Thursday, June 13, 2013

Occupational Exposure Limits in Australia

Every country has its own legal system and within that system its own occupational safety laws. For people not familiar with these laws, finding the relevant occupational exposure limits (OELs) can be time consuming.  This blog recently provided an article with links for readers to find occupational exposure limits in Canada, and compared these to the US OSHA Limits. This article provides similar information for Australia.

Unlike the United States which has a strong federal government and relatively weak states, in Australia the opposite is true. The provinces are considered co-sovereign states with the federal government; and the territories though under the egis of the federal government, also promulgate their own laws. However, all the six states and several territories collaborated through an organization called Safe Work Australia to develop a common set of OELs and a model occupational statute and associated regulations that the states and territories can adopt.


Occupational Exposure Limits
Safe Work has created an on-line database for occupational exposure limits, which allows chemicals to be searched by name or CAS number. The complete list of OELs is also available for download as a pdf. The OEL for some representative compounds are shown below and for the most part they are fairly similar to those used in the US.

                                   Australia              US-OSHA              ACGIH TLV
Ethylene Oxide             1 ppm (8 hr TWA)            1 ppm (8 hr TWA)           1 ppm (8 hr TWA)
Glutaraldehyde            0.1 ppm peak                       n/a                                            0.05 ppm ceiling
Hydrogen peroxide     1 ppm (8 hr TWA)            1 ppm (8 hr TWA)           1 ppm (8 hr TWA)
Ozone                                     0.1 ppm                                  0.1 ppm (8 hr TWA)        0.05 - 0.2 ppm
                                                                                                                                            
Notes: 
1) TWA = time weighted average, peak = ceiling = maximum permissible exposure at any time.
2) Regulations are always subject to change and to the readers should verify that the above information is correct before relying on this information.


Work Safe has also developed a guide on the application of workplace exposure standards for airborne contaminants (exposure standards) in the workplace. 

Occupational Safety Statutes and Regulations
The federal government and all of the states and territories, except for Victoria, have adopted the model statute and regulations. As with most common law countries, the legislature passes a broad act or statute that empowers a government agency to then develop more specific regulations. The statutes and regulations are listed below as a reference but will not discussed further in this article.

Work Health and Safety Act 2011

Model Work Health and Safety Regulations 2011

While Victoria's statute is different from the other states, its occupational laws are generally compatible.

The Victoria Occupational Safety and Health Act of 2004

The Victoria - Occupational Health and Safety Regulations 2007





Wednesday, June 5, 2013

Occupational Exposure Limits in Canada Compared to the US.


The primary goal of this blog article is to allow readers to easily find exposure data in the US and Canada, by following the links in the text. Hydrogen peroxide will be used as an exemplary chemical to compare exposure limits, but the exposure limits for other chemicals are usually in the same sources, though some jurisdictions list carcinogens separately.

The Canadian provinces each set their own occupational exposure limits, though the majority of them follow the American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit values (TLVs). The occupational exposure limits for each Canadian province (P) and Territory (T) is set out below:

Note: Regulations are always subject to change and to the readers should verify that the above information is correct before relying on this information. 

The current ACGIH TLV for hydrogen peroxide is 1 ppm calculated as an 8 hour TWA.  The ACGIH TLVs are time weighted exposures (TWA) that are reviewed periodically based on the available scientific data.

For the US, the OSHA PEL for hydrogen peroxide is 1 ppm (8 hr TWA) with no short term exposure limit. Hawaii and Washington have the same 8 hr PEL, but also have a STEL of 3 ppm (15 min. TWA). 


There are significant jurisdictional differences between the US and Canada. In the United States, the Occupational Safety and Health Administration (OSHA) establishes safety standards for the entire country including permissible exposure limits (PELs) for workplace exposure to chemicals. Most state agencies with responsibility for workplace safety follow the federal limits, though a few, such as California, Washington and Hawaii set their own PELs but these state PELs are either the same or more restrictive than the OSHA PELs because of the Supremacy clause in Article VI of the US constitution.

Unlike the United States which has a strong federal government and relatively weak states, in Canada the opposite is true. In Canada there are ten provinces and three territories. The provinces are considered co-sovereign states with the federal government; and the territories though under the egis of the federal government, also promulgate their own laws. Thus people working with chemicals in Canada need to look at the requirements of each province and territory separately.


Friday, May 31, 2013

No OSHA Hazcom Training in Healthcare

The last two blog entries described a survey of low temperature sterilization and liquid sterilants and high level disinfectants. The survey was conducted at the recent IAHCSMM show where we invited attendees to complete a short information card in exchange for being entered into a competition to win some prizes.

We had about 175 respondents and eliminated entries that did not list the chemicals and equipment, and multiple people from the same institution. For this analysis non-US facilities were also excluded, leaving 117 US based facilities that use low temperature sterilization and in most cases liquid sterilants/high level disinfectants

The most startling answer we received on our survey was to the question "Have you ever received OSHA HAZCOM Training?" Of the 89 people who answered this question, 45 (51%) said YES and 44 (49%) said NO.

OSHA's Hazard Communication (Hazcom) Standard 29 CFR 1910.1200 applies to any work location where chemicals are used and requires training about the chemicals used (safe use, how to recognize leaks, safety data sheets, and labels; and of course training about the standard itself.

Our survey was shocking since it is a federal law that everyone who uses chemicals in the workplace be trained on the HazCom standard. The International Association of Healthcare Central Service Materiel Management (IAHCSMM) show is for primarily for people who work in sterile processing departments in healthcare. Additionally, all of the people included in this survey had identified the chemical used for low temperature sterilization and so presumably are working with or near potentially hazardous chemicals.

However, the percentage of people who have not had Hazcom training may be conservative. ChemDAQ's President & CEO, David Hilliker, frequently gives talks about the HazCom standard to people from hospital sterile processing departments and he estimated that about 80% audience members that he talked to individually have never had HazCom training. Our survey was voluntary and perhaps a disproportionate fraction of the 28 people who did not answer this question in the survey would have selected NO had they checked a box. For information about ChemDAQ's Hazcom training program contact Kevin Vaughn at kvaughn@chemdaq.com.

In 2009 the NIOSH-NORA State of the Sector Healthcare and Social Assistance report stated in the Executive Summary that

"The HCSA sector is burdened by the historical and entrenched belief that patient care issues supersede the personal safety and health of workers and that it is acceptable for HCSA workers to have less than optimal protections against the risks of hazardous exposures or injuries."

If our survey is representative across healthcare in the US, then it suggests that healthcare can make significant improvement in workplace safety, at least with respect to exposure to hazardous chemicals, by improving training and ensuring at a minimum that everyone has the training they are required to receive by law.