"To understand something complex, ask a simple question."
~ Alan Duffy ~
An occupational hazard is a thing or situation with the potential to harm a worker. Occupational hazards can be divided into two categories: safety hazards that cause accidents that physically injure workers, and health hazards which result in the development of disease.
The Ontario law that governs employer responsibility, for workers handling chemicals is the Ontario Occupational Health and Safety Act (OHSA). OHSA also governs many hazards in the workplace such as working at heights and confined spaces. There are many regulations under the act but the major chemical handling regulations are shown in Figure 1.
Figure 1: Chemical Handling Regulations Under OHSA
In Addition, there are further OHSA regulations depending on the sector you are working in. Figure 2 shows the sectors with specific requirements under The Act.
Figure 2: Sectors with specific requirements under OHSA.
While most employers believe that WHMIS education and making personal protective equipment available to employees, are the only requirements under the Occupational Health & Safety Act (OHSA), these are just the beginning. Figure 1 shows all the steps required, when handling hazardous chemicals, to be compliant in the province of Ontario.
Figure 1: Rillea Technologies' Continuum for Chemical Handling Compliance
There are, in fact, a minimum of seven steps required to achieve compliance to OHSA, for chemical handling, in Ontario. Links to the specific parts of The Act for each of these requirements, are found below:
The best methods of controlling exposure to a particular hazard will depend on what it is. In general, methods of control can be placed in four categories:
Engineering controls are methods of designing or modifying plants, processes and equipment so as to minimize workers' exposure to the hazard. They are preferred because they work independently of workers.
Work and hygiene practices are on-the-job activities that reduce the potential for exposure.
Administrative controls are things like job rotation schedules, work-rest cycles and timing of maintenance procedures, which can be used to limit the amount of time an individual is exposed to a hazard.
Personal protective equipment includes items like respirators, hearing protectors, safety clothing and protective clothing. They can reduce a worker's exposure but must be used properly to be effective.
PPE should be provided to workers wherever there are health (or safety) risks that cannot be adequately controlled in other ways. PPE can reduce or prevent a worker's exposure to a health hazard in the workplace and can include respirators, hearing protectors, protective clothing, footwear and face and eye shields.
PPE is also required in specific situations and dealt with in regulations made under OHSA. For example:
Section 7.2(2) of the Regulation respecting the Control of Exposure to Biological or Chemical Agents requires respirators to be provided when engineering controls are not practical.
Employers are required by OHSA to take all reasonable precautions to protect the health and safety of workers.
WHMIS does not require that SDSs be obtained for consumer products. Consumer products are obtained by an individual to be used for non-commercial purposes (ie: items that can be purchased by the public at a retail store) and contain consumer product warning symbols not WHMIS symbols. As an employer you are still required to train employees on the safe handling, storage and use of these products. The easiest way to do this is the same way you train employees on hazardous products – with the information on an SDS.
You should also keep in mind that the duration and frequency of use (and therefore exposure) of these products in your workplace could be much greater than what the typical consumer would experience. A Window Cleaner would use “Windex” with much greater frequency than a consumer would in their home.
SDSs are not required for non-hazardous chemicals. However, an easy way to show a product is non-hazardous is to have an SDS for it.
No. But keep in mind what a "manufactured article" is. Part of the definition states that under normal conditions of use, it will not release or cause an individual to be exposed to a hazardous product; and when being installed, it will not release or cause an individual to be exposed to a hazardous product.
The following examples are commonly used items which are NOT manufactured articles.
- Welding rods are not manufactured articles because during use they release hazardous products previously contained in the rods.
- Sheets of friction materials that contain asbestos and which are manufactured with the intent of later being cut or shaped to form specific friction products are not manufactured articles.
No. Per section 38(5) of the Occupational Health and Safety Act in Ontario, electronic copies are sufficient as long as employees have access to the information at all times.
Suppliers often have no idea about how chemicals are to be used or the types of personal protective equipment (PPE) that may be available to employees. Perhaps employees will be mixing chemicals. Perhaps the chemicals are used in very small or large quantities. As a result, an employer must conduct a risk assessment to understand how the chemical is to be used and provide clear guidance to employees about the type of PPE required and where it can be found.
The onboarding process for SDS RiskAssist™ is made up of 8 steps. They are as follows:
- Custom website setup - Rillea can build a client's website in minutes, if necessary. However, the time to customize the website depends on the client. Rillea makes the process easy by providing an electronic form with all required information. This form takes about 15 minutes to complete and submit.
- Accurate Chemical Inventory - The most important task of the onboarding process is to start with an accurate chemical inventory. This can be accomplished using binders, if they have been kept up-to-date, procurement records from the last year to know what was purchased, or a chemical inventory. Rillea provides services to help with conducting chemical inventories at an additional charge.
- Acquire up-to-date SDSs - Using the accurate inventory, the client can acquire up-to-date SDSs from the internet or chemical suppliers. Rillea will complete these services for the client at an additional charge.
- Upload SDSs - Once up-to-date SDSs have been acquired, they can be uploaded by the client (at a rate of about 200/hr) or the electronic files can be shared via Dropbox for Rillea to upload at no extra charge.
- Auto-tag - if the client has purchased the option to auto-tag, Rillea personnel will work with them to develop auto-tag directives. Once this has been completed, all chemicals will be tagged with directives with a click of the mouse. Workers having access to SDS RiskAssist™ will be able to immediately obtain the 1-page summaries for safe chemical handling.
- Frequency of use - since risk of harm to workers depends on the severity of the hazard and frequency of use, Rillea recommends that the client populate the frequency of use (daily, weekly, monthly, yearly) for each of the high-hazard chemicals. Once this information is entered, clients can filter on high frequency/high hazard chemicals to prioritize risk assessment activities.
- Define organization-specific tags or directives - schedule risk assessments and record resulting directives, if different from the auto-generated tags or directives in step 5. Clear directives are better for worker safety when using high-risk chemicals.
- Audit & review - Rillea recommends that the safety officer discuss the handling of chemicals with employees to ensure the directives can be followed. Adjust directives based on feedback for continuous improvement. Also ensure that SDSs are kept up-to-date by checking the supplier provided SDS against the version available in SDS RiskAssist™. If necessary, upload the new SDS, review any changes in the hazards, tag the chemical with directives and archive the older version.