dust is left on surfaces after
use.
Soap powder.
High Fine, light powders. When used, dust clouds can be
seen to form and remain in the air for several
minutes.
Cement, carbon black,
chalk dust.
Table 3.4: Level of dustiness
Degree Descriptions Example
High Boiling point below 50oC Butadiene
Medium Boiling point between 50 and
150oC
Acetaldehyde, acetone,
chloroform, diethylamine
Low Boiling point above 150oC Ethylene glycol, carbon
tetrachloride, n-butyl
acetate
Table 3.5b: Degree of volatility based on boiling point at 25oC
VAPOUR PRESSURE
Pressure exerted by a vapour.
Describes tendency of a chemical to form vapour
Useful (with evaporation rate) in estimating how
quickly a substance becomes airborne within the
workplace (estimation of the inhalation or fire
hazards)
High vapour pressure => volatile(easily vapourised)
Volatility band Vapour pressure
Low Less than 500 Pa
Medium 500 to 25 000 Pa
High More than 25 000 Pa
CONTROL APPROACH
TRADITIONAL CONTROL BANDING
Elimination
Substitution
Modification
Containment
Ventilation
Work Practices
Personal Protective
Equipment
Special-
Expert Advice
Containment
Engineering Control
General Ventilation
PPE for
Respiratory, Skin &
Eyes protections
CONTROL APPROACH
The risk controls are divided into 4 bands or approaches:
• General ventilationCA 1
• Engineering controlCA 2
• ContainmentCA 3
• SpecialCA 4
35
Unit
OperationSheet title
Solids Liquids
Small Medium Large Small Medium Large
Control Approach 2: Engineering control
Mixing Mixing G201 G215 G216 G201 G217 G217
Sieving Sieving G218 G218
Screening Screening G219
Surface
coating
Spray painting G220 G221
Powder coating G222 G222
Lamination Batch lamination G223 G223
Continuous lamination G224 G224
Dipping Pickling bath G225 G226
Vapour degreasing bath G227 G227
Drying Tray drying oven G228 G228
Continuous drying
labyrinth oven
G229 G229
Pelletising Pelletising G230 G230
Tablet press G231
General or Dilution Ventilation Allows chemical emissions to mix with the work
room air then dilutes to acceptable exposure levels
07/10/201536
Engineering
control
37
Local Exhaust Ventilation (LEV)
Fume CupboardSpray booth
CONTROL APPROACH ADJUSTMENTS
CA is adjusted for a very short total duration of
exposure
For very short exposure duration (less than 15
minutes per day) CA drop by 1 level except if CA is
4 or 1.
CONTROL GUIDANCE SHEET (CGS)
G SERIES
(General)GENERAL TASKS
SPECIFIC TASKS
S SERIES
(Skin)
GENERAL GUIDE
PPE SELECTION
R SERIES
(Respiratory) GENERAL
PRINCIPLE
P Series
(for Pest Control)
Direct Advise
SPECIFIC
TASKS
W Series
(for Soldering)
C Series
(for Cleaning Services)
LP Series
(for Lithography Printing)
CONTROL GUIDANCE SHEET (CGS)
Sample of CGS
3. Use Table 3.3 for
scale of Use
5. Finding The Task- Specific
CGS
2. Get H Code
Table 3.1 & 3.2 to get
Hazard Group
Solid
4. Use table 3.4 on
level of dustiness
Is Direct
Advice
Available?
Liquid
4. Use Table 3.5a & 3.5b
and Figure 2 to decide
volatility
6. Select Relevant CGS
• Table 3.8 Pest Control
• Table 3.9 Soldering
• 3.10 Cleaning Services
• 3.11 Lithography Printing
7. Develop & Implement
Action Plan
Report Writing and Record
Keeping
Yes No
SiRAC
Steps
1. Gather Information &
Identify Chemical
5. Use Table 3.6 for selection
of Control Approach
or
Report Format
Form SA1
Form SA2a
Form SA2b
Form SA3
Simple Assessment FormSA1
Company :
Address :
Telephone : Fax : Email :
Type of industry : Employer/Representative Name
:
Position :
Assessor Name : Assessor Contact No. : Assessor
Email :
Total no. of chemicals at the workplace : No. of chemicals assessed (using simple
assessment) :
Summary of Simple Assessment
Process : Task description CGS Existing
control
**
Further Action
Control
Measure
**
Training
yes (✓)
no (×)
EM*
yes (✓)
no (×)
MS*
yes (✓)
no (×)
*Note: CGS: Control Guidance Sheet, EM: Exposure Monitoring, MS: Medical Surveillance
** Existing Control; Control Measure (Fill in the following code)
1. General Ventilation
2. Local exhaust ventilation
3. Containment
4. Training
5. Safe work procedures
6. PPE (please specify) _____________________________________________________________
7. Others (please specify) _____________________________________________________________
Identify and Gather Information on Chemicals SA2a
Work Area :
Date of Assessment :
Process No. of
Worke
r
Task Name of
Chemicals
R-
phrase
/ H-
code
Quantity
Use
Physical
s form
Temp. (oC) Total
Duration
of
Use/day
(min.)
Existing
control
B.P O.T
Simple Assessment Worksheets
SA2b
Work Area :
Date of Assessment :
No. Task Name of
Chemical
s
Hazard
Group
(A, B, C,
D, S)
(Table
3.1&
Table
3.2)
Scale
of Use
(S, M, L)
(Table
3.3)
Dustiness/Vola
tility
(L, M, H)
(Table
3.4/Table 3.5a
or
Table 3.5b)
Total
Duratio
n of Use
<15min
?
Control
Approach
(CA)
(Table 3.6
or
Table 3.7)
CA
Adjustm
ent
Control
Guidanc
e Sheet
(CGS)
(Table
3.8)
Action Plans
SA3
No. Task Name of
ChemicalsExisting control
Adequacy
of control
Action to be
takenDue Date PIC
I ______________ will be responsible for the improvements as specified in the action plan. I also promise to keep good
records of the assessment and hand it over to my successor if my company ceases to carry on business or hand it over
to the Director General of Occupational Safety and Health if there is no successor.
Signature of employer : Position: Date:
Review Asessment
Review In line with USECHH Regulations requirements
Assessment need to be reviewed under any one of the following condition:
> Significant change in work
> New/improved control measures implemented
> 5 years has elapsed
> Directed by DG, DDG or Director of OSH