If your workplace contains biological or chemical agents with established exposure limits, you may be affected by amendments to O. Reg. 833: Control of Exposure to Biological or Chemical Agents.
A key amendment requires employers who provide respiratory protection to implement a respiratory protection program. For example, employers would have to 1) ensure that respiratory equipment is appropriate for the form and concentration of airborne substance 2) establish written measures and procedures regarding the selection, care and use of the equipment, and 3) instruct and train workers in the care, use and limitations of the equipment.
"This is an important change," says WSPS Occupational Hygienist Sara Lovell, "but remember that personal protective equipment sits last in the hierarchy of controls. Rely on it only if no other option is available."
Among other changes, the amendments also
- add substitution as a method employers must consider to protect workers from exposure. The measures now include, in order, substitution, engineering controls, administrative controls, hygiene facilities and practices, and personal protective equipment only as a last resort. "We will have a stronger system in place if we can protect workers without having to rely on them to protect themselves."
- add an option to use the "Quebec Model" for calculating exposure levels during irregular shifts. The model was developed by the University of Montreal and Institut de recherche Robert Sauvé en santé et en sécurité du travail (IRSST).
8 next steps
Sara offers these suggestions for workplaces that may be affected by the regulatory amendments.
- Review the changes to O. Reg. 833, Control of Exposure to Biological or Chemical Agents. If your workplace has designated substances, review the changes to O. Reg. 490/09, Designated Substances, as well.
- Understand what potential exposure hazards may exist in the workplace. "Once you know what chemical products are on site, how they interact with the work environment, and how they are being used," says Sara, "you are ready to identify hazards and further evaluate the risk in your workplace."
- Figure out who may be exposed. Don't overlook people working in the same area, and maintenance and other support staff. "The person who applies paint may not be the same person who cleans the paint lines."
- Determine what the actual exposure is. If you don't have anyone on staff with the qualifications to carry out an exposure assessment as set out in the amendments, bring in someone who does. "A qualified person ensures that you're collecting samples that provide the information you need. This person can interpret the results to help build an appropriate program."
- Think twice before conducting your own exposure testing. The regulatory amendments now allow the use of direct reading instruments, but do you know how to use the instruments properly? "If you set an instrument up in one corner of the room and exposure is taking place in another area, the readings won't reflect actual exposure," says Sara. "If you're evaluating airborne concentrations of gases and vapours, you need to understand how they interact with air, if they will rise or fall in the work environment."
- Consider what could happen in the event of an emergency, and how you need to respond. If a spill occurs, what are the risks? What would cleanup look like? Do you have the right materials to mitigate dust becoming airborne? Should cleanup staff be wearing a respirator when sweeping things up?
- Eliminate the need to wear a respirator through other controls. "Otherwise, you will be required to implement a complete respiratory protection program, even if you're just providing something as simple as an N95 respirator."
- Inform all affected employees of the hazards and controls in place.
How WSPS can help
"We can help from start to finish," says Sara. "Reviewing safety data sheets, performing air sampling, conducting exposure assessments, developing control programs, fit testing, training…" Find out more by chatting with our on-duty consultant, 1-877-494-WSPS (9777).
WSPS also offers a comprehensive selection of hazardous materials resources, including downloadable job aids, WHMIS training, and more.