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Occupational Health and Safety Act, 1993 (Act No. 85 of 1993)

Regulations

Hazardous Chemical Substances Regulations, 1995

Annexure 1

Applying Occupational Exposure Limits

 

 

GENERAL

 

18) The lists of occupational exposure limits given in Table 1 and Table 2 of Annexure 1, unless otherwise stated, relate to personal exposure to substances hazardous to health in the air of the workplace.

 

UNITS OF MEASUREMENT

 

19) In occupational exposure limits, concentrations of gases and vapours in air are usually expressed in parts per million (ppm), a measure of concentration by volume, as well as in milligrams per cubic metre of air (mg/m³), a measure of concentration by mass. In converting from ppm to mg/m³ a temperature of 25°C and an atmospheric pressure of 101.325 kPa are used. Concentrations of airborne particles (fume, dust, etc.) are usually expressed in mg/m³. In the case of dust, the limits in the tables refer to the total inhalable fraction unless specifically indicated as referring to the respirable fraction (see paragraph 36). In the case of a man-made mineral fibre, the limit is expressed as fibres per millilitre of air (fibres/ml).

 

OCCUPATIONAL EXPOSURE LIMITS - CONTROL LIMITS; CL 9TABLE 1)

 

20) An OEL-CL is the maximum concentration of an airborne substance, averaged over a reference period, to which employees may be exposed by inhalation under any circumstances, and is specified together with the appropriate reference period in Table 1 of Annexure 1.

 

21) Regulation 19(1) of the HCS Regulations, when read in conjunction with the Act, imposes a duty on the employer to take all reasonable precautions and to exercise all due diligence to ensure that exposure is kept as far below an OEL-CL as is reasonably practicable.

 

22) To comply with this duty, in the case of substances with a 8-hour reference period, employers should undertake a programme of monitoring in accordance with regulation 6 so that they can show (if it is the case), that an OEL-CL is not exceeded. Such a monitoring programme need not be undertaken if the assessment carried out in accordance with regulation 5 shows that the level of exposure is most unlikely ever to exceed an OEL-CL. For substances assigned a short-term limit, such value should never be exceeded.

 

23) The assessment should also be used to determine the extent to which it is reasonably practicable to reduce exposure further below an OEL-CL as required by regulation 10 (1) In assessing reasonable practicability, the nature of the risk presented by the substance in question should be weighed against the cost and the effort involved in taking measures to reduce the risk. (Also see the definition of reasonably practicable as defined in the Act.)

 

OCCUPATIONAL EXPOSURE LIMIT-RECOMMENDED LIMIT;OEL-RL (TABLE 2)

 

24) An OEL-RL is the concentration of an airborne substance, averaged over a reference period, at which, according to current knowledge, there is no evidence that it is likely to be injurious to employees if they are exposed by inhalation, day after day, to that concentration.

 

25) For a substance, which has been assigned an OEL-RL, exposure by inhalation should be reduced to that standard. However, if exposure by inhalation exceeds the OEL-RL, then control will still be deemed to be adequate provided that the employer has identified why the OEL-RL has been exceeded and is taking appropriate steps to comply with the OEL-RL as soon as reasonably practicable. In such a case, the employers objective must be to reduce exposure to the OEL-RL, but the final achievement of this objective may take some time. The assessment under regulation 5 will determine the urgency of the necessary action, taking into account the extent and cost of the required measures in relation to the nature and degree of exposure involved.

 

26) Control of an OEL-RL as prescribed in regulation 10 (1) (a) can always be regarded as adequate control of that substance for the purpose of the HCS Regulations, so far as exposure from inhalation is concerned. However, due to the variations in process control and the fluctuations in substance concentrations in the workplace, it will be prudent for employers to reduce exposure below an OEL-RL as to ensure that the exposure of all employees does not exceed that OEL-RL. Similarly, it is not intended that the statutory requirements under regulation 10 (1) should discourage the further application of good occupational hygiene principles in order to reduce exposure below the OEL-RL.

 

LONG-TERM AND SHORT-TERM EXPOSURE LIMITS

 

27) The pattern of effects due to exposure to substances hazardous to health varies considerably depending on the nature of the substance and the exposure. Some effects require prolonged or accumulated exposure. The long-term (8-hour time weighted average) exposure limit is intended to control such effects by restricting the total intake by inhalation over one or more workshifts. Other effects may be seen after brief exposures which have occurred once or repeatedly. Short-term limits (usually 15 minute) may be applied to such substances. Where long-term limits also apply, the short-term limits restrict the magnitude of excursion above the average concentration during longer exposures. For those substances for which no short-term limit is specified, it is recommended that a figure of three times the long-term limit be used as a guideline for controlling short-term excursions in exposure. With some other substances, brief exposure may be critical and the exposure limit necessary to prevent these excursions will also control any other effects. A separate long-term limit is not considered necessary in such cases and the short-term limit applies throughout the shift.

 

28) Exposure limits are expressed as airborne concentrations averaged over a specified period of time. The period for the long-term limit is normally eight hours. When a different period is used, this is stated. The averaging period for the short-term exposure limit is normally 15 minutes. Such a limit applies to any 15 minute period throughout the working shift.

 

LIMITATIONS TO THE APPLICATION OF EXPOSURE LIMITS

 

29) The exposure limits relate to personal exposure with the exception of the annual OEL-CL for vinyl chloride which should be recorded as the time-weighted average of vinyl chloride in the atmosphere of a working place over a period of one year (see Annexure 2 and the OEL-RL for cotton dust is not a personal exposure standard, but a static air standard (see Annexure 4).

 

30) The limits cannot readily be extrapolated to evaluate or control non-occupational exposure, e.g. levels of contamination in the neighbourhood close to an industrial plant. OELs only apply to persons at work. Employers should also take into account their duties under the Environmental Protection Act. The OELs are also only approved for use where the atmospheric pressure is between 85 kPa and 101.325 kPa. This covers the normal range of meteorological variations and slightly pressurised workplaces such as cleaning rooms, but not the higher pressures that may be encountered in, for example, tunnelling or underwater hyperbaric chambers. Such situations require special assessments.

 

31) Occupational exposure limits, as set out in Tables 1 and 2 of Annexure 1, are intended to be used for normal working conditions in workplaces. Employers should also take into account their duties and the provisions of the Environmental Conservation Act. OELs are not, however, designed to deal with serious accidents or emergencies, particularly where employees may be exposed to rapidly rising concentrations of gas, as may arise from a major escape due to plant failure. Over and above their responsibilities to ensure that the requirements of the HCS Regulations are met, employers also have a clear responsibility to ensure that the plant is designed, operated and maintained in a way that avoids accidents and emergencies. Where appropriate, detection, alarm and response measures should be used in order to minimise the effect of any such unplanned events.

 

32) To help maintain adequate operational control, employers may find it helpful to select their own indicators of control when undertaking investigations or corrective action.

 

EXPOSURE IN MINES

 

33) The HCS Regulations and the occupational exposure limits in this publication do not apply to exposure to substances hazardous to health in mines.

 

LEAD AND ASBESTOS

 

34) Work with asbestos or lead is not subject to the HCS Regulations. The exposure limits for various types of asbestos and lead are specified in the Asbestos Regulations and the Lead Regulations.

 

PESTICIDES

 

35) Substances used as active ingredients in pesticides are listed under their chemical names and/or their common (ISO) names. These names may sometimes be used as parts of the names of proprietary pesticide formulations. In all cases the exposure limit applies to the specific active ingredients and not to the formulation as a whole.

 

DUSTS

 

36) The general approach necessary to control occupational exposure to dusts is as follows: not all dusts have been assigned occupational exposure limits but the lack of such limits should not be taken to imply an absence of hazard. In the absence of a specific exposure limit for a particular dust, exposure should be adequately controlled. Where there is no indication of the need for a lower value, personal exposure should be kept below both 10 mg/m³ 8-hour time-weighted average total inhalable dust and 5 mg/m³ time-weighted average respirable dust. Such, or greater, dust concentrations should be taken as the substantial concentrations. A substantial concentration of dust should be taken as a concentration of 10 mg/m³, 8-hour time-weighted average, of respirable dust, where there is no indication of the need for a lower value, and as such they are referred to as substances hazardous to health

 

TOTAL INHALABLE DUST AND RESPIRABLE DUST

 

37) Total inhalable dust approximates to the fraction of airborne material that enters the nose and mouth during breathing and is therefore available for deposition in the respiratory tract. Respirable dust approximates to the fraction which penetrates to the gas exchange region of the lung. A fuller definition is given at the end of Table 2 of Annexure 1 (Abbreviations). (reproduced below)

 

The concentration of respirable dust shall be determined from the fraction passing a size selector with an efficiency that will allow:

i) 100% of particles of 1 mm aerodynamic diameter
ii) 50% of particles of 5 mm aerodynamic diameter
iii) 20% of particles of 6 mm aerodynamic diameter
iv) 0% of particles of 7 mm aerodynamic diameter and larger to pass through the size selector.

 

38) Where dusts contain components which have their own assigned occupational exposure limits, all the relevant limits should be complied with.

 

FUME

 

39) Where a separate OEL has been set for fume, it should normally be applied to solid particles generated by chemical reactions or condensed from the gaseous state, usually after volatilisation from melted substances. The generation of fume is often accompanied by a chemical reaction such as oxidation or thermal breakdown.

 

ABSORPTION THROUGH THE SKIN

 

40) In general, for most substances the main route of entry into the body is by inhalation. The OELs given in these regulations solely relate to exposure by this route. Certain substances such as phenol, aniline and certain pesticides (marked in the Tables with an SK notation) have the ability to penetrate the intact skin and thus become absorbed into the body. Absorption through the skin can result from localised contamination, for example, from a splash on the skin or clothing, or in certain cases from exposure to high atmospheric concentrations of vapour. Serious effects can result in little or no warning and it is necessary to take special precautions to prevent skin contact when handling these substances. Where the properties of the substances and the methods of use provide a potential exposure route via skin absorption, these factors should be taken into account in determining the adequacy of the control measures.

 

SENSITISERS

 

41) Certain substances may cause sensitisation of the respiratory tract if inhaled or skin contact occurs. Respiratory sensitisers can cause asthma, rhinitis, or extrinsic allergic alveolitis. Skin sensitisers cause allergic contact dermatitis. Substances which cause skin sensitations are not necessarily respiratory sensitisers or vice-versa. Only a proportion of the exposed population will become sensitised, and those who do become sensitised, will not have been identified in advance. Individuals who become sensitised may produce symptoms of ill health after exposure even to minute concentrations of the sensitiser.

 

42) Where it is reasonably practicable, exposure to sensitisers should be prevented. Where this cannot be achieved, exposure should be kept as low as is reasonably practicable and activities giving rise to short-term peak-concentrations should receive particular attention. As with other substances, the spread of contamination by sensitisers to other working areas should also be prevented, as far as is reasonably practicable.

 

43) The Sen notation (marked in the Tables with a Sen notation) has been assigned only to those sensitisers that may cause sensitisation by inhalation. Remember that other substances not contained in these Tables can act as respiratory sensitisers.

 

OTHER FACTORS

 

44) Working conditions which impose additional stress on the body, such as exposure to ultra-violet radiation, high temperatures, pressures and humidity, may increase the toxic response to a substance. In such cases, specialist advice may be necessary to evaluate the effect of these factors.