Friday, 5 August 2011

Under the USECHH 2000, chemicals hazardous to health are those chemicals listed in schedule I and II of USECHH 2000, possess any of the properties categorized in Part B of Schedule I of CPL (Classification, Packaging and Labeling) Regulations, defined as ‘pesticide’ in the Pesticide Act 1974, and listed in the First Schedule of Environmental Quality (Scheduled Wastes) Regulations.

TheGlobalOne.net e-Book Series on Occupational Health & Safety Management
USECHH Regulations 2000
By Ken Hong

USECHH is the abbreviation for Occupational Safety & Health (Use and Standards of Exposure of Chemicals Hazardous to Health) Regulations 2000. It is meant to control the use of any chemical hazardous to health (CHH), set standards and specifications for workplace exposure to these CHH, safeguard the health of employees & other persons at work, and spell out responsibility of employer.

This picture is for illustration purpose only

Under the regulations, employer is to identify CHH in his work place, adhere to the permissible exposure levels (PELs), engage registered assessor to undertake chemical health risk assessment (CHRA) for his work place to control and monitor employee’s exposure level to these CHH.
Other duties of employer include: to properly label CHH being used, provide employees with relevant information, instruction and training on CHH, arrange employees for health surveillance if so required, post warning signs where CHH are stored/used, keep relevant CHH records e.g. maintenance records of engineering control equipment, CHRA reports, exposure monitoring results, and health surveillance results, etc.
Application of these regulations covers all work places where CHH are used. However it does not cover chemicals stated below: radioactive materials defined under the Atomic Energy Licensing Act 1984, chemicals that are hazardous to health solely because of their explosive or flammable properties, or due to their being at high/low temperature or at high pressure. Pharmaceuticals and foodstuffs are also not covered under the USECHH 2000.
Under the USECHH 2000, CHH are those chemicals listed in schedule I and II of USECHH 2000, possess any of the properties categorized in Part B of Schedule I of CPL (Classification, Packaging and Labeling) Regulations, defined as ‘pesticide’ in the Pesticide Act 1974, and listed in the First Schedule of Environmental Quality (Scheduled Wastes) Regulations.
The regulations also requires employer to identify and record all CHH in a register, prepare the register in accordance with DOSH’s  guidelines for the preparation of a chemical register, make the register of CHH accessible to all employees. While register of scheduled waste is to be in accordance with the Environmental Quality (Schedule Wastes) Regulations.
The register shall contain list of all CHH used, current CSDS for each CHH, average monthly or yearly usage, production or storage quantities for each CHH,  the process and work area where the CHH are used, name and address of supplier of each CHH.
Permissible exposure limits (PELs) have also been defined, where no person is expected to be exposed to any CHH in Schedule I: above the ceiling limit at any time, above the 8-Hr time-weighted-average airborne, concentration, specified PEL for that CHH, and above the maximum exposure limit during the work shift.
Once CHH have been identified by employer, a chemical health risk assessment (CHRA) is to be carried out by a registered assessor, and covers: the potential risk to employee resulting from exposure to CHH, handling methods and procedures for CHH, route of exposure to CHH (ingestion, inhalation or skin/eye), and risk to health created by use and release from work processes. Other areas to be covered in the CHRA are emergency response measures, procedures and equipment pertaining to accidental emission from leakage, spillage or process or equipment failure, employee exposure monitoring program, health surveillance program, as well as the employee training and retraining program.
Upon completion of the CHRA, employer must take action within one month from the receipt date of CHRA report to control employee exposure to CHH as recommended by the assessor e.g. changes in work process, practice or procedures, as well as engineering control in order to reduce employee exposure to lowest practicable level, etc.
Control measures may include general examples as listed below: elimination – stop using the CHH; substitution – replace with a chemical less hazardous; enclosure – use partition to limit access to that area; isolation – relocate the process to an isolated  area; or modification of process – change parameters to reduce fume emission; engineering controls – install LEVs to suck out any  fume/vapor released; safe work systems – more stringent work procedures, instruction, etc.; personal protective equipment (PPEs) – respirators, face shield, gloves, etc. However, PPEs should only be used as last resort should other more proactive control measures are not viable.
All chemicals supplied or purchased, and all containers used at work place shall be properly labeled/re-labeled  according to: CPL Regulations 1997 for CHH,  Pesticide Act 1974 for Pesticide, Environmental Quality (Schedule wastes) Regulations for scheduled waste. If CHH is used immediately after transferred, then there is no need to re-label its container as above.
Employer must provide to all employees information related to  potential/known risks to health from exposure, and the precautions to be taken to prevent exposure, obtain CSDS from supplier and make it accessible to all employees. Employer must also review and conduct training program when: employees are assigned to new tasks or new work areas, when hazard information, control, and procedures change, and when 2 years has elapsed if there is no process changes.
Employer must engage DOSH registered hygiene technician to monitor employee exposure at work place: when CHRA indicates that monitoring is required to ensure control of exposure are adequately maintained.
Employer must consult DOSH registered occupational health doctors when a CHRA indicates that medical surveillance is necessary, remove employee from his/her current work areas if he/she has a detected medical condition, or when she becomes pregnant or breast feeding; and only allow them return to their work areas if the above conditions no longer exist.
Warning signs must be: posted at conspicuous place e.g. main entrance to warn employees that they are being exposed to CHH;  illuminating and readily visible especially during unforeseen circumstances e.g. electricity/power failure; written in national language and English for easy  understanding; and must be in red against a white background.
If the employer decides to cease his business he must hand over to his successor and if no successor to the Director General all CHRA reports, maintenance reports on engineering control equipment, exposure monitoring reports health surveillance reports, etc. When the record retention period expires (30 years for some records), employer must notify the  Director General with at least 3 month notice before he disposes of them.
Reference
Occupational Safety and Health (Use and Standards of Exposure of Chemicals Hazardous to Health) Regulations 2000.