Hazard Identification and Control Banding as a
Potential Alternative to Risk Assessment
John J Whale
Monash University Occupational Health and Safety Unit
Email: john.whale@eng.monash.edu.au
ABSTRACT
Monash University and many other organisations have used the traditional matrix or
consequence likelihood tables as the primary method of assessing risk. This method, although
simple and effective in the hands of a competent practitioner, does little to direct the user
towards typical or multiple controls associated with acceptable protection from the hazard.
Recent changes to the Victorian Occupational Health and Safety Regulations 2007 have
removed the need for “assessment” and instead have placed the emphasis on the use of
controls for known Hazards. Monash University is developing a method to better direct those
who manage hazards to adopt appropriate controls within the Hierarchy and to use layers of
controls to minimise the potential effects of known hazards. The University’s Control Banding
method has been developed to include several classes of hazards, specifically in the areas of
Manual Handling, Equipment & Process (physical), Chemical, Biological and Radiation
Exposure, and link the known associated hazards within these classes to defined control options
thereby removing any control option ambiguity from the assessment.
THE NEED FOR A NEW SYSTEM OF MANAGING HAZARDS
Risk management is an integral part of any safety management system (SMS) and the risk
assessment process is seen as an important component for the management of hazards
(Gallagher 2000, Bluff 2003). The risk assessment process, however, has multiple components
and may be complex and confusing to the novice or untrained user.
Risk management involves establishing an appropriate infrastructure and culture
and applying a logical and systematic method of establishing the context,
identifying, analysing, evaluating, treating, monitoring and communicating risks
associated with any activity, function or process in a way that will enable
organizations to minimize losses and maximize gains.
(AS/NZS 4360:2004 - Risk Management, pg 5)
The current risk management process leaves the participant with a perceived added workload
(normally not factored into projects although crucial for success), insufficient added project or
operational value, as well as no direction in the best way to control the hazards identified (Gadd
2004). This unfortunately means risk management can become a process or rule which is
avoided, generalised and seen as a barrier to work rather than an integral part of the job (Leplat
1998).
The change in the Victorian OHS Regulations (2007) removes the need for analysis as a step in
choosing an appropriate control for known hazards. The removal of the assessment component
from the regulation allows the resources currently being committed by organisations to the
documentation of risk assessments (in order to comply) to be shifted to concentrate on
managing hazards through known controls. The emphasis of the regulation now lies in the
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hazard identification and implementation of controls, with the hierarchy of controls still being a
prominent feature within the regulations (Victorian OHS Regulations 2007).
The Victorian OHS Regulations (2007) state several different categories of risk that need
specific controls (Manual Handling, Plant, Chemicals etc) and that in essence, an employer
must, so far as is reasonably practicable, identify all hazards to health and safety associated
with those tasks to be undertaken by an employee. The control of risk is similar for these
categories and, put simply, the employer must ensure that the risk of a task affecting an
employee is eliminated so far as is reasonably practicable. Where it cannot be eliminated, an
employer must reduce that risk so far as is reasonably practicable by:
•
substituting the way the task was to be performed with a process that presents a lower
level of risk; or
•
using engineering controls; or
•
isolating the plant from people.
(Victorian OHS Regulations 2007)
These primary controls give the highest level of protection from the hazard and are used in
preference to, or in conjunction with, secondary controls such as the use of administrative
controls or personal protective equipment (PPE). The Victorian OHS Regulations (2007) state
that the employer must as part of the control structure provide sufficient information, instruction
and training to enable the employee to perform his or her work in a manner that is safe and
without risks to health. The Regulations also require similar information to be provided by
suppliers and designers of equipment.
From both a Monash University and a safety professional point of view this may mean a more
standardised, directive approach to controlling known hazards rather than the use of secondary
controls.
ISSUES WITH THE CURRENT SYSTEM:
Monash University currently uses a modified consequence versus likelihood matrix system of
risk assessment similar to that prescribed in HB AS/NZS 4360 - Risk Management Companion
Guide -Table 6.6 to evaluate the level of risk and assign controls for the particular hazards
identified. Although this method is adopted in many industries and universities there are many
issues in its execution. The matrix has been seen as a simple way to assess risks and generate
a risk score. However the value of the assessment is in the control selection, which needs
background knowledge in the field of the hazard or significant training.
Successful achievement of goals and objectives depends on how risks and
uncertainties involved with them are assessed and optimal decisions are taken in
containing and managing the risks.’
(Tummala, et al 1996)
The main issues with the current assessment method are:
•
individuals may score Consequence and Likelihood differently therefore the end
assessment (risk score) may be inaccurate
•
ambiguity with end score significance in relation to controls needed
•
addition of controls and reassessment may not reduce risk score so process is perceived
as futile (when the process focus is about assessment not control)
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•
control may be over or under represented as a solution and therefore be oppressive to
the process or not adequately reduce the risk
•
similar scores may be represented for tasks which are obviously dissimilar in risk
o
I.e. making a cup of tea and taking it to one’s office versus operating a lathe.
Within Monash University there is currently an emphasis on all tasks requiring a risk assessment
with risk controls being left up to the risk assessor to identify and then implement. There are
many issues which arise from this approach, such as the following.
•
The possibility that tasks or equipment may still have inadequate or outstanding controls
from prior assessments where the focus has been on the assessment component only.
•
Many “generic” assessments are derived from similar equipment or projects which have
little to do with the true risks involved or the appropriate controls required for the
particular hazard.
•
It may be possible to select an inadequate control for the type of hazard or pick a control
down the Hierarchy for the risk level with little guidance to better options.
•
Choosing an incompatible control because of a lack of hazard knowledge.
•
Choosing a lower order control for expediency, in terms of time, resources or cost.
•
Reassessment of risk with new controls may either under or over estimate the control
effectiveness with the result that the hazard may not have been sufficiently minimised or,
alternatively, that it becomes over protected to the extent that the process becomes
unviable.
Gadd (2004) found similar pitfalls and concerns with the risk assessment process and states that
“effective management of health and safety will depend, amongst other things, on suitable and
sufficient risk assessments being carried out and on the findings being used effectively” (Gadd
2004, Pg 842).
MONASH’S CONCEPT: RISK BANDING PROTOCOL
Monash University’s approach to risk banding has been a culmination of many different
influences. Firstly, the recent changes to the Regulations presented the catalyst to review
current practice. Secondly, the opportunity to elevate the level of controls being utilised where
higher order primary controls are essential and are used in preference to or in combination with
secondary controls. Thirdly, the shift in staff and post-graduate culture to want to more
effectively control hazards within their workplace.
Viner (1991) in his book on accident analysis and hazard control indicates that “risks are best
evaluated by those who experience the adverse consequences...” and controls are best
implemented by “...those who have the authority to make the proposed changes happen” (Viner,
1991, pg 125). This new system combines the expertise of risk practitioners to classify recurrent
hazards and develop associated control structures, but allows those responsible for hazards in
the workplace to identify and manage control implementation.
This model has been developed in consultation with many of the stakeholders within the
University and focuses on known hazards and recognised treatments or controls that are
outlined in many of Monash University’s internal guidelines, AS/NZS standards and Government
regulations (i.e. OGTR). The model also provides an easy reference for researchers who may
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be planning activities to identify what controls need to be incorporated within their projects.
Such an approach raises awareness of the complexity of the respective projects, together with
the need to adequately resource the controls and infrastructure needed. This is particularly
relevant in cross faculty research where controls and hazards may be beyond the researcher’s
area of core expertise.
The risk banding protocol uses known controls, mostly multiple layers, for known groups of
hazards and has:
•
a focus on the elimination or substitution of hazards
•
changed the risk analysis process to a system which incorporates both Monash
University endorsed Protocols and Australian Standards
•
related hazards directly to the selection of known controls
•
use of a hazard specific matrix as well as incorporating a table of control solutions based
on the hazard group.
The new approach uses the University’s traditional Hazard categories and control information
that have been redesigned and reformatted to correspond with the current standards.
The major hazard groupings currently being used by the University are:
•
physical
•
manual handling
•
chemical
•
radiation
•
biological.
Hazard types under these major groupings were expanded to give the user a greater ability to
identify the right controls. For example the physical hazards grouping was expanded to include a
control selection for noise and laser exposure. Other sub groups within the Physical Hazards
grouping may include radiation producing equipment (Xray) and working at heights, which are
still in an early development phase.
The Control Band system utilises four distinct bands of control based on the level of hazard,
these being:
1. low hazard level with low level controls
2. moderate hazard level with the use of selected primary controls
3. high hazard level and multiple primary and secondary controls
4. unacceptable hazard level, no controls or facilities (internally) available and need for
external / independent review.
Where possible direct controls are identified and combinations to reduce contact or impact from
the hazard are used. These “applicable” controls are then selected for the process / task /
equipment
Example of the concept and model for biological hazards and associated control tables can be
seen in appendix 1.
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LIMITATIONS OF RISK BANDING CONCEPT
It is important to note that the risk banding model is only one tool which can be used to
implement controls to reduce injuries or incidents. It is recognised by Monash University that
other systematic processes such as competency based training, safety systems and
infrastructure, as well as a “safety culture”, are needed to reduce the risks As Low As
Reasonably Practicable (ALARP) (HB436: AS/NZS 4360:2004). James Reason’s work in
organisational risk management (1997) recognises the need for multiple levels of controls and
systems as well as an organisational culture active in safe practices, all of which are needed to
reduce injuries or catastrophic events. Reason likened accident causation to a number of slices
of Swiss cheese where the slices represented the defence layers of organisation (procedures,
calibrations, alarms, barriers, etc) and the holes are weaknesses or gaps (active & latent
conditions) in the organisation. Reason proposed that these dormant failures in the system
(latent conditions) and human error can combine to allow an incident to occur (the holes in the
cheese line up) (Reason 1997). Similarly the model proposed in this paper represents only one
slice of cheese, and needs to be combined with other resources and systems to reduce hazards
in the workplace.
The model also may not be useful for tasks which may still need an “assessment” component
such as:
•
dynamic or evolving tasks or tasks which occur in dynamic environment
–
ie maintenance, installations, field trips, one off activities
•
activities which may require Job Safety Analysis or scrutinizing of procedures such as
entry into confined spaces
•
tasks which may have competing or multiple hazards / control options
•
physico-chemical reactivity hazards
•
emerging technologies where hazards and controls are not yet defined
•
psychological injury control.
These require a more in-depth and specialised training approach in hazard identification and
control.
CONCLUSION
Current OHS Regulations in Victoria have removed the need for the assessment of risk where
known controls exist.
The current risk assessment methodology of a likelihood and
consequence matrix has known pitfalls and limitations in its execution and guidance for
controlling hazards. Control banding may be a simple way of bridging the knowledge gap
between an identified known hazards and acceptable levels of control.
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APPENDIX 1 Concept of the Hazard Model and Control Tables
Reduce Process Hazard
Eliminate: Redesign, do not use or do
Substitute: Use a less hazardous alternative
Determine Hazard Classes
As either physical or energy, Chemical,
Biological, radiation or manual handling
No
Is Hazard
Eliminated
Yes
Reduce Hazard in each class
Eliminate: Redesign, do not use or do
Substitute: Use a less hazardous alternative
Select Primary Controls from Tables
Isolate hazards from the person or the
person from the Hazard
Use Engineering Controls to protect from
the hazard
Select Secondary Controls from Tables
Administrative controls such as
procedures, training and signage
Personal Protective Equipment to reduce
the impact of the hazard and as a last line of
defence
Develop Emergency Controls
To reduce the impact or aid recovery of a
primary or secondary control breach.
Isolation, shutdown and contingencies
Example of process for Microbiological Hazards
Document process
Use Hazard Control Sheets as well as using
information in Safe Work Procedures and
Manuals
Page 6 of 10
No
Is Hazard
Eliminated
Yes
Microbiological Hazards
Type of procedure
Microbiological Hazard Identification
Procedures
with low aerosol
risk
Procedures
with high
aerosol risk
Risk group 4
4
Risk group 3
3
Risk group 2
2A
Diagnostic specimens from
animals or humans –
blood, bodily fluids, tissue
Organism Group
•
Identify if the work involves a genetically modified organism (GMO),
then determine to which category it belongs: Exempt dealing, NLRD,
DNIR or DIR. Refer to the Gene Technology Act, 2000.
•
Identify if the work involves the use of imported microbiological samples
and whether they require an import permit. Refer to the ICON database,
which can be accessed from the AQIS website. Confirm if the conditions
on the permit require a QAP facility for the organism.
2B
This analysis must take into account the use and storage of the
organism(s), as well as the disposal of waste products. Each hazard
should be listed separately but assessed as part of an overall process.
2A
2B
- PC2 NLRD; 12
categories as listed in GT
Act
Genetically Modified
Organisms (GMOs): - PC1
NLRD; 3 categories as
listed in GT Act
Identify which risk group (RG1-4) the organism belongs to by referring
to AS2243.3
2B
Genetically Modified
Organisms (GMOs):
- DIR
- DNIR
•
1
ƒ
Using the table below, determine what steps need to taken and the
controls that are needed before work with this organism commences.
ƒ
Identify what controls are currently in place, make a comparison
between this and what the relevant control level stipulates should be in
place and record on the risk control sheet the additional measures (if
applicable) which are to be implemented.
ƒ
Use as many controls as possible without compromising the process or
creating further hazards.
2B
Genetically Modified
Organisms (GMOs): Exempt dealings, i.e.
exempt host-vector
system, < 10L
1
Risk group 1
1
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Hazard Control Reference Sheets – Micro Biological Hazards
Control Group
Description
1
Work with Risk group 1 organisms must be
carried out in facilities that have been
certified as PC1 by the OGTR
Isolation:
Segregation of waste streams: General
waste vs. infectious waste
Only work that has been assessed to have a
low aerosol risk may be conducted on the
bench.
Level 2B: Any procedure which may
produce aerosols of potentially infectious
material should be performed in a Class II
Biosafety cabinet.
A secondary unbreakable container which
can be readily decontaminated must be
used for the transport of
microorganisms/GMO’s between facilities
Level 2B: Centrifuges that are used for
diagnostic samples or infectious
microorganisms must be fitted with either a
sealed rotor or removable buckets, for easy
decontamination in the event of a spill.
Level 2B: Samples must be placed in
sealable tubes
Engineering:
Administration:
2
Level 2 A: Work that has been assessed to
have a low aerosol risk may be conducted
on the bench using good aseptic technique
and must be carried out in facilities that
have been certified as PC2 by the OGTR.
An OGTR license must be obtained prior to
commencing work with DNIR’s and DIR’s
Level 2B: All work must be conducted in a
Class II Biosafety cabinet and PC2 work
practices must be adhered to at all times.
Access to PC2 laboratories should be
restricted to appropriately trained staff
No consumption/storage of food or drink can
be permitted in the facility. If food/drink is to
be used for research purposes, it must be
clearly labelled “Not for human
consumption”.
As per level 1 and….
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3
All work with Risk group 3 organisms must
be conducted in a Class II Biosafety cabinet.
PC3 work practices must be adhered to at
all times.
Access to PC3 laboratories must be
restricted to appropriately trained staff
As per Level 2 and…
Steam sterilizer (autoclave) must be located
within PC3 facility for processing of
infectious waste
Aerosol containment
Class II Biosafety cabinets
Centrifuges with sealed rotors and
removable buckets
As per level 2 and….
Safe Work Instructions for all procedures
Training to include Monash University
Biosafety & Organism specific training
Relevant vaccination(s) e.g. Hepatitis B, Qfever
Personal
Protective
Equipment
(PPE):
Training to include Monash University
Biosafety, Pathogen specific training,
Emergency training including spill
management
High level of planning and supervision of
task
Suitable disinfectant must be available at all
times for regular decontamination of work
benches e.g. Sodium hypochloride or
Ethanol
All potentially infectious waste must be
steam sterilised before leaving the building
or a medical waste contractor must be
engaged for infectious waste disposal
Safe work instructions for all procedures
including spill clean up procedures
Medium level supervision
Health monitoring
Lab coat/gown
As per level 1 and
As per level 1 and
Closed footwear
Suitable gloves – must protect against
biological as well as any chemicals used in
the procedure. Refer to Ansell Glove chart
Suitable gloves – must protect against
biological as well as any chemicals used in
the procedure. Refer to Ansell Glove chart
Respiratory protection
Safety eyewear
Long hair must be tied back
Control Band 4
Work must be carried out in Physical Containment Level 4 (PC4) certified facilities which are located within the Animal Health Laboratories in
Geelong and the VIDRL in North Melbourne.
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REFRENCES
AS/NZS 4360:2004, (2004) Risk Management, Downloaded from Standards online
(8/4/09)
Bluff, L, (2003) Systematic Management of Occupational Health and Safety - Working
Paper 20 National Research Centre for Occupational Health and Safety Regulation
Gadd S.A., Keeley D.M., Balmforth H.F. (2004) Pitfalls in Risk Assessment: Examples
from the UK Safety Science 42 (2004) 841–857
Gallagher, C. (2000). Occupational Health and Safety Systems: System Types and
Effectiveness. Thesis, Deakin University
HB436: AS/NZS 4360:2004 (2004) - Risk Management Companion Guide, Downloaded
from Standards online (8/4/09)
Leplat,J. (1998) About implementation of safety rules, Safety Science 29 (1998)
Monash Risk Control Program (2004)
http://www.adm.monash.edu.au/ohse/assets/docs/others/risk-control-program.pdf
Occupational Health and Safety Regulations 2007, S.R. No. 54/2007, Version
incorporating amendments as at 1 July 2008, Downloaded from
http://www.dms.dpc.vic.gov.au/
Rao Tummala, V. M., Leung, Y.H. (1996). A risk management model to assess safety
and reliability risks. International Journal of Quality, 13(8), 53-62.
Reason.J.T, (1997) Managing the Risks of Organizational Accidents. Ashgate Pub Ltd
Viner, D. (1991). Accident Analysis and Risk Control. Ballarat: Derek Viner Pty Ltd.
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