Guidance note A Applying the Hierarchy of Control At all times, regardless of the level of risk, we are required to do what is reasonably practicable to eliminate or minimise the risk of any hazard with the potential to cause harm. Control measures are the things we do to eliminate or lower the level of risk. The types of control measures are categorised according to the ‘hierarchy of control’. Controls should be considered and used in this preferred order. Hierarchy of Control Most effective (High level) Elimination: remove the hazard completely from the workplace or activity Substitution: replace a hazard with a less dangerous one (e.g. a less hazardous chemical) Redesign: making a machine or work process safer (e.g. raise a bench to reduce bending) Isolation: separate people from the hazard (e.g. safety barrier) Administration: putting rules, signage or training in place to make a workplace safer (e.g. not mowing near people, painting trip hazards) Least effective (Low level) Personal Protective Equipment (PPE): Protective clothing and equipment (e.g. gloves, lab coats/overalls, enclosed leather shoes) Higher level controls are considered more effective and are therefore preferred, because they eliminate or reduce the risk of harm for everyone at all times. Lower level controls are less preferred because, essentially, the risk of harm still exists and they require people doing the right thing to provide an element of safety. If lower level controls are to be implemented instead of higher level controls, it is important that the reasons behind the decision are explained. The following table provides options and examples to guide you in applying the hierarchy of control to your risk management process: Guidance note A Controls Applying the Hierarchy of Control Options Examples of Hierarchy of Control Elimination Eliminate the use of the substance New risk assessment required Find alternative process that removes the need for the chemical or eliminate an activity that increases the risks. Use a physical process instead of a chemical process e.g. using ultrasound to clean equipment instead of a process involving chemicals; using clips/bolts or nails instead of adhesive. Substitution Use a safer substance or a safer form of the substance New risk assessment required Find less dangerous material to use - use detergent instead of chlorinated solvent for cleaning, use water-based chemicals instead of solvent-based, use less hazardous chemicals where compatible to the task. Use safer form (e.g. pellets vs. powder) or process – paint with a brush instead of spraying, purchase a substance in a safer form. Reduction Reduce amount stored Ensure the smallest possible volumes are purchased and stored for effective operation. Uncontrolled copy. Refer to the Department of Education, Training and Employment Policy and Procedure Register at http://ppr.det.qld.gov.au/ to ensure you have the most current version of this document Chemical Use Activity Guidance Notes — Page 1 of 10 Guidance note A Controls Applying the Hierarchy of Control Options Examples of Hierarchy of Control Isolation Separate people or property from the substance by distance or barriers Separate safety cabinet/ cupboard/ shelf/separate spill trays/Fire separation (>5 m)/Space separation (> 3m) Consider separation from other dangerous goods (see http://www.deir.qld.gov.au/workplace/subjects/hazardousmaterials/incompatible/isolati on/index.htm#compatible for guidance. Use closed systems. Isolate the process to one room with restricted access or use appropriate barriers/screens to separate substances. Distance workers from substances/processes through the use of remote controls. Distance property, incompatible chemicals and ignition sources (e.g. flames, sparks) from goods. Separation Separation from ignition sources Use of storage cabinets Consider ignition sources – flames, electrical fittings, static, friction. Classes and Subsidiary Risks 2.1, 3, 4, 5 and Combustible Liquids at least 5 metres from all ignition sources and naked flames. Separation from incompatible substances. Engineering Use physical controls (such as plant/ equipment) that eliminate or reduce the generation of substances; suppress or contain substances; or limit the area of contamination in the event of spills and leaks Use bunding/trays/appropriate material for containers to contain spillage. Use local exhaust or natural ventilation systems (e.g. air ducts, open doors/windows), general ventilation/local exhaust ventilation/regular compliance/inspection of fume hoods undertaken. Fully or partially enclose the process with exhaust extraction/use fully or partially enclosed ventilation booths. Register of chemicals with special storage requirements kept to maintain regular inspection and recording. Fire detection and suppression/compliance inspection of fire systems undertaken. Flammable and gas generating substances kept in spark-free refrigeration. Electrostatic control/vapour control. Keep under a nitrogen/water/kerosene/paraffin blanket. Temperature control. Administrative Use safe work practices including good housekeeping. Regularly review work procedures Ensure induction and training has been undertaken and records are maintained Regular Inspection of storage area undertaken (e.g. checklist). Advisory signs for storage locations, hazard ID, emergency. Instruct employees on how to use substances safely Train staff in use of fire equipment and emergency procedures. Mark receipt and expiry dates noted on containers on receipt. Develop and establish standard procedures for safe receipting and storage of new stock. Reduce the amount of property or the number of employees exposed/keys not available to all staff/storage is secured at all times/authorised persons only. Training records kept. Safety instructions continually enforced. Ensure safe interim storage of wastes/products (e.g. labelled properly in suitable containers stored away from people, the environment, incompatible chemicals, ignition sources, etc). Provide first aid facilities/provide suitable washing facilities/fire extinguishers. Cover containers and make sure lids are attached. Clean up spills immediately (includes provision of suitable aids, equipment and isolate floor and storm water drains, avoid dust). Ensure no eating, drinking or smoking in areas where substances are used. Supervision Untrained/unqualified staff are supervised at all times or access is restricted Personal Protective Equipment (PPE) Provide protective clothing and equipment for employees, supervisors and visitors. NB: items must be compatible with chemical(s) being used/ stored Overalls, aprons, gowns, chemical resistant suits. Footwear (enclosed leather upper shoes, safety boots) gloves. Chemical resistant glasses (safety glasses). Face shields/masks, respirators, full/partial head protection. Uncontrolled copy. Refer to the Department of Education, Training and Employment Policy and Procedure Register at http://ppr.det.qld.gov.au/ to ensure you have the most current version of this document Chemical Use Activity Guidance Notes — Page 2 of 10 Guidance note B Hazard Management - Control Measures Listed below are some indicative hazards/risks and suggested control measures for operations undertaken with chemicals. They are by no means exhaustive lists. There may be other non-chemical hazards associated with the activity. Add details of any other hazards/risks or additional controls you intend to implement in your risk assessment. Refer to the product Safety Data Sheet (SDS) for specific chemical hazards and control measures. For any items not applicable, please tick N/A. [Preferred control measures should be implemented in accordance with the hierarchy of control. If lower level controls (such as Administrative or PPE) are to be implemented instead of higher level controls (e.g. elimination, substitution, engineering controls), it is important that the reasons are explained]. For general information regarding curriculum risk management, refer to Managing Risks in School Curriculum Activities. All persons engaging in this activity should: identify the hazards, including any additional hazards not mentioned here assess their significance manage the potential risks. Physical Chemical Risks Chemical Hazards/Risks Health Hazards Suggested Control Measures Physical Hazards Reactivity Stability Fire/Explosion Fume/Vapour build up Hazardous reaction Uncontrolled reaction Odours Hazardous by-products Environmental hazards Spills Leaks Contamination This is the safest material available to achieve the desired result. A current SDS for the material is referred to, and all its requirements are complied with. The minimum amount of the material at the weakest possible dilution to achieve the desired outcome will be used. Management processes including [provide details]are established for handling, distribution and control during activities. All conditions for the safe management of the work area are met (refer to relevant SDS, SOP and workplace guidelines), especially as relates to the safe handling, use and storage of the chemical or work process. All containers storing the material are suitably labelled. Adequate ventilation is provided (especially for volatile, combustible materials). All recommendations regarding the management of physicals hazards listed on the SDS are adhered to. All extraction equipment (fumes/dust) are fitted and in operational order. Work procedures that minimise the generation of dust/gas/vapour/spray or fumes are used. All incompatible chemicals are kept segregated to avoid cross contamination or hazardous reaction (do not store fuel near fertilizers, herbicides with pesticides/fungicides and DG labelled reagents with incompatible classes). The chemical product is used for the purpose specified and no unauthorised mixing of substances occurs. Waste disposal occurs according to direction on SDS. Disposal method: Safe for Sewerage or Regulated Disposal or Safe for Sewerage after neutralisation/dilution. Containers are triple rinsed and rendered unsuitable for reuse before disposal to industrial bin. Rinse effluent is treated as hazardous and treated accordingly. Implement control processes to restrict the possibility of spillage and accidental contact with chemicals, and to allow the safe containment and/or easy removal of spilled chemicals. Such processes might include: establish safety procedures for the preparation and use of solutions limit the amounts of chemicals used restrict movement around the work area clearly and informatively label all containers of chemicals for student use and replace the lids on containers immediately after use have access to running water/eyewash/safety shower before engaging in the activity, students should be informed of the appropriate clearly identified process of dealing with substances if they are spilled. Take care to handle and store substances in the approved manner. Uncontrolled copy. Refer to the Department of Education, Training and Employment Policy and Procedure Register at http://ppr.det.qld.gov.au/ to ensure you have the most current version of this document Chemical Use Activity Guidance Notes — Page 3 of 10 Chemical Handling Risks (refer to SDS for addition handling information) Handling risks Handling considerations Labelling Suggested Control Measures Safety Management Spills Contamination Supervision Personal Protection Work area conditions including environment if working outdoors Weather Surfaces Surrounds Students Instructions Experience Special needs Medical conditions Student numbers High risk behaviour First aid provisions Equipment/Materials Sharp implements Glass breakages Plant/tools/ equipment The SDS has been consulted to determine specific handling considerations. Work processes are selected to prevent or minimise the risk of injuries caused by manual tasks. The labelling is securely attached, the product is labelled in accordance with regulations and the product has been labelled after it has been decanted. A current SDS for the material is referred to, and all its requirements are complied with. Processes for pumping/decanting/dispensing/filling/diluting/using the chemical reduce the generation of vapours/dust and minimise spills and splashes. Ensure that appropriate cleanup equipment (spill kits, broom, dustpan and brush, glass bin) is available. Safe hygiene standards and processes will be maintained to ensure only safe exposure to the material. Suitable personal protective equipment (PPE) as described in the SDS is available, clean and is in working order, complies with Australian Standards and is worn in accordance with the SDS. Appropriate enclosed footwear is worn by all participants. All conditions for the safe management of the work area are met, especially as they relate to the safe handling, use and storage of the material and access to safety and emergency equipment. All containers storing the material are suitably labelled Sufficient clear space is available to undertake the task and nearby hazards have been removed or controlled. Relevant instructions on the work and safety procedures is provided to students before they are exposed to the material, the activity including the hazardous materials being used, safety procedures and appropriate work site safety measures. Students have had suitable experience to use the material. Induction and Training is provided. Safety instructions continually enforced and training records are kept. Student work areas should have: o suitable ventilation for the activity o stable work tables or benches of a suitable height for the students o adequate room for movement of persons involved so they do not cause an additional hazard o access to all safety equipment. Safety zones established to ensure that students have an adequate work area that other students will not enter. Refer to individual education plan/behaviour management plan or other student documentation. Medications and emergency responses are available for students with medical conditions. Emphasise need for student hygiene (hand washing, no food or drink). Where necessary, obtain advice from relevant advisory visiting teachers or specialist teachers. are available and ready to use to execute planned emergency responses (e.g. ice packs, neutralising agents, antidotes, product SDS); and trained staff are available to administer first aid; and workers are aware of the location of first aid facilities and who the designated first aid officers are. Safety instructions will be provided for the use and handling of any equipment used in association with the material. Establish safety zones for use of equipment. All equipment items are maintained as required, and will be visually inspected before use. Clean up equipment is available [provide details]. Uncontrolled copy. Refer to the Department of Education, Training and Employment Policy and Procedure Register at http://ppr.det.qld.gov.au/ to ensure you have the most current version of this document Chemical Use Activity Guidance Notes — Page 4 of 10 Handling risks Electricity (refer to SDS for addition handling information) Suggested Control Measures Ensure Electrical Safety Guidelines are adhered to. Implement control processes for the safe use of power, heat and/or the use of combustible substances in any activity. Transport Risks Transport risks Transport considerations Suggested Control Measures Ensure products are adequately labelled and lids are securely sealed. The containers should be firmly secured and protected from other objects striking against them during transport. Use trolleys or carriers to move large glass or heavy containers. Avoid transport of chemicals in private vehicles where possible. Avoid transporting chemicals in enclosed spaces (e.g. cabin of car or ute). Only approved containers designed specifically for the containment of the chemical should be used. Storage Risks Storage risks Storage Considerations Spills Leaks Fire Explosion Fumes Vapour build up Hazardous reaction Suggested Control Measures Chemicals are stored separately to other incompatible Global Harmonised System (GHS) divisions. Storage occurs as described in SDS. Chemical must be stored [provide details]. Chemicals are segregated by separate storage in a safety cabinet/cupboard/shelf/same cupboard - separate spill trays. Space separation (> 3m). Volatile chemicals are stored away from ignition sources. Fire separation (>5 m) Spill containment is used (bunding/use of trays) and is made of appropriate material so as not to react with the chemical(s). Fire detection and suppression systems are compliant and inspection of fire systems is undertaken regularly. Staff are trained in the use of fire equipment and emergency procedures. Ensure all sources of ignition (sparks, naked flame, static) are removed from the work area. General ventilation/local exhaust ventilation is available for vapour control and regular compliance inspection of fume hoods is undertaken. Register of chemicals with special storage requirements is kept and regular safety inspections undertaken. Temperature control is observed (chemical temperature tolerances are compatible with ambient room temperatures – refer to SDS). Housekeeping - regular inspection of storage area undertaken (e.g. a checklist). Advisory signs for storage locations, hazard identification and emergency information are clear and well positioned. Good stock control practices are used (e.g. manifests, hazardous chemical register, receipt and expiry dates noted on containers, adequate labelling). Storage is secured at all times. Keys not available to all staff and entry is restricted to authorised persons only. Chemical storage should be: o secure from forced entry o well ventilated, either by fan forced or by natural means o sufficiently large so that movement is not likely to cause additional hazards. Fit for purpose (storage should be able to cater for the various classes of hazardous compounds, e.g. corrosive liquids (acids), flammable materials, toxic materials). Uncontrolled copy. Refer to the Department of Education, Training and Employment Policy and Procedure Register at http://ppr.det.qld.gov.au/ to ensure you have the most current version of this document Chemical Use Activity Guidance Notes — Page 5 of 10 Storage risks Equipment/Materials Storage cabinets/ shelving/plant/ tools/equipment Suggested Control Measures Safety instructions are provided for the use of any equipment used in association with the substance. All equipment items are maintained as required, and will be visually inspected before use. All conditions for the safe management of the work area are met, especially as they relate to the safe handling, use and storage of the material. There is sufficient space and adequate lighting to undertake the task safely. Outdoor activities Waste treatment/disposal facilities. Access to water supply for emergency first aid treatment/emergency response. Use of trays/carriers for the transport and storage of chemicals. Emergency response A Chemical Spill Kit is available: the spill kit contains materials appropriate to type of chemical being used; and a spill response procedure is available and personnel are trained in its use; and staff and students are aware of the spill kit location. In case of an uncontrolled release (e.g. spill, explosion) an emergency response plan has been established, and the necessary resources are readily available to execute the plan. General hazards Hazard General hazards Contact Collision Slip Fall Impact Moving parts Noise Posture Sharps Weather Surfaces Surrounds Recommended Control Measures Physical hazards Breakage/rupture (e.g. glass, plastic) spills, splashes Physical injury Breaks/sprains Cuts and grazes Concussion Accidental contact Chemical burns Skin/eye/ respiratory irritation Absorption Injury Visual Temperature Fatigue Dehydration Ensure that a venue is selected which is appropriate to the activity, taking into consideration the following: o working space o access to emergency facilities and safety equipment o ventilation. Ensure environmental conditions are suitable for the activity (e.g. light levels, wind speed and direction, terrain). Inspect equipment for cracks and damage before use. Do not heat or cool materials quickly. Ensure that appropriate clean-up equipment (broom, dustpan and brush) is available. Ensure that appropriate decontamination materials are available in cases of spillage of hazardous materials. Label information and SDS information should give details of the type of decontamination material required for each chemical. Ensure that everyone handles materials and equipment carefully. Provide instruction in the form of demonstration, rules, standard operating procedures, prerequisite skills and emergency response before students undertake the activity. Ensure that students wear appropriate PPE including enclosed footwear and sun protection where required. Uncontrolled copy. Refer to the Department of Education, Training and Employment Policy and Procedure Register at http://ppr.det.qld.gov.au/ to ensure you have the most current version of this document Chemical Use Activity Guidance Notes — Page 6 of 10 Hazard Recommended Control Measures Electrical/heating hazards Burns Voltage Current Cold Heat Shock Ensure Electrical Safety Guidelines are adhered to. Safety switches have been installed and tested. Equipment is visually inspected before use. Equipment has been tested (where appropriate) and is in good repair. Heat sources Hot plates Flames Friction Conduction Radiation Welding processes Kilns, ovens, or incubators Exo- or endothermic reactions Implement control processes for the safe use of heat and/or the use of combustible substances in any activity. Such processes might include: o keeping burners on low heat while not directly using them o keeping combustible substances a specified minimum distance away from naked flames/using small amounts o using appropriate water, sand or oil bath heating techniques. Apparatus/tools/machi nery or equipment Pressure/Vacuum Heat Moving parts Projectiles Ventilation Entanglement/ Crushing Scientific apparatus Machinery (fixed plant/portable) Hand tools Vehicles/trailers Ensure that equipment to be used with hazardous materials is checked to confirm that it is safe, properly maintained and used in accordance with the manufacturer's operating manual and/or relevant code of practice. Ensure that others not actively involved in the activity with hazardous materials are kept at a safe distance (e.g. in an area where they will not be exposed to agricultural chemical hazards). Undertake a risk management process in order to prevent or minimise the risk of injuries caused by manual tasks. Reduce handling and exposure risks by providing diluted or pre-mixed substances for student use or providing activity as a demonstration (note that students are only permitted to handle and mix schedule 5 hazardous materials). Manual tasks Environment Design Shape Weight Repetition Force Posture Personal Factors Special needs Stability Temperature Grip Working at heights Restricted space Uncontrolled copy. Refer to the Department of Education, Training and Employment Policy and Procedure Register at http://ppr.det.qld.gov.au/ to ensure you have the most current version of this document Chemical Use Activity Guidance Notes — Page 7 of 10 Guidance note C Risk Assessment Conclusions The purpose of a chemical risk assessment is to enable decisions to be made about appropriate control measures, training, and monitoring of hazards associated with a chemical or a chemical process. The assessment does this by establishing: the nature and severity of the hazard for each hazardous chemical the degree of exposure of persons in the workplace, and whether existing control measures adequately control exposure. The information collected, and the decisions made around the points above, allow us to make reasoned conclusions about the risk of using of a hazardous chemical under particular working conditions. Making conclusions about a risk level is important as it allows us to determine what action is required. Regardless of the risk classification, we always have an obligation to do what is reasonably practicable to eliminate the risk, or if that is not possible, to minimise the risk to the lowest possible level. The Risk Assessment Conclusions table may be used as a guide to assist with quantifying the risk level. Note that conclusions 1 to 4 differ from other CARA risk level matrices used by DETE for non-chemical based activities. These differences arise because of legislative requirements and because we know what the consequences are if we are exposed to a chemical during a curriculum activity (the consequences are documented in the SDS). However, in non-chemical activity risk assessments, informed judgments are made about the inherent risks associated with the activity, as the consequences can only be projected. The result of this process means that there can only be an indicative relationship between the CARA risk levels of low, medium or high and risk conclusions 1 to 4. Activities involving chemicals may only be undertaken at the risk conclusion 1 or risk conclusion 2 levels. Once risks are not effectively controlled (conclusion 3 and conclusion 4 activities), or there is not sufficient certainty about the risks associated with an activity, the level of exposure to a chemical cannot be determined with confidence and the activity becomes unsafe. Thus, Conclusion 3 risk classifications must be revised to reduce the risks, as risks are not effectively controlled. Conclusion 4 activities are not to proceed because there is insufficient information available to make a valid risk conclusion. Schools are reminded that a Curriculum Activity Risk Assessment Register is to be established and maintained for Conclusion 2 activities, where the risk occurs at the higher end of the spectrum where risks are significant and not effectively controlled. A School Curriculum Activity Register can assist schools to record and manage the details of their risk management strategies involving hazardous chemicals. Uncontrolled copy. Refer to the Department of Education, Training and Employment Policy and Procedure Register at http://ppr.det.qld.gov.au/ to ensure you have the most current version of this document Chemical Use Activity Guidance Notes — Page 8 of 10 Risk Assessment Conclusions Overall Risk Level Conclusion Conclusion 1 Action Required/Approval Risks are not significant Comply with all requirements of the label and current SDS. now, and not likely to Comply with the standard operating procedure for the increase in the future (i.e. substance(s). risks are low) Manage and document through regular planning processes and/or the person(s) using the chemicals should approve and sign the risk assessment. Select 1 if you are using a concentration less than which is considered hazardous or no precautions are required and it is unlikely that the use of the chemical(s) will adversely affect the health of persons at the workplace and the risk is not likely to increase in the future, e.g. you are using concentrations that are too small to constitute a risk, even if controls fail, or the operation strictly conforms to the information on the label and in the SDS. Risks are significant but effectively controlled, and could increase in the future (i.e. medium to high risk) Conclusion 2 Comply with all requirements of the label and current SDS. Comply with the standard operating procedure for the substance(s). Implement the identified controls to minimise the chances of higher exposure occurring. Determine and implement additional measures for regaining control if a high risk event occurs despite the precautions already taken. Parental consent may be required. Document controls in planning documents and/or complete this Chemical Use Curriculum Activity Risk Assessment. The Principal or delegated head of program (i.e. DP, HOD, HOSES) to review and approve the risk assessment. Select 2 if you are satisfied that adequate controls are in place. Select where serious health effects could result if the control measures fail or deteriorate. This usually results from the use of toxic hazardous chemicals or where the potential exposure is high. Risks, while presently adequately controlled, could increase in the future. Risks significant now and not effectively controlled (extreme risk) Conclusion 3 The activity must not proceed. Alternatives to undertaking the activity must be found. Obtain additional information or expert advice to reach a conclusion of 1 or 2. Comply with all requirements of the current SDS. Comply with the standard operating procedure for the substance(s). Implement sufficient controls to ensure the safe use of the material. The Principal is required to review and approve the revised risk assessment prior to conducting this activity. Select 3 if the use of a chemical is likely to constitute a significant risk and further investigation may be necessary (e.g. there are persistent or widespread complaints of illness, discomfort, irritation or excessive odour, hazardous chemicals are splashed; control measures are broken, defective or badly maintained, for example a poorly maintained extraction system which no longer draws a hazardous chemical away from the work area; recognised safe work practices are not being observed). Conclusion 4 Uncertain about risks There is not enough information, or there is uncertainty about degree or extent of exposure. DO NOT PROCEED. The activity must not proceed. Alternatives to undertaking the activity must be found. Obtain additional information or expert advice to reach a conclusion of 1 or 2. In the meantime, implement work practices to ensure safety. Select 4 if no SDS is available, labelling is inadequate, the level of exposure cannot be estimated with confidence or further investigation is necessary. Obtain additional information from other sources, such as suppliers, occupational health and safety consultants and industry or trade associations. Meanwhile, implement good work practices to minimise exposure. Uncontrolled copy. Refer to the Department of Education, Training and Employment Policy and Procedure Register at http://ppr.det.qld.gov.au/ to ensure you have the most current version of this document Chemical Use Activity Guidance Notes — Page 9 of 10 HAZARDOUS CHEMICAL Curriculum Activity Risk Management Flowchart Establishing the context: 1. Which students will be involved? 2. What will the students be doing? 3. What will the students be using? 4. Where will the students be? 5. Who will be leading the activity? 6. What is the level of chemical exposure? Planning – Manage and document through regular risk planning processes. If hazardous chemicals are involved, refer to the chemical CARA 1. Identify chemical 2. Identify hazards 3. Identify control measures Conclusion 1 (Non-hazardous) Risks are not significant. No exposure controls needed. 4. Classify risk conclusion 5. Determine actions/approval required Conclusion 2 (Hazardous) Conclusion 3 (Uncontrolled risk) Conclusion 4 (Risks uncertain) Use constitutes a significant risk and further investigation is required. Adequate controls are in place. Health effects are minimal if control measures fail. Revise activity Adequate controls are in place. Serious health effects (e.g. burns, dizziness) could result if control measures fail. Regular planning Chemical Curriculum Risk Assessment Template Approval by Principal or delegated officer School Curriculum Activity Register Implement safety control measures, conduct activity, monitor safety and controls. Review controls Uncontrolled copy. Refer to the Department of Education, Training and Employment Policy and Procedure Register at http://ppr.det.qld.gov.au/ to ensure you have the most current version of this document Chemical Use Activity Guidance Notes — Page 10 of 10