Know your chemicals
Gary Singh, business manager at SETA-accredited Occupational Health & Safety Training (OHST), shares some compliance tips relating to working with hazardous chemical substances
There are 17 sections under the Hazardous Chemical Substance Regulation in the Occupational Health & Safety Act, no. 85 of 1993. They are all important, but we will focus on just a few here.
Section 3: Information and training
An employer must ensure, before any employee is exposed to (or may be exposed to) any hazardous chemical substances, that the employee is adequately and comprehensively informed and trained.
This training is critical to ensure that employees are aware of and understand the hazardous chemical substances with which they interact, and, more importantly, the risks associated with exposure to these chemicals, including the potentially detrimental effect on their reproductive ability. They also need to be made aware of the controls that have been engineered and put in place to ensure minimum exposure.
Section 9A: Handling of hazardous chemical substances
In this section, we refer to the Material Safety Datasheet, better known as the MSDS or SDS. A list of all hazardous chemical substances (HCS) must be compiled, and for each HCS there must be an MSDS readily available.
The SDS should consist of 16 sections as per the International Organisation for Standardisation (ISO) standard. These SDSs must be supplied free of charge by the manufacturer of the HCS, and should be located at the site where the substances are being used or stored. It is in the best interests of the employee’s health to ensure that the SDS is read and understood.
Section 14: Labelling, packaging, transportation and storage
This section is highly underestimated.
This regulation is not comprehensive enough to cover all aspects involving
the labelling, packaging, transportation and storage of HCS; hence, one
also needs to take note of the South African National Standards (SANS)
code of practices that regulates this section.
Labelling also needs to be compliant with the Global Harmonised System (GHS) for the labelling of chemicals. One also needs to refer to HCS compatibility charts for the storage and handling of dangerous goods, as well as the conveying thereof by road. Compatibility or segregation of HCS is of paramount importance – non-compatible handling and storage could result in explosions or fires.
Section 15: Disposal of hazardous chemical substances
If you are the originator of the HCS waste, you are liable for it. The phrase “cradle to grave” has intensified to “cradle to grave and beyond”. Simply translated, you shall be liable for any incident that occurs within, or outside, your organisation, resulting from the HCS waste. Even if you use the services of a waste disposal contractor, as an employer you are still responsible and liable. HCS containers and waste must be disposed of in the correct and responsible manner. As an employer you also need to look at your municipal by-laws.