National Industrial Chemicals Notification and Assessment Scheme



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Summary


All three labels demonstrated very poor compliance with the SUSDP. Label 1 is for a product used only for domestic purposes and contains over 60% trichloroethylene. Labels 2 and 3 were for products used both industrially and domestically and contained <60% and >90% trichloroethylene respectively. Labels 2 and 3 are required to comply with the Labelling Code as well as the SUSDP, and so they were checked for the additional elements required according to the Labelling Code. It was found that the labels contained risk phrase R40, but not risk phrases R36 or R38. They contained appropriate safety phrases (S23, 36/37), however they were lacking in emergency instructions, contact telephone number, and reference to the MSDS.

Discussion of findings

Deficiencies common to labels for pure trichloroethylene and mixtures used industrially were:

omission of a risk phrase warning of irreversible effects (R40);

omission of a risk phrase regarding irritation to eyes (R36);

omission of a risk phrase regarding irritation to skin (R38);

omission of a safety instruction regarding the wearing of protective clothing (S36); and

omission of emergency procedures for clean-up of spills, leaks or fires.

In addition, labels for the mixtures had the following deficiencies:

omission of safety instruction regarding the wearing of gloves (S37);

omission of the signal word POISON; and

omission of details of the amount of trichloroethylene in the mixture.

Compliance with the SUSDP in the case of three products used domestically was very poor, with most requirements not present.


14.3.3Education and training


Guidelines for the induction and training of workers exposed to hazardous substances are provided in the National Commission’s National Model Regulations for the Control of Workplace Hazardous Substances, (the Model Regulations) (National Occupational Health and Safety Commission (NOHSC), 1994). Under these regulations employers are obliged to provide training and education to workers handling hazardous substances.

The Model Regulations stipulate that training and induction should be appropriate for the workers concerned. It is important that each workplace implement a program that is suitably designed to accommodate the needs of different workers.

Training should be given to the workers at induction and repeated at regular intervals to reinforce the information. Training and education needs for workers should be reviewed on a regular basis.

For trichloroethylene, the training program should address:

acute and potential chronic health effects of trichloroethylene;

skin absorption potential and skin effects of trichloroethylene following prolonged exposure;

explanation of MSDS and labelling of trichloroethylene and trichloroethylene products; and

use and maintenance of personal protective equipment.

In addition, training for workers involved in vapour degreasing should include:

basic plant operation, covering start up procedures, checking cut outs, cooling and solvent condition, loading, unloading and jigging work and delays in the freeboard zone;

procedures to be followed during cleaning of degreasing tanks, particularly regarding procedures for working in confined spaces when entering the tank is required.

Information obtained for assessment indicates that very few places have written instructions or formal training for workers. Most of the worksites provide “on the job” training where the supervisor trains the new employee in the various activities involved. Only one of the six workplaces visited had a training manual and operating procedures and the training was repeated every 12 months.

Most importers of trichloroethylene provide technical bulletins which give information about the specifications of trichloroethylene, it’s physical properties and uses. One importer provides a Product Stewardship Manual for chlorinated solvents to end users. The manual includes information on precautions for the safe handling, storage and use of chlorinated solvents including trichloroethylene. It also includes information on safe work practices to be followed while operating a degreaser and cleaning of a degreasing tank. These bulletins and manuals may be used as aids to draw up training programs that would be useful to workers.

14.4Monitoring and regulatory controls

14.4.1Atmospheric monitoring


Atmospheric monitoring is not conducted on a regular basis at workplaces in Australia using trichloroethylene. No monitoring data were available for worksites engaged in repacking or formulating. Some workplaces conduct air monitoring on an ad hoc basis during vapour degreasing. The reasons for conducting monitoring varied from a need to establish base-line monitoring results following modifications to the degreaser and complaints of solvent fumes following installation of a new plant to need to improve employee safety.

Under the National Commission’s National Model Regulations for the Control of Workplace Hazardous Substances (National Occupational Health and Safety Commission (NOHSC), 1994), employers need to carry out an assessment of the workplace for all hazardous substances, with methodology for the assessment provided in the Guidance Note for the Assessment of Health Risks arising from the use of Hazardous Substances in the Workplace (National Occupational Health and Safety Commission (NOHSC), 1994). When the assessment indicates that the risk of inhalation exposure is significant, atmospheric monitoring should be conducted to measure trichloroethylene concentrations in the workplace. Monitoring provides an indication of the effectiveness of the control measures in place and whether there is a need to improve measures to reduce worker exposure. Atmospheric monitoring should be repeated if any changes are made to the process or equipment.

Analytical methods for the measurement of trichloroethylene in air are detailed in Chapter 6.

14.4.2Exposure standard


The current Australian occupational exposure standard for trichloroethylene, reviewed in 1990, is 50 ppm (8 h TWA) with a short term exposure limit (STEL) for 15 min. of 200 ppm. The National Occupational Health and Safety Commission’s Exposure Standards Expert Working Group concluded in 1990 that studies of industrial situations reported subjective symptoms, such as mild

irritation, headache and dizziness at 50 ppm while controlled laboratory studies reported anaesthetic effects may begin to occur at about 100 ppm and would be mildly felt at 200 ppm. The STEL is recommended on the basis that it is low enough to protect against early anaesthetic effects. The documentation states that these levels should provide a safety margin for preventing other health effects such as liver toxicity.

Table 36 lists the exposure standards in various countries.

The hazard assessment indicates that:

the critical effect is renal toxicity;

the inhalation NOAEL for renal toxicity is 100 ppm and the LOAEL is 300 ppm (these values do not incorporate any safety factor);

a classification of carcinogen Category 2 is appropriate;

a classification of mutagen Category 3 is appropriate; and

trichloroethylene is absorbed through the skin.
Table 36 - Occupational exposure limits


Country

TWA

STEL

Year adopted

Australia


Canada

Ontario


British

Colombia
France


Germany

50ppm


50 ppm

50 ppm


75 ppm
50 ppm

C

200 ppm for 15 min

200 ppm


150 ppm for 15 min

200 ppm
250 ppm with a maximum duration of 30 min/shift occurring maximally twice per work shift.


1990


1995

1991


Netherlands


35 ppm

190 ppm

1992

New Zealand

50 ppm


200 ppm for 15 min


1994



Sweden

10 ppm


25 ppm for 15 min

1993

U.K.

100 ppm, skin notation


150 ppm for 10 min

1993

USA

ACGIH

50 ppm

100 ppm

1992


NIOSH

25 ppm







OSHA

50 ppm


200 ppm

1993

Note: C=pregnancy group C (no reason to fear risk of damage to the developing embryo when adhering to MAK or BAT values)

14.4.3Biological exposure index


Biological monitoring is the assessment of exposure through measurement of the chemical or its metabolites in biological specimens. Estimations of trichloroacetic acid and trichloroethanol in urine and blood are recommended by ACGIH (ACGIH, 1992) and Germany (Deutsche Forschungsgemeinschaft, 1996) for biological monitoring of exposure to trichloroethylene. These are non-specific indicators of exposure to trichloroethylene as they can be metabolites of other chlorinated ethanes and ethylenes. Methods available for biological monitoring of trichloroethylene are detailed in Chapter 6 of the report.

The following biological exposure indices to determine exposure to trichloroethylene have been recommended by ACGIH and Germany.


Germany (1991): Trichloroethanol in blood 5 mg/L at end of exposure
or end of shift.

Trichloroacetic acid in urine 100 mg/L at end of


exposure or end of shift.
ACGIH: Trichloroacetic acid in urine 100 mg/g creatinine at the (1991-1992) end of shift at the end of the workweek, as an indicator

of integrated weekly exposure to trichloroethylene.

Trichloroacetic acid and trichloroethanol in urine 300 mg/g creatinine with sampling time end of shift at end of workweek, as an indicator of integrated exposure to trichloroethylene.

Free trichloroethanol in blood 4 mg/L at end of shift at end of workweek, as an indicator of recent exposure.


14.4.4Health surveillance


Health surveillance is not routinely conducted for workers exposed to trichloroethylene.

Trichloroethylene was reviewed by the National Commission’s Expert Working Group on Health Surveillance in 1993. It was decided not to include trichloroethylene in Schedule 3 (substances requiring health surveillance) of the National Model Regulations for the Control of Hazardous Substances (1994) as atmospheric monitoring was considered adequate to assess worker exposure and thus health surveillance was not warranted. There is therefore no formal requirement for health surveillance programs for workers.

Under the National Commission’s National Model Regulations for the Control of Hazardous Substances (1994) health surveillance is required for employees where the workplace assessment has shown that there is a likelihood of an identifiable disease or health effect occurring under the particular conditions of work following exposure to a hazardous substance. The employer is responsible for providing health surveillance.



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