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David K. N. Leong*, Ph.D., P.Eng., CIH, ROH, C. Chem.

Ontario Ministry of Labour’s Occupational Hygiene Initiatives, Strategies and Programs Fall 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

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David K. N. Leong*, Ph.D., P.Eng., CIH, ROH, C. Chem.

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  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

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