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Evaluation of the Control Banding Method—Comparison with Measurement-Based Comprehensive Risk Assessment

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Evaluation of the Control Banding Method—Comparison with Measurement-Based Comprehensive Risk Assessment Journal of J Occup Health 2007; 49: 482–492 Occupational Health Evaluation of the Control Banding Method—Comparison with Measurement-based Comprehensive Risk Assessment Haruo HASHIMOTO1, Toshiaki GOTO1, Nobutoyo NAKACHI1, Hidetaka SUZUKI1, Toru TAKEBAYASHI2, Shigeyuki KAJIKI3 and Koji MORI3 1Medicine and Occupational Health, ExxonMobil Yugen Kaisha, 2Department of Preventive Medicine and Public Health, School of Medicine, Keio University and 3Occupational Health Training Center, University of Occupational and Environmental Health, Japan Abstract: Evaluation of the Control Banding workplace safety by compensating for its insufficient Method—Comparison with Measurement-based exposure information with safe-sided judgment criteria Comprehensive Risk Assessment: Haruo and by requiring experts’ intervention in high-risk cases. HASHIMOTO, et al. Medicine and Occupational Health, Control banding could be widely and effectively utilized ExxonMobil Yugen Kaisha—The control banding in Japan, especially by employers in small enterprises, method, or “control banding”, is a simplified risk provided that the above characteristics are pre- assessment system for chemical handling tasks. This acknowledged and health experts are made available. system is supposed to provide assessment results of To this aim, it is essential to develop new local health reasonable quality without expert involvement. The experts and establish institutional mechanisms for objective of this study was to evaluate the facilitating employers’ access to expert advice. It should appropriateness of control banding judgment on the however be noted that the number of workplaces basis of workplace safety. A common approach for evaluated in this study was small. assessing workplace risk, which is called (J Occup Health 2007; 49: 482–492) “comprehensive risk assessment” in this study, is to measure workers’ exposure and compare it with Key words: Control banding, COSHH Essentials, Risk relevant occupational exposure limits. Risk assessment, Exposure, Chemicals, Hazard, Control, assessment was performed with control banding Small enterprises, Expert (COSHH Essentials, UK) at 12 workplaces of a petroleum company in Japan, where health risks had It has been reported that the number of chemicals already been assessed separately through currently used in Japan is more than fifty thousand. This comprehensive risk assessment by experts and control makes the appropriate control of the health risks of these technologies implemented accordingly. The obtained chemicals a current occupational health issue1). While control banding judgments were then examined with occupational health control of chemicals in Japan has been regard to their adequacy by comparing them with existing control technologies. There was majority of performed according to the Industrial Safety and Health cases (seven) where judgments by control banding Law, which defines specific requirements for workplaces, were identified as “over-controlled”; there was no employers are supposed to autonomously perform risk judgments identified as “under-controlled”. Control assessment and management of chemicals that are not banding also requested the seeking of expert advice specified in regulatory clauses, since the number of in the majority of cases (eight). Thus, it was chemicals regulated by the law is limited. With this demonstrated that control banding tends to provide background, the Ministry of Health, Labour and Welfare, safe-sided judgment. A possible interpretation of this Japan, promulgated the “Guideline for risk assessment is that control banding is inherently designed to secure of chemicals and other hazards” in March 2006, which recommends employers to perform risk assessments for all chemicals used by them and to take risk mitigation Received Jun 28, 2007; Accepted Aug 13, 2007 2) Correspondence to: H. Hashimoto, Medicine and Occupational measures as needed . Health, ExxonMobil Yugen Kaisha, 1–8–15 Kohnan, Minato-Ku, In order to perform an accurate risk assessment of a Tokyo 108-8005, Japan workplace, collection of detailed hazard information and (e-mail: [email protected]) measurements of workers’exposure are commonly Haruo HASHIMOTO, et al.: Evaluation of the Control Banding Method 483 required, and a health expert who has sufficient company in Japan, were assessed with control banding knowledge of chemicals management is usually needed (COSHH Essentials) available on the HSE website6). The to perform them. However, there are often cases where details of each task, its process, duration, the chemical an expert is not readily available, especially among small handled and its amount, are shown in Table 1. and medium enterprises. Thus, a simple risk assessment Characteristics of each task relevant to control banding method is required which does not require expert assessment, such as the chemical species assessed, its involvement. Risk-phrases (R-phrases) and hazard group, scale of use, The control banding method, or “control banding”, is and ability to become airborne, are shown in Table 2. R- a risk assessment system for chemical handling tasks phrases corresponding to a chemical were identified which was originally developed by the HSE (Health and through the chemicals database carried on the homepage Safety Executive, UK) and is now being globally of the European Chemicals Bureau7). When the handled promoted by the ILO (International Labour Organization). chemical was a mixture of multiple chemical species, R- Control banding recommends necessary control phrases assigned to that mixture (example: gasoline) were technologies based on only three characteristics of a used for assessment, and R-phrases assigned to chemical handled: these are “hazard of the chemical”, components of the mixture (example: benzene) were not “scale of use”, and “ability to become airborne”3). Since used. This is because it was assumed that it would not control banding is designed to follow a standardized necessarily be easy for small and medium enterprises, process without direct exposure monitoring, this method the chief target employers of control banding, to obtain is supposed to provide assessment results with reasonable specific information regarding components of a chemical quality under circumstances in which an expert is not mixture. However, the chemical species assessed for task available. Several published studies have investigated # 4 was selected as benzene, and not petroleum products, the appropriateness of risk assessment judgments of since it was well known by workers that the petroleum control banding. These studies have attempted to validate products handled in this task contained appreciable the two exposure models on which the risk decision amounts of benzene (1 to 5%). For respective tasks, the scheme of control banding is grounded3–5). It was partially set of above information was input into control banding demonstrated that control banding tends to provide online interface, and then one of the four risk levels— appropriate or safe-sided (over-controlled) judgment in the “control approach criteria” which range from level 1 general. However, the results of these studies are (lowest risk) to level 4 (highest risk)—was judged and insufficient to draw an overall conclusion regarding the presented (Table 2). appropriateness of control banding for workplace safety, because the actual exposures of workplaces controlled in Comprehensive risk assessment accordance with control banding judgment were not The following risk assessments and managements were directly compared with the relevant occupational performed by workplace health experts (a Certified exposure limits. Industrial Hygienist of U.S.A. or equivalent) with more Occupational exposure limits have been common than several years of experience. A series of assessment judgment criteria for workplace safety. In order to steps was used for this risk assessment. First, personal accomplish accurate risk assessment of chemical handling exposure monitoring was performed regarding the most tasks, it is usually considered as a standard approach to hazardous or most representative component of the evaluate the exposure level and to compare it with chemical handled. The monitored chemical species were occupational exposure limit of the chemical; this approach benzene, lubricating oil (monitored as total hydrocarbons) will hereafter be called “comprehensive risk assessment” and n-heptane (Table 1). The exposure monitoring was in this study. In this study, risk assessment was performed carried out with passive samplers (Traceair OVM-1 from with control banding at workplaces where health risk had K&M Environmental Co.) which were then analyzed at already been assessed separately by experienced experts the ExxonMobil Biomedical Sciences Inc. (New Jersey, through comprehensive exposure assessment and control U.S.A.) which is an AIHA (American Industrial Hygiene technologies had been implemented, as needed, Association) accredited industrial hygiene laboratory8). accordingly. Then, the appropriateness of control banding Second, a set of “exposure rating” was defined, in order was examined by comparing the obtained control banding to classify the degree of exposure for workers. This is judgment with the already existing controls. shown in Table 3: there are five levels of exposure rating from A (highest exposure) to E (lowest exposure) which Methods are based on the relative relationship between the Control banding magnitude of exposure and the corresponding The
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