Risk Management – What do I need to do?
• Obligations of the Carcinogens and Mutagens Directive
• Question 2: How do I conduct an assessment of personal exposure to respirable crystalline silica?
– Personal Exposure Monitoring
– Occupational Exposure Limits
• General Prevention Principles
Since 2018, works involving exposure to respirable crystalline silica dust generated by a work process are included in the European Carcinogens and Mutagens at Work Directive (Directive 2017/2398). A European Binding Occupational Exposure Limit Value of 0.1 mg/m³ is set in Annex III for respirable crystalline silica dust.
The Directive recognises in its Recital 19 that NEPSI good practices are “valuable and necessary instruments to complement regulatory measures and in particular to support the effective implementation of limit values”.
This section integrates the obligations of the Carcinogens and Mutagens at Work Directive and provides recommendations on when and how to apply the advice given in this Good Practice Guide to their specific circumstances.
Using a simple question and answer format, it will introduce basic risk management techniques that should be applied to workplace situations where persons may be exposed to respirable crystalline silica.
OBLIGATIONS OF THE CARCINOGENS AND MUTAGENS DIRECTIVE
This Directive 2004/37/EC (and its amendments) aims at the protection of workers against risks to their health and safety arising or likely to arise from exposure to carcinogens or mutagens at work.
Its obligations include:
- Reduction and replacement: the employer shall reduce the use of a carcinogen or mutagen at the place of work, in particular by replacing it, in so far as is technically possible, by a substance, preparation or process which is not dangerous or is less dangerous.
- Use of closed systems: where the replacement is not technically possible the employer shall ensure that the carcinogen or mutagen is, in so far as is technically possible, manufactured and used in a closed system.
- Where a closed system is not technically possible, the employer shall ensure that the level of exposure of workers is reduced to as low a level as is technically possible. Exposure shall not exceed the limit value of a carcinogen as set out in Annex III.
- The employer shall also apply the following measures:
- Limitation of the RCS quantities at the place of work;
- Reducing the number of workers exposed or to be exposed to RCS
- Design of work processes and engineering control measures in order to avoid or minimise the release of RCS
- Evacuation of RCS at source, local extraction system or general ventilation
- Use of existing appropriate procedures for the measurement of RCS
- Application of suitable working procedures and methods
- Collective protection measures and/or individual protection measures
- Hygiene measures, in particular regular cleaning of floors, walls and other surfaces;
- Information for workers;
- Demarcation of risk areas and use of adequate warning and safety signs (e.g. “no smoking”)
- Plans to deal with emergencies in case of high exposure
- Means for safe storage, handling and transportation, in particular by using sealed and clearly and visibly labelled containers;
- Means for safe collection, storage and disposal of waste by workers, including the use of sealed and clearly and visibly labelled containers.
The specific advice given here will help the reader to decide to what extent this Good Practice Guide applies to their circumstances.
Guidance will be given on:
How to assess whether there is a significant risk from exposure to respirable crystalline silica.
How to decide what type of control and prevention measures should be put in place to treat the risks that are identified – i.e. to eliminate them, or to reduce them to an acceptable level.
How to monitor the effectiveness of the control measures in place. How to monitor workers’ health.
What information, instruction and training should be provided to the workforce in order to educate them about the risks to which they may be exposed.
The risk management processes of Assessment, Control, Monitoring and Education make up the foundation of all European health and safety legislation, including the European Carcinogens and Mutagens at Work Directive.
Question 1:
How do I determine whether people are exposed to respirable crystalline silica in my workplace?
Answer
Respirable crystalline silica enters the body when dust containing a proportion of crystalline silica is inhaled. When the particle size range of the dust is sufficiently small (such that the particles fall within the respirable fraction), the dust will travel deep into the lungs. It is at this point that respirable crystalline silica can cause health effects. Occupational exposure to respirable crystalline silica can occur in any workplace situation where airborne dust is generated, which contains a proportion of respirable crystalline silica. Occupational exposure to respirable crystalline silica occurs in many industries.
Use the simple flow chart below to carry out an initial assessment to determine whether there is any significant risk of exposure to respirable crystalline silica. The possible presence of fine particles of crystalline silica means that there may be a risk. If there is no foreseeable risk, then you don’t need to take any specific measures. However, you should always obey the general principles of prevention.
Figure: Initial assessment procedure.
Question 2:
How do I conduct an assessment of personal exposure to respirable crystalline silica?
Answer
Use this simple flow chart to help you to carry out your assessment of personal exposure levels. It’s a good idea at this stage to make detailed notes of the dust control measures that are already in place in your workplace. You will need this information later, in order to assess whether you are complying with the general principles of prevention.
Figure: Assessment of personal exposure levels to respirable crystalline silica.
PERSONAL EXPOSURE MONITORING
The only way to quantify the amount of respirable crystalline silica present in the workplace atmosphere is to perform sampling of the air and analysis of the dust collected. Occupational exposure assessment is the process of measuring or estimating the intensity, frequency and duration of human contact with such contaminants.
There are two types of measurements commonly used:
• Personal;
• Static
Both types of measurement can be used jointly as they are complementary.
It is up to the experts designated by the employers and the employees’ representatives to opt for the most adequate solutions, while respecting the national and European provisions.
General requirements for dust monitoring (taken from the European Standards EN 689 and EN 1232) are provided in the “Dust Monitoring Protocol”, Annex 2 of the Agreement on Workers Health Protection through the Good Handling and Use of Crystalline Silica and Products Containing it. Producers and end users of products and raw materials containing crystalline silica are encouraged to adopt this protocol.
Advice on organising a dust-monitoring programme can be sought from a competent occupational hygienist.
OCCUPATIONAL EXPOSURE LIMITS
An occupational exposure limit value represents the maximum time-weighted average concentration of an airborne contaminant to which a worker can be exposed, measured in relation to a specified reference period, normally eight hours.
Currently there are many different types of occupational exposure limit value, defined by individual Member States of the European Union. These limits are all different and, in addition, cannot be compared directly.
In 2018, works involving exposure to respirable crystalline silica dust generated by a work process were included in Annex I of the European Carcinogens and Mutagens at Work Directive (Directive 2017/2398). A European Binding Occupational Exposure Limit Value of 0.1 mg/m³ is set in Annex III for respirable crystalline silica dust.
Question 3:
I have done my exposure assessment, but I’m not sure how to interpret the results. What do I need to do now?
Answer
You need to compare the results of your assessment against the occupational exposure limit for respirable crystalline silica that applies in your country and you need to check that you are complying with the general principles of prevention.
It may be necessary for you to implement additional control measures (following the general principles of prevention), and in the case carcinogenic processes are identified following the CMD obligations, to eliminate, or reduce, exposure to respirable crystalline silica so that you meet the relevant occupational exposure limit.
In any case, you will need to provide training to your workforce on the risks to their health, which may arise from exposure to respirable crystalline silica and how to use the control measures provided.
The following flow chart will guide you through the process.
GENERAL PREVENTION PRINCIPLES
In the development of this Good Practices guide, the authors respected the prevention strategy, which is described in Council Directive 89/391/EEC and in its transposition in the national laws, and the measures of the CMD 2017/2398 whenever carcinogenic processes are identified.
Nine prevention principles are described and one must consider the following hierarchy in the preventive measures to be taken:
- avoiding risks
- evaluating the risks which cannot be avoided
- combating the risks at source
- adapting the work to the individual
- adapting to technical progress
- replacing the dangerous by the non dangerous or the less dangerous
- developing a coherent overall prevention policy (including the provision of health surveillance of workers)
- giving collective protective measures priority over individual protective measures
- giving appropriate information, instruction and training to the workers
In the context where crystalline silica is handled in the workplace, examples of practical applications of the above principles are:
- Substitution: taking into account economic, technical and scientific criteria, replace a dust-generating process with a process generating less dust (e.g. use of a wet process instead of a dry process, or an automated process instead of a manual process).
- Provision of engineering controls: de-dusting systems (dust suppression¹, collection² and containment³) and isolation techniques⁴ .
- Good housekeeping practices.
- Work pattern: establish safe working procedures, job rotation.
- Personal protective equipment: provide protective clothing and respiratory protective equipment.
- Education: provide adequate health and safety training to the workers, information and instructions specific to their workstation or job.
Compliance with Member State Occupational Exposure Limits is just one part of the Risk Management process. You should additionally always ensure that you comply with the General Principles of Prevention, as defined in Council Directive 89/391/EEC and the measures of the CMD 2017/2398 whenever release of carcinogens by a work process into the place of work is identified.
TRAINING FOR THE WORKERS
One of the task guidance sheets in the task manual part of this guide gives detailed guidance on the format and content of training, which should be provided to workers to inform them of the risks to their health that may arise from the handling and use of substances containing crystalline silica.
RISK MANAGEMENT – SUMMARY
The following diagram summarises the risk management process, from the perspective of both employer and employee, when applied to control of respirable crystalline silica.
The health and safety systems implemented in the companies must be respected by both employer and employee.
