CP Chief Executives and Board of Director's WSH Duties

 

1.1 Scope

1.1.1 This Code of Practice aims to provide clarity on and strengthen ownership of companies’ Chief Executives’and Board of Directors’ (henceforth termed as “Company Directors”) workplace safety and health (WSH) roles and duties. Company Directors include the Chief Executive or equivalent officer involved in executive decisions as well as activities on policy and decision-making related to the business affairs of the company, which are capable of affecting the company as a whole or a substantial part of it. This is regardless of their title and whether he or she is a member of the entity’s Board of Directors.

1.2 Purpose

1.2.1 Company Directors set the safety culture of their organisations. Their influence and control over their workplace resources and priorities ultimately drive WSH practices at workplaces.

1.2.2 The Workplace Safety and Health Act (WSH Act) section 48(1) already holds all Company Directors liable in ensuring their workers’ safety and health. Under section 48(1)(b) of the WSH Act, they are also responsible for proving that they had exercised due diligence to prevent workplace incidents. This Code of Practice outlines the desired outcomes in organisational systems and culture that Company Directors should seek to achieve in order to comply with section 48(1) of the WSH Act, and lists examples of reasonably practicable steps that Company Directors can take to realise the desired organisational WSH systems and culture.

1.2.3 There are three key points to note about this Code of Practice:

1.2.3.1 Fulfilment of WSH Act obligations

By adopting the principles and measures in the Code of Practice, the Company Directors would be better placed to be considered to have taken reasonably practicable measures to uphold their workers’ safety and health. Compliance with the Code of Practice could be used as a mitigating factor for the Court’s consideration in the event of an organisation’s WSH Act offence. Compliance with the Code of Practice means fulfilling the four principles listed in the Code of Practice. An organisation can fulfil the Code of Practice’s principles by effectively implementing the specific measures suggested in the Code of Practice; more measures implemented will likely result in fulfilling each principle to a greater extent. However, compliance with the Code of Practice, in and of itself, does not equate to due diligence. The Court will assess the degree of diligence that the Company Directors have exercised, having regard to the nature of their functions and to all the circumstances related to the commission of the offence.

1.2.3.2 Relevance to all organisations

The Code of Practice is relevant for all Company Directors, regardless of industry and organisation size.Under the WSH Act, all Company Directors must demonstrate that they have exercised a reasonable degree of due diligence to prevent WSH lapses in their organisations. As such, they should adopt and adapt the recommended practices that best suit the nature of work in their sector and organisation.

1.2.3.3 Calibration of measures in the Code of Practice

Company Directors should calibrate the measures cited in the Code of Practice based on the relevance to their organisations, including industry type and nature of exposure to risks and hazards. There is no one-size-fits-all solution that meets the different needs of every organisation, and the measures listed within the Code of Practice are not intended to be exhaustive. An organisation can still comply with the Code of Practice by implementing other measures in place of those listed here if it can demonstrate how these other measures can also fulfil the four principles.

1.2.4 Workers and managers are also encouraged to know and understand what is expected of the Company Directors who lead their organisations.

2. Principles and Measures

2.1 General

2.1.1 This section describes how the Company Directors can demonstrate leadership in improving WSH performance and management, based on the following principles and measures

2.2 Principle 1: Ensure WSH is integrated into business decisions and have clarity of roles and responsibilities of Chief Executive and individual members of the Board of Directors in leading WSH

2.2.1 Company Directors should set the WSH standards for the organisation. They should identify the individual Company Director(s) to be accountable for the relevant Code of Practice measures or any other WSH related measures the Board adopts, given the diverse range of measures and differing responsibilities and expertise among the Company Directors. In particular, the specific roles of the relevant individual Company Director(s) should be spelt out clearly (e.g. Chief Executive vis-à-vis the individual members of the Board of Directors, and executive directors vis-à-vis non-executive directors).

2.2.2 Measure 1: Assign and document WSH roles and responsibilities of individual Company Director(s). Appointed Company Director(s) should provide WSH oversight, and their roles and responsibilities should be clearly specified and documented. Company Directors should ensure that this document is readily available organisation-wide (e.g. via emails and townhalls), to provide clarity on the WSH duties of individual Company Director(s).

2.2.3 Measure 2: Establish the WSH policy, standards and strategic goals for the organisation. Company Directors or the relevant individual Company Director(s) should set highly effective WSH standards to ensure the safety and health of all their workers and develop strategies and initiatives to achieve these standards. In particular, WSH considerations should be classified as important and non-negotiable decisions.

2.3 Principle 2: Continuously build a strong WSH culture, set the tone and demonstrate visible leadership in embodying and communicating highly effective WSH standards

2.3.1 Company Directors should communicate and demonstrate that WSH is a priority at their workplace. Communication and actions should signal a visible and active commitment from the Company Directors. This includes publishing the organisation’s WSH commitment, reviewing and tracking WSH targets and performance, allocating sufficient resources for WSH, promoting WSH proactively, and having the necessary knowledge on WSH.

2.3.2 Measure 3: Publish the organisation’s WSH commitment, and review, endorse and track the organisation’s WSH targets and performance regularly.

Company Directors should publish their organisation’s WSH commitment annually via their sustainability report, organisation’s website and/or other means. Minimally, this information should be made available within their organisation and to their workers. They should also review, endorse and track their organisation’s WSH targets and performance regularly, such as via performance indicators.

2.3.3 Measure 4: Set WSH as a regular agenda item in management/board meetings. Company Directors should seek to be briefed on and have discussions around WSH-related topics such as:

• WSH Developments – developments on WSH legislation and within the industry, including new and emerging risks and innovative solutions.

• WSH Performance – WSH targets, statistics, industry benchmarks, contractor performance, near-misses and lessons learnt, lost time and cost incurred due to safety lapses, and WSH complaints lodged.

• WSH Resources – WSH personnel, budget, training, technology.

• WSH Measures – key WSH risk register and mitigation measures, workers’ health and well-being, WSH communications and engagement activities.

Company Directors should also incorporate WSH considerations into business and procurement decisions made at management/board meetings.

2.3.4 Measure 5: Ensure sufficient resource allocation to WSH.

Company Directors should allocate sufficient resources to the following WSH areas as relevant to the needs of the company:

• Conduct regular risk assessments;

• Redesign processes to address upstream risks;

• Set reasonable timeframes for project completion to prevent rushing;

• Identify WSH personnel, worker or union leader to champion good WSH practices on the ground;

• Adopt WSH technology and industrial best practices to detect and prevent workplace incidents;

• Provide relevant WSH training and refresher courses;

• Provide safe equipment and tools to ensure safe work procedures;

• Promote WSH and mental well-being initiatives through events and programmes; and

• Hire/leverage professional advice to address or advise on WSH issues.

2.3.5 Measure 6: Facilitate direct reporting of WSH issues to the Company Director(s).

Company Directors should consider (depending on the size of the organisation and number of work sites):

• Implementing a direct reporting line between the Company Director(s) and WSH personnel (e.g. WSH

Officer, WSH Coordinator);

• Setting up a WSH Committee with representation from management, workers and/or union leaders; and

• Working with appointed WSH personnel and/or union leaders (if any) to remind workers to follow safe work procedures.

2.3.6 Measure 7: Acquire WSH knowledge.

Company Directors should consider attending external and/or in-house trainings and learning journeys to keep abreast of the latest WSH resources, developments and industrial best practices locally and internationally:

• External trainings can include bizSAFE and learning journeys to organisations with progressive WSH practices;

• Where resources are available, in-house WSH professionals could conduct WSH trainings for Company

Director(s) to equip them with knowledge on risk management, systems, and processes, as well as possible technologies to improve WSH;

• Subscribe to the WSH Bulletin to keep abreast of latest developments and WSH Alerts to improve WSH practices and prevent similar WSH incidents; and

• Attend WSH conferences and seminars organised by sector agencies, trade associations, tripartite partners, WSH Council etc.

2.3.7 Measure 8: Conduct engagements to understand processes, workers’ concerns and communicate the need to prioritise WSH.

Company Directors should consider:

• Personally conducting regular workplace walkabouts, together with union leaders (if any), and invite workers, including WSH personnel, to share concerns related to WSH, where timely measures are taken subsequently to address these concerns; and

• Conducting regular reviews to better understand workers’ state of well-being (e.g. via townhalls, pulse surveys, iWorkHealth).

2.3.8 Measure 9: Set and demand effective WSH standards and performance from vendors and partners.

Company Directors should include WSH requirements and WSH track records in their organisation’s tender and procurement decisions (e.g. attainment of bizSAFE or international WSH standards certification; good WSH performance track records based on CheckSAFE on MOM’s website).

As an Occupier or Principal, organisations have duties under the WSH Act to ensure the safety and health of their contractors, subcontractors and outsourced personnel when at work. Company Directors, as leaders of the organisations, must also exercise due diligence to prevent any work incidents.

2.4 Principle 3: Ensure that WSH management systems are highly effective and reviewed regularly

2.4.1 Company Directors should ensure that WSH management systems and processes are highly effective and reviewed regularly, so that WSH is upheld and consistently integrated in business decisions. These systems and processes should ensure that risks are regularly monitored, reported, and reviewed. Proactive monitoring and reviews ensure that outdated and unsafe practices are removed, and new and emerging risks are identified, understood and managed. Implementation of proper change management is also critical to ensure sustained improvement in workplace safety. Company Directors should consider using a reward and disciplinary framework to incentivise positive WSH actions and behaviours, and make WSH part of the performance appraisal of every worker.

2.4.2 Measure 10: Ensure effectiveness of WSH management systems and maintain oversight of compliance with safe work procedures.

Company Directors should:

• Institutionalise WSH audits to review robustness of WSH management systems;

• Institutionalise effective Management of Change programmes to ensure sustained improvement in workplace safety and review potential consequences of unintended changes;

• Work with appointed WSH personnel or union leaders (if any) to remind workers to follow safe work procedures; and

• Develop structures/processes to share audit findings and corresponding action plans to mitigate WSH risks and hazards.

2.4.3 Measure 11: Ensure suitable, adequate and timely risk assessment.

Company Directors should ensure that risk assessments are developed and customised to the organisation’s situation, and that WSH risks are updated, and corresponding control measures implemented. The list of WSH risks and control measures should be checked as often as required, such as through weekly coordination meetings and daily toolbox briefings, and reviewed as soon as reasonably practicable when the situation calls for it.

Examples of such situations include but are not limited to:

• After a WSH incident or near-miss;

• When new information of a hazard is known;

• Before deploying new equipment;

• Before introducing a new work process;

• Other external factors such as climate change and inclement weather (e.g. heat stress, heavy rain, haze); or

• When there are changes to the WSH legislation, Code of Practices and guidelines.

2.4.4 Measure 12: Recognise and reward workers’ efforts toward achieving good WSH performance Incentives help reinforce positive actions and behaviours, and strengthen the workplace safety culture.

Company Directors can consider rewarding workers for good WSH behaviours and outcomes (e.g. their proactiveness in reporting of or intervening in unsafe workplace practices, behaviours or situations, their involvement in implementing WSH improvement initiatives) and make WSH part of the performance appraisal of every worker.

2.4.5 Measure 13: Endorse immediate remedial/disciplinary actions to address workers’ repeated noncompliance with safe work procedures.

Conversely, disciplinary actions should be meted out in a timely manner, in response to workers’ repeated non-compliance despite the organisation’s attempt to actively remind and educate workers on safe work procedures (e.g. not following safe work procedures, not wearing personal protective equipment). Disciplinary actions should be balanced with the incentive schemes already implemented in the workplace.

2.5 Principle 4: Empower workers to actively engage in WSH

2.5.1 Company Directors should ensure that their workers are given the necessary voice and platforms to raise any WSH concerns at work. Workers should be equipped with the necessary knowledge and skillsets to uphold and improve WSH. Every worker is a source of WSH intel and a resource to improve WSH. Union leaders can also play an important role to act as the point of contact to gather feedback, encourage

workers to speak up, or be the bridge between workers and their management to strengthen workplace WSH practices.

Company Directors should ensure feedback channels are available from all levels within their organization and build an open reporting culture as part of a collaborative approach to improve WSH. This reporting system should be one where workers feel safe to report WSH issues without fear of reprisal or job loss, even when highlighting inadequacies of their supervisor/senior management.

2.5.2 Measure 14: Ensure processes are in place for workers to receive information on WSH risks and safe work procedures in a timely manner.

Relevant information that should be shared with workers include:

• WSH incidents, hazards, risks and near misses in the organisation;

• Developments in regulatory requirements, WSH management practice and technical work safety procedures; and

• Emergency and crisis response.

Information can be shared via platforms such as:

• Daily toolbox briefings and weekly coordination meetings;

• Department/unit-level meetings and townhalls;

• WSH Committee meetings;

• Staff onboarding and training programmes; and

• Posters in workplaces, emails and short text messages.

2.5.3 Measure 15: Set up reporting systems, encourage proactive reporting and ensure proper follow-up

to address WSH issues.

A comprehensive system and process is necessary for workers to report any WSH incidents, where all reported WSH incidents are adequately investigated and concluded, such as through doing a root cause analysis and the necessary rectifications where required. Company Directors should set the right tone and provide a safe environment for workers to report unsafe practices and near misses, and to assure workers of the safeguards and protections in place (e.g. their identities are kept confidential, no penalties for speaking up).

Company Directors should ensure that these systems (e.g. hotline number or online channels for reporting) are available for both workers and members of the public to report various WSH issues including:

• WSH incidents (e.g. near-misses, hazards, incidents and lapses);

• Concerns/feedback on incident-prevention measures or safety improvements; and

• Company Directors should consider inviting workers to share any WSH concerns or suggestions such as via secured and anonymous platforms to protect the identities of workers, and ensure that workers are empowered to voice WSH concerns and to stop work if they see WSH red flags at work.

Company Directors should ensure proper follow-up of these reports and that appropriate actions were taken to address the issues reported.

2.5.4 Measure 16: Commit resources and protected time for workers to undergo WSH training and refresher courses.

Company Directors should consider:

• Allocating training funds;

• Ensuring protected time during working hours for WSH training, refresher courses, and WSH meetings; and

• Ensuring that managers identify suitable WSH trainings (e.g. in-house/on-the-job, or external training) and monitor the competency of workers under their supervision, especially if the worker is new to the organisation or the role.

When prioritising training support, Company Directors can also consider:

• Ensuring workers attend the relevant mandatory training;

• Ensuring adequate training to mitigate key WSH risks; and

• Integrating WSH in functional training.

2.5.5 Measure 17: Involve workers in the joint development and implementation of strategies/programmes to improve WSH.

• Company Directors should include WSH considerations in all work planning or strategising sessions.

• Company directors should consider involving their contractors/vendors’ WSH teams as well.

• For unionised companies, Company Directors should consider partnering union leaders to jointly develop WSH improvement strategies and action plans.

Toxic Waste Control

 MANAGEMENT OF TOXIC INDUSTRIAL WASTE IN SINGAPORE

1 Introduction

1.1 Wastes may be defined as materials which no longer can be used for the purposes they were intended for originally. Toxic industrial waste is waste which by their nature and quality may be potentially detrimental to human health and/or the environment and which require special management, treatment and disposal.

1.2 In view of Singapore’s small land area with limited land and water resources, the siting of industries has to be carefully planned and managed. In addition, industries are required to design their manufacturing processes and provide pollution control facilities to comply with pollution control requirements on emission of air pollutants, discharge of industrial effluent, management of hazardous substances and toxic industrial waste.

1.3 There are currently several thousands of companies in Singapore which handle or use hazardous chemicals. The use of these chemicals generates a wide variety of toxic industrial waste. The main types are spent acids, spent solvents, spent etchants, waste oil and other waste sludge.

2 Strategy for Control of Toxic Industrial Waste

2.1 The key elements in Singapore’s strategy to control toxic industrial waste and ensure their safe treatment and disposal are as follows:

(i) avoid generation of intractable wastes;

(ii) encourage waste minimisation;

(iii) encourage waste reuse, recovery and recycling;

(iv) regulate collection, treatment and disposal;

(v) monitor and audit collection, treatment and disposal; and

(vi) promote and support educational and training programmes.

2.2 All new industrial developments are screened by the National Environment Agency (NEA) at the planning stage. One of the key areas checked in this screening process is the generation and disposal of wastes from proposed industrial developments. NEA would approve the proposed industrial development only if the wastes generated could be safely disposed of in Singapore. This avoids the generation of intractable wastes that cannot be safely disposed of in Singapore.

2.3 In addition, NEA will require industries to use processes that minimise waste generation or facilitates the reuse, recovery and recycling of the wastes. Industries also need to incorporate measures into the design of their facilities to ensure wastes generated can be properly handled and managed. At the building plan stage, checks are made to ensure that these measures are incorporated into the design of the plants.

2.4 NEA has encouraged the setting up of specialised waste recycling, treatment, and disposal plants. There are currently close to 100 such plants in Singapore, treating and recycling a wide range of toxic industrial waste. Some of the toxic industrial waste collected and recycled by these plants for reuse are discussed in Section 5.

2.5 The setting up of specialised waste recycling, treatment and disposal plants serve to help industries, especially the smaller companies, which may generate small quantities of special wastes but find it impractical or uneconomical to install, operate and maintain a waste treatment facility because of cost, lack of expertise or space constraint.

2.6 The collection, recycling, treatment and disposal of toxic industrial waste are controlled under the Environmental Public Health Act (EPHA) and the Environmental Public Health (Toxic Industrial Waste) Regulations (EPH(TIW)Regs).

3 The Environmental Public Health (Toxic Industrial Waste) Regulations (EPH(TIW)Regs)

3.1 The control on the import, sale, supply, receipt, transport, treatment and disposal of toxic industrial waste are regulated under the EPH(TIW)Regs. Toxic industrial waste controlled under the EPH(TIW)Regs are listed in the Schedule of the Regulations as waste streams from specific industrial activities, wastes with specified toxic components and as specific categories of wastes. The list includes spent acids, alkalis, wastes containing gallium arsenide,spent etching solutions containing copper from printed circuit board manufacturing, etc. The list is at the Annex.

3.2 In order to facilitate controls and proper management, the functions and responsibilities of key persons involved in handling of the toxic industrial waste are clearly delineated in the EPH(TIW)Regs. The key persons include the following:

(a) Generator of wastes

(b) Collector

(c) Carrier or transporter

(d) Driver

3.3 The generator will have to treat the wastes in an approved in-house waste treatment plant and dispose of the residues, if any, at NEA’s approved landfill site. Alternatively, the generator can engage a licensed toxic industrial waste collector to collect his wastes for treatment and disposal.

3.4 A toxic industrial waste collector is a person who receives toxic industrial waste for storage, reprocessing, treatment and disposal. He is required to obtain a licence from NEA to collect specific toxic industrial waste that are listed in his licence and confine his waste storage and treatment activities to approved premises and facilities.

3.5 Written transport approval from NEA is also required for the transportation of wastes in quantities which exceed those specified in the EPH(TIW)Regs. The responsibilities of the following key persons in the transportation are clearly defined in the EPH(TIW)Regs:

(a) Consignor - the person who presents a consignment of controlled waste for transport. The consignor can be either the generator or the licensed collector. Transport approval shall be obtained from NEA to transport the waste.

(b) Carrier - the person who undertakes the transport of the controlled waste. He can either be the generator, the licensed collector or the transport company engaged by either one of them.

(c) Consignee - the person who receives the controlled waste. He is usually the licensed collector.

(d) Driver - the driver of the vehicle transporting the toxic industrial waste.

3.6 To prevent illegal dumping and disposal of toxic industrial waste, the movement of every consignment of wastes from a generator through a carrier to a collector is tracked by means of an Internet based electronic submission of consignment note under the Waste and Resource Management System (WRMS).

4 Waste Minimisation

4.1 NEA formulates policies to promote and spearhead waste minimisation in Singapore. It works closely with the industries to promote waste minimization and some of the activities are as follows:

(a) Waste Exchange

NEA helps to link industries for exchange of wastes. Waste to one company may be a resource to another. For example,waste alkali generated by one company could be used by another company to neutralise the acidic wastes. This would minimise the ultimate quantity of wastes to be disposed of.

(b) Use of Clean Technology

At the planning consultation stage, NEA advises and encourages industries to use clean technologies which minimise waste generation.

(c) Reuse and Recycling

NEA encourages the recycling and reuse of wastes and assists in the setting up of waste recycling plants. Some of the wastes that are being recycled and reused in Singapore are discussed in Section 6.

(d) Waste Audit

NEA encourages those industries that generate large quantities of wastes to carry out waste audit. A waste audit is designed to achieve maximum resource optimisation and improved process performance. The audit enables one to takea comprehensive look at the process to understand the material flows and to focus on areas where waste reductions are possible. The waste audit can be carried out to cover a complete process or to concentrate on a selection of unit operations within a process. There are competent consultants in Singapore to carry out such waste audit for industries.

5 Some Practices Adopted for Recycling and Reuse of Wastes

5.1 A large amount of industrial waste generated and collected in Singapore by the licensed collectors are either recycled, reused or have valuable components extracted and recovered before disposal. Such wastes include spent solvents, spent etchants and photographic wastes.

5.2 Spent solvents are generated by a wide range of industries. Each year about 75,000 m3 of spent solvents are collected by the licensed collectors. The spent solvents collected include acetone, chloroform, ethyl acetate, methylene chloride and toluene. About 35% of spent solvents are recovered by distillation. The practice adopted by these collectors is usually batch (differential) distillation. The equipment comprises a still to vapourise the solvents, a condenser to condense the vapours and collecting vessels to collect the condensate and the residues. The recovered solvents are sold for reuse by industries. The remaining spent solvents that could not be recovered are used as supplementary fuel for toxic waste incinerators.

5.3 Printing and film processing activities generate photographic wastes such as spent fixers and bleaches. These wastes contain silver in solution. An effective and commercially viable method, the electrolytic extraction process, is used to recover the silver. In this process, carbon is used as the anode and a stainless steel drum as the cathode. The silver is deposited on the stainless steel drum. The extracted silver has a purity of more than 90 %. The remaining liquid from the electrolysis process is treated and neutralised in a wastewater treatment plant before discharge into the sewers.

5.4 Etching is an important process used in the electronics industry especially in the manufacture of the printed circuit boards. The process generates spent etchants such as cupric chloride etchants, ferric chloride etchants and ammonia etchants. Each year about 10,000 m3 of spent etchants are generated and treated in Singapore.Spent ferric chloride etchants are regenerated using scrap iron and chlorine. In this process, scrap iron is first added to the spent etchant and the copper sludge that precipitates out is collected and sold as a valuable by-product. The etchant is next regenerated by passing chlorine through it. The regenerated etchant is sold for reuse.

6 Monitoring and Enforcement

6.1 Any control system, no matter how well-crafted will not be effective without inspection and enforcement. Enforcement will ensure the minority of companies that violate the controls are penalized accordingly and would not gain unfairly from their violations. Without inspection and enforcement, companies that originally comply with the controls may become complacent and pay less attention and effort to ensure their operations continue to be safely managed.

6.2 Routine inspections are conducted on premises of toxic industrial waste collectors to ensure requirements on collection, storage, treatment, and disposal of toxic industrial waste are complied with.

7 Transboundary Movements of Hazardous Wastes

7.1 The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (Basel Convention) was adopted in 1989 and came into force in 1992. The Convention aims to protect human health from the generation, transboundary movements and management of hazardous waste as defined under the Convention.

7.2 Singapore acceded to the Basel Convention on 2 Jan 1996 and on 16 Mar 1998 enacted The Hazardous Waste (Control of Export, Import and Transit) Act and its Regulations to strengthen the control on export, import and transit of hazardous waste in accordance with the principles and provisions of the Basel Convention.

7.3 Under the Hazardous Waste (Control of Export, Import and Transit) Act and its Regulations, any person who wishes to export, import or transit hazardous waste shall obtain a permit from NEA. The Prior Informed Consent (PIC) procedure of the Basel Convention is adopted in granting any permit for the export, import or transit of hazardous waste.

8 Conclusion

8.1 In addition to regulatory controls, the co-operation of industries in ensuring that toxic industrial waste are properly managed and disposed of in Singapore is essential. NEA will continue to work with industry and relevant stakeholders in promoting better management and disposal of toxic industrial waste through joint research and educational programmes.

8.2 NEA will continue to participate in international events on the Basel Convention and adopt the principles of Basel Convention in dealing with transboundary movements of hazardous wastes defined under the Convention

ANNEX

Facial Characteristics Limitation

Table 1 – Limitations related to operator’s facial characteristics

Figure 6 – Facial characteristics affecting the use of a respirator

Limitations of Respiratory Protection

In general, respiratory protection is the weakest of the Hierarchy of Controls, You should consider whether you would know if the respiratory protection is failing to protect before a dangerous dose is inhaled. Irritant gases often self-indicate, so you can smell them or they will sting the eyes at low concentrations, allowing a quick escape before too much damage is done. However, many other toxic gases have an odour threshold above  the hazardous level. You should consider whether a higher control method is possible through the use of engineering controls, ventilation, substitution of the chemicals etc.

 

Selecting the Exact Make and Model

There are a wide range of manufacturers and suppliers of respiratory protection. Most offer a full spectrum of types, and they will offer several manufacturers’ models. As design and fit are all-important, it makes sense for the wearer to try several alternatives and to choose the one that feels most comfortable.

For some unusual contaminants, only specialist manufacturers may offer the exact mask or cartridge for instance when working with Mercury. It is important however that the qualified expert selects the exact makes and models to be used for each situation, and that the worker uses exactly that make and model for the job.

Types of Respiratory Protection

Selecting the types of respiratory protection equipment to be used 

Adequate against the hazard

Adequate against the hazard means two things:

• That it is the correct equipment for removing or reducing the exposure to the  hazard which is being targeted, and
• That it reduces exposure to the hazard to a level which will not harm the wearer’s health or safety.

The selection of respiratory protective equipment should be carried out by a competent person with knowledge of the level of each contaminant in the external air and the safe level for breathing (usually given on the Safety Data Sheet). The information is used to calculate the APF required. The APF then dictates the type and model of respiratory protection to be used.

The HRA may have required the industrial hygienist to measure or estimate the concentrations of hazardous substances in the air. The hygienist can then look up the WEL for these substances. By dividing the actual concentration by the WEL for each, the hygienist can calculate the APF required and thus select the type of respiratory protection which does the job.

Respiratory protection suppliers publish the APF figures for each of their models. In general, disposable facemask respirators and cartridge half masks have an APF of around 20, cartridge full face masks around 40, airline breathing apparatus around 200, and self-contained breathing apparatus around 2000.

In the U.S., the Occupational Safety and Health Administration has published default APFs for the major types of respirators which can be referred to via the OSHA Standard 29 CFR 1910.134 for Assigned Protection Factors.

The physical nature of the contaminant in the air must also be considered. Dusts, aerosols, vapours and gases required different types of filter to be removed.

Filtering respirators must not be used where oxygen deficiency is a problem. Only breathing apparatus can deliver air with the correct oxygen level. Where RPE is required in a confined space during hot work activities or activities that could potentially effect the oxygen levels in the confined space (such as when disturbing gases in sludges at the bottom of tanks, welding, needle-gunning, accessing chain lockers on Vessels/FPSOs, etc.), either fresh air hoses or constant-flow breathing apparatus are to be used to protect users from airborne particles, fumes and potential increases in carbon dioxide levels due to the work task.

It is important that the air being delivered meet the relevant quality standards. This may require a qualified expert, such as an industrial hygienist, to test the air or review air quality certifications before use 

Suited against the task

The task being carried out under respiratory protection may have elements  which affect the selection. For example, airline or self-contained breathing  apparatus may not allow the wearer to go into tight spaces.

If other types of PPE, such as head, hearing or eye protection, need to be worn, they may interfere with certain types of respiratory protection, and   this will also affect the selection decision. Most manufacturers offer combination (or integrated) PPE, which combines head, hearing, eye and respiratory protection.

Full face masks generally limit visibility, both because they give a limited view at the edges, and because the plastic screen loses some transparency. So, if the task requires visual accuracy, this should be considered.

Suitability factors

Suited to the Work Environment

If the work environment is challenging, for example if it is hot, wet, slippery or chemically contaminated, this should be considered. If the work is at height or depth, access issues may limit the decision, particularly if ladders have to be negotiated.

Where RPE is required in a confined space during hot work activities, such as welding, the use of either Fresh Air Hose or Constant Flow breathing       apparatus should be used to provide adequate protection to the user from air borne particles, fumes and potential increasing carbon dioxide levels due to the hot work task                   

Suited to the Wearer

Working with respiratory protection puts an extra load on the wearer in terms of ease of breathing, and also weight, heat and access problems. Fitness to Work testing for breathing apparatus users will determine

whether the user has the fitness required to handle the extra load. Facemasks require a good seal between the face and the edge of the mask in order to stop leakage round the mask. This can be difficult to achieve, and several types of mask may need to be tried to find the one which fits best. The material of the mask, particularly those with a rubber seal, can make a big difference. Facial hair, particularly beards and sideburns, can also interfere with the seal. If the user has facial hair and is prepared to shave it off, that is the best solution. If not, a head-enclosing (loose-fitting) mask may be necessary

 

 

 

Respiratory Protection Equipment Selection

Selection of Respiratory Protective Equipment (RPE)

Respiratory protective equipment selected must provides adequate protection against the hazard, is comfortable to the wearer and does not interfere with the  work. However, there is often a trade-off between protection and comfort.

The following are examples of each type of respiratory protection. They also give typical Assigned Protection Factors (APF), and common applications. Only types and models approved by local authority (e.g. NIOSH in the USA, In Europe have CE markings and appropriate EN certifications) should be used. 

Respirators can be non-powered (relying on the wearer’s breathing to draw the air through the filter) or powered (using a small pump or fan to draw the air through the filter). Powered respirators put less load on the lungs, and have the additional advantage (along with breathing apparatus) of maintaining a positive pressure inside the facemask, so any leakage will be outwards rather than inwards.

Some facepiece respirators have an exhalation valve built in. This allows inhaled air to pass through the filtering fabric or cartridge of the respirator, but exhaled air passes through the valve. This helps to keep the facemask tight against the face.

Understanding How to Select the Correct APF Value

All respiratory protective equipment is assigned an Assigned Protection Factor (APF) that allows a specialist to select the correct type of RPE and Filter/ Cartridge to protect the user from the hazards associated with the job based on the Workplace Exposure Limit (WEL) of the hazardous substance the user is working with.

For instance if a worker was working with softwood (particulates) where the concentration in the workplace from the task is 55 mg/m3, and this product has a WEL of 5 mg/m3 over an 8hr Time-Weighted Average (TWA). The calculation to work out the required APF Level of respiratory protection is completed as follows:

55 mg/m3      
5 mg/m3
= 11 x WEL (5 mg/m3)

This means you would need a facemask with an APF of at least 11, which would mean using a particulate filter FFP3 facemask as it has an APF of 20 rather than a  FFP2, which has an APF of 10.

Types of Respiratory Protective Equipment (RPE) 

Disposable Facemask Respirators

Disposable facemask respirators are simple devices which cover the mouth and nose. The breathing air passes through the material on the mask, which is capable of removing the contaminant from the breathing air by filtering or absorbing it.

These usually have a bridge which can be pinched to get a better fit over the nose, and may have a valve to allow exhaled are to escape more efficiently. Each model and type of respirator is designed to protect from one hazard so, for example, a nuisance dust mask should not be used for organic vapours.

Their most common use is for protecting against solid particles such as nuisance dusts, for example when needle-gunning or emptying sacks into a hopper. They have an APF of 4-20  (FFP1=4, FFP2=10, FFP3=20). This means that for an APF of 4 the facemask will provide the user protection up to four times the WEL

Figure 1 – Examples of Disposable Facemask Respirators

Cartridge/ Filter Half Mask Respirators

Cartridge half mask respirators consist of a rubber or polymer housing with one or two cartridges fitted into the housing. The breathing air passes through the cartridges, which remove the contaminant from the breathing air by filtering or absorbing it.

The housing is more flexible than for disposable respirators, so a better fit and face seal can be obtained, however they are heavier. They are used for protecting against solid or liquid particles such as nuisance dusts and oil fumes, and for gases and vapours such as paint solvents or ammonia.

They have an Assigned Protection Factor of 4-20 (P1=4, P2=10, P3=20) for particulates, and 10 for gases and vapours          

Figure 2 – Examples of cartridge/filter Half Mask Respirators

Cartridge Full Face Mask Respirators                     

Full face mask respirators work in the same way as half mask respirators, with a rubber or polymer housing fitted with one or two cartridges, which remove the contaminant from the breathing air. However, they also incorporate an eye screen in the housing. As well as protecting the eyes, this gives a better face seal, but it does make them heavier, and restricts vision. They also need more maintenance

Figure 3– Examples of Cartridge Full Face Mask Respirators

Self -Contained Breathing Apparatus (SCBA)

Self-contained breathing apparatus feeds breathing quality air from a cylinder carried on the back via a demand valve to the facemask. This allows better access into vessels and awkward spaces than airline breathing apparatus. Their main uses are for protecting against solid or liquid particles, gases and vapours. They are used in oxygen depleted atmospheres, such as vessel entry. They have an Assigned Protection Factor of 2,000 with a full face mask.

Figure 5 – Example of a Self-Contained Breathing Apparatus

WSH Audit -CP CEO WSH Duties

With the launched of the Code of Practice on Chief Executives and Board of Directors WSH Duties what should an Workplace and Health professional do?

Singapore Standard Code of Practices and other applicable legal requirements and guidelines are legal binding that is must comply with their associated legal requirement.

Review Code of Practice on Chief Executives and Board of Directors WSH Duties for its requirement and carrying out documentation review of the Safety and Health Management System (SHMS) to identify the lapses and close the gaps .

Remember the onus of responsibility and accountability of an organization Workplace Safety and Health standards now falls on either the CEO or Board of Directors. and they must be involved in all aspects of Workplace Safety and Health management systems which shall include but not restricted to:

• WSH Policy Development
• WSH roles and responsibilities
• WSH training
• WSH objectives
• WSH program
• WSH Inspection and Employee Engagement
• WSH Standards for Contractor / Supplier Qualification
• WSH Recognition Program and more

Here is sample of WSH Audit checklist

CP CEO WSH Duties

 The Code of Practice on Chief Executives and Board of Directors WSH Duties was published on the Government Electronic Gazette on 14 October 2022 which comes into force from 31 October 2022.

The objective of the CP is to provide clarity on and strengthen ownership of companies’ Chief Executives’ and Board of Directors’ (henceforth termed as “Company Directors”) workplace safety and health (WSH) roles and duties.

Chief Executives and Board of Directors are usually the ones behind the scene steering the operations and oversee management of their organisation and have greater influence and authority over their workplace safety and health (WSH) standards.

The CP called for Company Directors to prioritise  workplace Safety and health and set the safety culture for their organisations as stipulated in Section 48(1) of the Workplace Safety and Health Act .

This Code of Practice provide greater clarity on and strengthen WSH ownership of Company Directors and also lists available resources that can aid Company Directors in their efforts to discharge their duties and uphold WSH standards at their workplaces.

Here are  the 7 Principles and 17 Measures to Guide To Uphold Workplace WSH Standard