David K. N. Leong*, Ph.D., P.Eng., CIH, ROH, C. Chem. Provincial Hygienist, Ontario Ministry of Labour 505 University Av

1. Ontario Ministry of Labour’s Occupational Hygiene Initiatives, Strategies and ProgramsFall Symposium, Occupational Hygiene Association of Ontario (Toronto, Ontario) David K. N. Leong*, Ph.D., P.Eng., CIH, ROH, C. Chem. Provincial Hygienist, Ontario Ministry of Labour 505 University Avenue, 20th Floor Toronto, Ontario M7A 1T7 Tel: (416) 326-1431; Fax: (416) 326-7761 *Chair, ACGIH Air Sampling Instruments Committee

2. Presentation • Key MOL Occupational Hygiene Initiatives • Regulation Updates • Enforcement Strategies • Targeted Substances • GHS Implementation

3. Key MOL Occupational Hygiene Initiatives Increased Occupational Hygiene Interventions in workplaces through: • Regulation Development/amendments • Enforcement of Regulations, Occupational Exposure Limits (OELs), and Federal/Provincial WHMIS Legislation • Inspections and Investigations

4. Key MOL Occupational Hygiene Initiatives (Cont’d) • Industrywide Air Quality Surveys • Supporting other MOL initiatives • Collaborating with Federal, Provincial and Territorial agencies on GHS implementation • Participation in consensus standards development

5. Goals for MOL Occupational Hygiene Initiatives • Identification and assessment of risk factors contributing to occupational diseases and illnesses • Compliance with regulation requirements and OELs • Better protection of workers from the risks of exposures to hazardous substances and noise • Prevention of occupational diseases and illnesses through collaboration with Ontario Health and Safety System partners

6. Key Revisions and New Requirements for Noise in Amended Regulations • Noise requirements amended in Regulations 851 for Industrial Establishments (Section 139) and Regulation 855 for Oil and Gas-Offshore (Section 41) • Amendments effective July 1, 2007 • Revised noise limit expressed as “equivalent sound pressure level” • No exposure greater than equivalent sound pressure level of 85 dBA over 8-hour shift, based on 3 dB exchange rate

7. Key Revisions and New Requirements for Noise … (Cont’d) • All reasonably necessary protective measures to be taken • Posting warning signs at every approach to work area where sound level regularly exceeds 85 dBA • Ministry’s Guideline released on May 29, 2007 • Duty for employer in other sectors to take every reasonable precaution to protect workers from noise hazard under section 25(2)(h) of OHSA • Noise prevention guideline being drafted by OSHCO working group

8. OEL Development, Revisions & Updates • Permanent process followed for adopting revised and new OELs in Regulation 833 and DSRs • Proposals based on adopted ACGIH TLVs announced annually since 2004 • Regulation 833 and DSRs amended following consultation period and Ministry’s decision

9. OELs Development, Revisions & Updates (Cont’d) • Latest proposal announced on July 23, 2007 including: • Proposed OELs for 6 new substances • Proposed revised OELs for 13 substances • Proposed withdrawals of OELs for 2 substances • Stakeholders’ comments to be submitted by September 28, 2007

10. OELs Development, Revisions & Updates (Cont’d) • Stakeholders encouraged to nominate substance without TLV for OEL development, and include proposed OEL and supporting documentation • OEL revisions made in 1994, 2000, 2005 and 2007 • Revised and new OELs for 349 substances adopted in regulations since 1994

11. Particulate Size-Selective OELs, Criteria and Sampling • OELs set on specific size range of particulates and aerosols • Inhalable • Thoracic • Respirable • Internationally harmonized size-selective criteria adopted for setting OELs • Same criteria to be met by size-selective devices used for sampling specific size range

12. Size-Selective Devices for Thoracic Particulate Sampling • 50% cut-point of 10 microns and matching the thoracic size criteria • BGI Thoracic Cyclone, GK 2.69, referenced in NIOSH Method 5524 for sampling of metalworking fluid • Flowrate set at 1.6 Lpm when using BGI G2.69 Cyclone for sampling thoracic particulate

13. Size-Selective Devices for Thoracic Particulate Sampling (Cont’d) • Stainless steel model available for sulphuric acid sampling • BGI G2.69 Cyclone used for respirable particulate sampling at 4.2 Lpm • SKC Parallel Particle Impactor also available for thoracic particulate sampling at 2 L/min.

14. Size-Selective Devices for Respirable Particulate Sampling • 50% cut-point of 4 microns and matching the respirable size criteria • Various types of cyclones and flow rates specified in NIOSH Method 0600: • MSA 10 mm Dorr-Oliver Nylon Cyclone, 1.7 L/min • BGI Higgins-Dewell (HD) Cyclone, 2.2 L/min • SKC Aluminum Cyclone, 2.5 L/min • Other cyclones are commercially available • Advantages for using cyclone operating at higher flow rate

15. Size-Selective Devices for Inhalable Particulate Sampling • 50% cut-point of 100 microns and matching the inhalable size criteria • Various types of inhalable particulate samplers and flow rates specified in HSE Method MDHS 14/3: • IOM Sampler, 2 L/min • Multi-orifice (or 7-hole) sampler, 2 L/min • Conical Inhalable Sampler (CIS), 3.5 L/min

16. Size-Selective Devices for Inhalable Particulate Sampling (Cont’d) • IOM samplers available from SKC: • Plastic Model • Stainless Steel Model • SKC Button Aerosol Sampler, operating at 4 L/min with porous curved-surface sampling head

17. Particulate Size-Selective Sampling for Three Size Ranges • All three sizes of particulate can be determined simultaneously by a TSI Respicon Particle Sampler, operating at 3.11 L/min • Direct-reading instrument such as SKC HAZ-Dust IV Aerosol Monitor for measuring the concentrations of inhalable, thoracic or respirable particulate individually.

18. Inhalable vs “Total” Particulate • “Total” particulate referred to particulate sampled onto 37 mm filter loaded into cassette • Inhalable and “total” particulate concentrations about the same for smoke, fumes, and fine particles • Inhalable particulate concentrations usually greater by 1.2 to >3 times than “total” particulate concentrations for larger particles • “Total” referred to total analysis by gravimetric method, nothing to do with particle size

19. Key Requirements for Compliance in Regulation 833 • All reasonable measures to be taken to protect workers from exposure to hazardous chemical or biological agent (section 3(1) & (2)) • OELs not to be exceeded in the exposure of workers (Section 4)

20. Key Requirements for Compliance in Designated Substance Regulations • All necessary measures to be taken to ensure compliance with OELs • Written assessment of the exposure, or likelihood of exposure • Development and implementation of control program • Following fully validated standard methods or Measurement Codes for determining the concentrations of designated substance in air

21. Key Requirements for Compliance in Designated Substance … (Cont’d) • Standard methods refer to those methods published by agencies such as NIOSH, OSHA, HSE, ASTM or ISO • Following Respirator Code or NIOSH Respirator Selection Logic 2004 for respirator selection and other guidance, where respiratory protection is allowed

22. Diffusive Samplers • Performance standards available in: • ANSI/ISE 104-1998 (R2000), workplace • ASTM D6246-02, workplace • EN 838:1995, workplace • EN 14412:2004, IAQ • ISO 16107:1999, workplace • EN 13528-1:2002, EN 13528-2:2002 & EN 13528-3:2003, Ambient Air • OSHA & NIOSH protocols available for laboratory evaluation and testing

23. Diffusive Samplers (Cont’d) • Sampling rate variation (SRV) determined by OSHA for each brand and type of commercially available sampler • SRVs used to calculate the sampling and analytical errors (SAEs) in OSHA validated methods • Use of diffusive samplers included in fully validated standard methods for some substances

24. Diffusive Samplers (Cont’d) • Manufacturers’ validation reports also available • AIHA diffusive sampler PAT programs available • Advantages in using diffusive samplers for full-shift TWA sampling and IAQ investigations • Increased use of diffusive samplers and better acceptance by government agencies will help make gas and vapour sampling a more common practice in workplaces

25. Role of Ministry’s Field Hygienists • Responsible for occupational hygiene interventions in workplaces; identifying evaluating and assessing exposures • Enforcement of DSRs, Regulation 278/05 for asbestos in construction, regulations for confined space, Reg. 833/90, Noise, WHMIS Legislation (both Federal and Provincial) and Sector Regulations

26. Role of Ministry’s Field Hygienists (Cont’d) • Issuance of Orders for compliance • Investigations of events and referrals of federal WHMIS issues from other provinces and territories • Targeting substances and related work operations for inspections and industrywide air quality surveys to enforce OELs • Communicating the hazards, risks and exposure potentials to workplace parties

27. MOL Hygiene Resources

28. Hazardous Substances Enforcement Strategy • DSRs, Regulation 833/90 and WHMIS Regulation 860 are enforced all together when inspecting a workplace where hazardous chemicals are used, handled or stored • Compliance with the federal WHMIS legislation will also be enforced when the WHMIS issues are related to importers, suppliers and distributors

29. Hazardous Substances Enforcement Strategy (Cont’d) • Inspections and industrywide air quality surveys will continue to focus on substances with: • New and revised OELs in effect as of September 30, 2000 • Potentials as occupational carcinogens, reproductive toxins or sensitizers, or • Newly recognized health effects

30. Hazardous Substances Enforcement Strategy (Cont’d) • Orders may be issued for: • Conducting re-assessment of the risks of exposures to designated substance(s) • Upgrading control programs related to designated substance(s) • Updating or upgrading labels, MSDSs and training to meet WHMIS requirements

31. Hazardous Substances Enforcement Strategy (Cont’d) • Submitting compliance plan(s) for meeting Regulation 833/90 requirements, and/or • Testing if quick fixes are not possible and the risks are unknown

32. Noise Enforcement Strategy • Noise-generated processes, operations, devices and tools, control measures, work practices will be inspected and the available noise data will be reviewed • Focusing on industrial workplaces in the following sectors: • Automotive • Chemical, Rubber and Plastics • Industrial Services • Primary Metals • Textile and Printing, or • Wood and Metal Fabrication

33. Noise Enforcement Strategy (Cont’d) • Noise assessment will be carried out with integrating SLM and employer may be ordered to comply with the revised noise exposure limit • In workplaces where workers are exposed to both noise and ototoxic chemicals • Employers and workers will be informed of the higher risk of hearing loss • Employers will be advised to take additional precautionary measures to protect their workers from exposures to both noise and ototoxic chemicals

34. Examples of Substances Targeted for Inspections & Industrywide Air Quality Surveys • Respirable silica in granite and marble shops • Manganese and other metals (chromium, nickel, cadmium, etc.) in welding operations • 1, 3, 5-Triglycidyl-s-triazinetrione or Triglycidyl Isocyanurate (TGIC) in the use of powder coating paints • Wood dust in woodworking shops

35. Examples of Substances Targeted for Inspections & Industrywide Air Quality Surveys (Cont’d) • Methylene chloride in furniture refinishing • Metalworking fluids in machining and metal-finishing operations • Toluene and other volatile organics in solvents used across various industries • Formaldehyde and Glutaraldehyde in health care facilities

36. Examples of Substances Targeted for Inspections & Industrywide Air Quality Surveys (Cont’d) • Hexavalent Chromium in plating operations • Styrene in plastic manufacturing, boat building facilities, and fibreglass lay-up shops • Isocyanates in polyurethane production facilities and automotive spray painting

37. Effectiveness of MOL Interventions Through Industrywide Air Quality Surveys • Silica Exposures in Granite Shop • MWF Exposures in Tool-Machining Shop • Synthetic Graphite Exposures in Graphite Powder Production Facility

38. Silica Exposures in Granite Shop • Survey on Feb. 14, 2006 • 0.06 to 0.39 mg/m3 for resprirable quartz (3 of 4 samples above 0.1 mg/m3) • ND to 0.08 mg/m3 for respirable cristobolite, 2 samples above 0.05 mg/m3 • Orders issued for exposure reduction and interim PPE • Control measures implemented included: • Wet cutting • Dry grinding minimized • Rotating Dusty Assignments

39. Silica Exposures in Granite Shop (Cont’d) • Follow-up survey on July 26, 2007 • 0.01 to 0.06 mg/m3 for respirable quartz • ND to 0.03 mg/m3 for respirable cristobalite

40. MWF Exposures in Tool-Machining Shop • Survey conducted on Feb. 9, 2006 • 0.5 to 1.4 mg/m3 for MWF • 7 of 8 samples above 0.5 mg/m3 • Orders issued for exposure reduction and interim PPE • Control measures implemented included • Minimizing compressed air cleaning • Upgrading work practices • Follow-up survey on November 14, 2006 • 0.2 to 0.6 mg/m3 • 2 of 8 samples above 0.5 mg/m3

41. Synthetic Graphite Exposures in Graphite Powder Production Facility • Survey on March 4, 2004 • 1.2 to 5.0 mg/m3 for personal exposures (1 of 3 samples above 2 mg/m3) • 0.44 to 0.91 mg/m3 for area sampling results (3 samples) • Orders issued for reducing exposure of powder production operator • Control measures implemented included • Repairing dust collection system • Eliminating small package bagging • Upgraded housekeeping

42. Synthetic Graphite Exposures in Graphite Powder Productivity Facility (Cont’d) • Follow-up survey on Aug. 1, 2006 • Personal exposure reduced to 0.22 mg/m3 • 0.18 to 0.22 mg/m3 for area sampling results (5 samples)

43. Globally Harmonized System (GHS) of Classification and Labeling of Chemicals • GHS is the internationally harmonized system for defining and classifying hazards, and communicating information of hazards on labels and safety data sheets consistently, lessening the barriers to trade • Endorsed at UN Meeting in 2002 for implementation in each nation by a date suggested to be no later than December 31, 2008

44. Globally Harmonized System (GHS) of Classification and Labeling of Chemicals (Cont’d) • GHS classification criteria • Health and Environmental Hazards • Physical Hazards • Canada is working towards GHS implementation for: Health Canada • Workplace Chemicals (WHMIS) • Consumer Chemical Products • Pest Control Products Transport Canada • Transportation of Dangerous Goods

45. Objectives of GHS Implementation in Canada • Harmonization to the greatest extent possible between the sectors • Harmonization to the greatest extent possible among the NAFTA countries

46. Status of GHS Implementation in Canada Situation analysis completed in August 2003 • Comparing classification criteria in existing systems with GHS • Identifying implementation issues for discussion Multi-Stakeholder working groups established • Sectoral working groups, including the WHMIS Current Issues Committee (CIC) • Ad hoc expert groups on • Environmental Hazard Classification/Labeling • Chronic Hazards for Consumer Chemicals • GHS General Issues Committee (GIC)

47. Status of GHS Implementation in Canada (Cont’d) • Interim recommendations in each sector being developed through technical consultations with sectoral working group, and possibly re-visited for harmonization among NAFTA countries

48. Next Steps Regarding GHS Implementation in Canada • Consultation on Implementation Phase-in Options • Consultation with Trading Partners • Economic Analysis • Development of Final Recommendations for • Decision Making (Minister of Health) • Drafting Regulations • Federal Regulatory Process • Phasing in Implementation

49. GHS Impacts on WHMIS • Changes to WHMIS classification criteria • Changes to label elements: • Hazard symbols • Signal words • Hazard statements • WHMIS hatched border • Changes to MSDSs • From 9 to 16 headings

50. GHS/WHMIS Harmonization Process • Health Canada (HC) • Harmonization of Federal WHMIS legislation (HPA/CPR, IDL, HMIRC, HMIRR) with GHS • Canadian Association of Administrators of Labour Legislation (CAALL) • Harmonization of Canada Labour Code and provincial/territorial WHMIS regulations with GHS