Contents:
OSH requirements
Identifying chemical hazards
Hazard classes
Material Safety Data Sheets
The 'walk-through'
Measuring hazard
Evaluating risk
Controlling risks
Protective clothing and emergency equipment

OSH requirements
Under Occupational Safety and Health legislation, safe chemical handling practice is now a legal requirement.  Tanners who do NOT practice responsibility for OSH requirements face :

• Legal prosecution
• Possible crippling lawsuits in the future

It is VITAL that you do two things.

• Follow the best available safety practice
• Document this thoroughly, so that you have a defense if something goes wrong.

The law states that you must :

• Identify the hazards
• Measure the hazards
• Evaluate the risks
• Control the risks

Identifying Chemical Hazards

• Check all chemicals that come on site
• Check which (if any) dangerous goods class they belong to
• Identify the primary hazard
• Identify any important secondary hazards

Hazard Classes
There are nine main hazard classes.  Of these, four may be of concern to the tanner
Class 2.  Flammable liquids.  Shown by a red diamond. Flammable liquids such as fuels and oils represent a fire risk.

Class 5.  oxidizers.  Shown by a yellow diamond. This is of special concern to tanners.  Oxidizers such as hydrogen peroxide, sodium chlorite etc., will react, sometimes explosively with anything organic.  This could be many chemicals, even including flour, oil, or sawdust.  If possible avoid having strong oxidizers on site at all. If they are essential, they must be treated be very special care.

Class 6.  Toxic and infectious substance.  Shown by a white diamond. Infectious substances are not normally on a tannery site.  Toxic substances are a matter of concern.  It is vital that the toxic route is identified.  Is it toxic by swallowing, breathing dust or droplets, or toxic through the skin?  Via the skin is a major concern, and such materials should not be on site.  Toxic through dust or droplets is also of concern, and systems need to be in place to avoid dust or droplets forming.  Ingesting these chemicals by swallowing is of lesser concern, if staff are correctly trained in simple techniques (such as washing hands after handling chemicals, and changing clothes when they are contaminated).

Class 8.  Corrosives.   Shown by a diamond, half white, half black. These substances are common in a tannery, and you need to be very clear on how to handle them. The biggest hazard is inhaling droplets (avoid generating sprays), or getting them into the eyes.  Staff training and the provision of proper equipment for both protection and treatment is vital.

Material Safety Data Sheets
This is the prime tool for identifying hazards.
Things to check :

• Hazard diamonds
• Statement of hazard class
• UN Number
• Dangerous goods class
• Hazchem code
• Subsidiary risk.

The MSDS must NOT just be filed away.  It must be studied, and must be made readily available to anyone who handles that chemical.

The “Walk Through”
The tannery safety officer, and at least one other person should conduct a “walk through” check with a proper check list, of the entire tannery site, at least once each three months.  (more often is better).  The list below is very general, and is meant to serve only as a rough guide to base your own, more specific, and more detailed checks upon.
 
 

Physical   Workplace construction Workplace housekeeping Lighting Noise Ventilation - general Ventilation - local Thermal environment Machine guarding Machine design Electricity/ radiation Sanitary facilities Eating facilities	Personal/ Biological Infectious diseases Bacterial Viral Fungal Direct animal contact Posture Work movements repetition force Personal protective equipment respiratory ears eyes heads/ feet/ skin
Chemical Dusts Fumes/ Vapours Chemical storage MSDS Emergency shower Waste disposal	Social/ Administrative Organisation structure Management-worker relationships Make-up and size of workforce Absenteeism (injury illness) Induction/ Training/ Education Health service / policy

 
Measuring the Hazard
Your second legal requirement (after identifying hazards) is to measure them.  There are two approaches to measuring chemical hazards, and you are obligated to use them both.
 

1. Environmental Measurements.
   This involves sampling and testing the environment.  For chemicals, you should test the air for chemicals, particles, vapours etc. 
   
   
2. Biological Measurements.
   These involve the workers and their response to the chemical environment.  Various tests can be carried out. Examples are :
1. Lung function
2. Blood tests
3. Symptoms of illnesses
4. Regular full medical check-up.

Evaluate the risk
Your third legal obligation.

Risk can be estimated by the following equation.   R =  F.E.S

Risk  =  Frequency  x  length of Exposure  x  Severity of any harmful result.

Controlling Risks
Your fourth legal obligation. This is done in four ways.

1. Elimination of the risk
2. Isolation of the risk
3. Minimizing the risk
4. Monitoring the risk.

Elimination
Vital for those chemicals you have found by your evaluation to be an extreme risk.  For lesser risks, ask yourself “Is this dangerous item really essential?”  If not, get rid of it!

Isolation
Put dangerous chemicals into a secure enclosure. Make sure there is secure and ample bunding. The special case is oxidizers.

• Keep them well clear of other chemicals (including oil, sawdust etc.)
• Keep away from untrained staff.  Good security required.
• Keep off the floor.

Minimizing

• Keep exposure to hazardous chemicals to a minimum.
• Use good ventilation.
• Design your systems to reduce time exposed to chemicals.
• Thorough training of operators.
• Make sure proper protective clothing is fully available, and used.
• When possible, use automatic dosing systems.

Monitoring
This is a legal requirement - not voluntary.

• Use both environmental and biological monitoring methods.
• Watch absenteeism.  Sometimes there is a good reason!
• Involve all staff in monitoring programs. Their input is vital.

Protective Clothing and Emergency Equipment
It is vital that all the necessary clothing and equipment be provides.  General principles are :

• All must meet approved standards.
• All must be fully available when required.
• One item per operator may be required.  Do not expect staff to share intimate personal equipment such as respirators, gloves or boots.  Hygiene is then a major problem.
• Store close to work station.  Store in a suitable box to keep the equipment clean and in good condition.
• Replace safety clothing and equipment often.
• Each item must fit the individual.  Do not rely on “one size fits all” approach.

Respirators must be of the proper type.  Filter masks are fine for dusts, but no good for gases.  Use filters, activated charcoal masks, or air flow masks as needed to meet the  particular hazard. For example, Hydrogen Sulphide exposure needs at least air flow or self contained breathing apparatus.

Gloves
This is an often misused item.  There are many types, and they are not all suitable for all end uses. Consider the following factors.

• How long do they need to be?
• For prolonged use, they should be lined with cotton.
• Chemical resistant gloves are needed for specific chemicals.
• Seams in gloves will allow chemicals to pass through.
• Replace them often.

Emergency Eye Wash
These need to be near each work station where chemicals are used.  Near means within 5 metres.  Place them in a position so that all staff can use them.  Check them often, and keep them clean.

The modern aerated wash should be used.  Older “jet” wash systems should be replaced.

When in use, they need to be washing for minutes, not seconds.  Preferably 15 minutes.  While doing so, hold the victim’s eyes open.

This article has been a brief run through some aspects of chemical safety.  Obviously this is an enormous subject, with many, many special requirements for specific chemicals and specific conditions.   If we can help further, please let us know.

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