Personal exposure to airborne pollutants Report

61 Pages·2015·0.91 MB·English

by  User @

Mine Health and Safety Council

Develop an operations manual for the
implementation of the revised code of practice for
the assessment of personal exposure to airborne
pollutants

Final Report

Authors: CJ Pretorius, JJ Dekker
S Letsoalo, T Grové, JJ Lottering

Research agency: Council for Scientific and Industrial Research
Project number: MHSC031/14/15
Date: November 2015
Table of Contents

Abbreviations and Nomenclature ............................................................................................ 3
Executive Summary ................................................................................................................ 4
1. Introduction .................................................................................................................. 5
2. Objective ...................................................................................................................... 5
3. Methodology and Outcomes ......................................................................................... 5
4. Conclusion ................................................................................................................. 10
5. Recommendations ..................................................................................................... 11
6. Acknowledgments ...................................................................................................... 12
Annexure A: Request for information letter ............................................................................ 13
Annexure B: Highlighted changes ......................................................................................... 15
Annexure C: Comparison with International Best Practice .................................................... 46
Annexure D: Printable Version of the operations manual ...................................................... 52
Annexure E: Recommended editorial corrections .................................................................. 53
Abbreviations and Nomenclature

ASPASA Aggregate and Sand Producers of Southern Africa
COP Code of Practice
DMR Department of Mineral Resources
GEE Group Environmental Engineers
HEG Homogeneous Exposure Group
MHSC Mine Health and Safety Council
MHSI Mine Health and Safety Inspectorate
MOHAC Mining Occupational Health Advisory Committee
OEL Occupational Exposure Limit
OHTTT Occupational Health Technical Task Team
SAMRASS South African Mines Reportable Accidents Statistical System
SANAS South African National Accreditation System
SANS South African National Standards
SAMOHP South African Mines Occupational Hygiene Programme
TWA Time weighted average
Executive Summary

The MHSC requested the development of an operations manual for the revised guideline.
The revised guideline was compared with the current guideline. Besides the editorial
changes, there were a few aspects that will have a significant impact on the mines, e.g.
Homogeneous Exposure Group (HEG) classification based on statistical analysis as this
may result in a significant increase in sample volumes. The revised guideline compares well
with International Best Practice; however, there are areas for improvement that will aid
standardisation across the industry.
Feedback was obtained from all stakeholders to determine where the problem areas were
with the current guideline. Specific areas were highlighted, such as the classification of
HEGs, statistical analysis, reporting, etc. This information was used to develop the
operations manual with practical examples and to provide guidance on how to address
certain aspects of the guideline. The operations manual was not aimed at being prescriptive,
or to provide training on the relevant disciplines (i.e. occupational hygiene), revise the
guideline or to contradict current mandatory requirements.
Feedback was also received on matters of principle that are not addressed by the guideline,
SAMOHP or the associated regulations (e.g. no category for exposures below 10% of the
Occupational Exposure Limit (OEL).
The outcome of the project was an electronic (i.e. eBook) operations manual with two
examples of printable versions. The manual contains practical examples and video tutorials
to assist the end-user of the revised guideline. The electronic manual may be accessed at
https://www.dropbox.com/sh/ntvslljf3f699pr/AACrBdZVoehrSOI24A45CeyOa?dl=0
Please note that this link expires 31 March 2016 after which the operations manual will only
be available from the MHSC.
1. Introduction
The Mining Occupational Health Advisory Committee (MOHAC) of the Mine Health and
Safety Council (MHSC) requested that an operations manual be developed for the revised
“Guideline for the compilation of a mandatory code of practice for the assessment of
personal exposure to airborne pollutants”. The need for such a manual arose because there
are different ways in which the current guideline is being interpreted by end-users. The
result is that codes of practices for personal exposure to airborne pollutants are not
standardised across the South African mining industry.
2. Objective
The objective of this project was to develop an operations manual that will be issued with the
revised “Guideline for the compilation of a mandatory code of practice for the assessment of
personal exposure to airborne pollutants” (herein referred to as “revised guideline”). The aim
of the manual was to assist the end-user of the revised guideline to develop a code of
practice for the assessment of personal exposure to airborne pollutants (herein referred to
as “Code of Practice (COP)”).
It was intended that the end-result would be a standardised implementation of the Code of
Practice.
3. Methodology and Outcomes
In order to achieve the objective of the project, the following methodology was followed:
a. Obtain feedback on current challenges
In order to develop an operations manual it was necessary to determine where the
challenges were with the current “Guideline for the compilation of a mandatory Code of
Practice for an occupational health programme on personal exposure to airborne pollutants”
(herein referred to as “current guideline”). A letter was sent through the MHSC requesting
information from all stakeholders (Annexure A).
The research team arranged meetings with the Department of Mineral Resources (DMR),
the Group Environmental Engineers (GEE) and the Aggregate and Sand Producers of
Southern Africa (ASPASA). At the meetings the scope and nature of the project were
discussed and the following information was requested:
 Participants were requested to be specific about the challenges that they faced when
using the current guideline for the development of a code of practice for airborne
pollutants.
 Mines were requested to provide copies of their current codes of practice for review
by the research team.
 Where audits were conducted on the current code of practice by an external party,
copies of these audits were requested.
 The Mine Health and Safety Inspectorate (MHSI) was requested to specify what
problems they encountered during audits.
 The MHSI was requested to provide copies of their code of practice audit reports for
review by the research team.
In addition to the above, it was requested that a small task team from each party was made
available to the research team. The purpose of the small task teams was to assist with the
piloting of the manual.
The team received feedback from the DMR on seven large-scale mining operations, four
from ASPASA and none from Labour. The request was re-submitted and the deadline for a
response was extended to the end of June 2015 as it was important that the feedback we
received was representative of the industry.
In general, the following challenges regarding the current guideline were highlighted:
 The current guideline was open to interpretation;
 Classification of HEGs and assessing their validity;
 Statistical analysis of data and the subsequent interpretation;
 Dose allocation;
 Linkage of occupational hygiene data with medical records; and
 Reporting of personal exposure measurements.
The research team also received some comments that were not related to the
implementation of the guideline, but to principles that were not addressed in the guideline or
the associated regulations. For example:
 The HEG re-classification is done annually and does not accommodate any changes
in personal exposure throughout the year. For example, when the statistical analysis
reveals that there are two categories in one HEG, the HEG cannot be re-classified in
the middle of the year. This has an impact on the sampling strategy and reporting of
exposure.
 The lack of time (i.e. one month) between the annual assessment of the HEGs and
the re-classification of HEGs and the review of the sampling schedule of the next
year. This can be quite a complex task when the workforce population is large (e.g.
30 000 employees).
 Dose allocation done during quarterly reporting compared to when it is done during
progressive reporting.
 How to treat exposure measurements that are below 10% of the OEL since there is
not a category for this classification band.
 How to accommodate short-term contractors, i.e. temporary employees who are
employed for only two weeks or three months, for example. Again, the sampling
schedule cannot be changed frequently, and for consistency of the system, these
employees are probably not included.
 Linking of medical surveillance when not all employees are linked to a HEG,
especially when exposure is below 10% of the OEL.
During the next revision of the guideline, these points may have to be considered for
inclusion.
b. Highlight amendments in revised guideline
The revised guideline was compared with the current guideline to show the end-user where
changes were made. Please refer to Annexure B for detailed records on the sections that
were reworded, removed or newly included in the revised guideline. A summary of the
changes made in the revised guideline is given below:
 Minor editorial changes throughout the document;
 Changes to some of the definitions;
 A section included under the Occupational Hygiene Programme (control, linking to
medical surveillance and training);
 Section 8.2 on Occupational Medical Surveillance was removed;
 Annexures A – C were included from the SAMOHP Codebook; and
 Annexure D was updated with new references.
Some of the changes to the revised guideline that will have a significant impact on the end-
user are:
 The legal implications now that the implementation of the Code of Practice (COP) as
developed by the mine is mandatory.
 The revised definition of the HEGs now states that it should be based on statistical
evaluation.
 Risk assessment and control: taking the new definition of HEGs into account and the
stipulated conditions for the review of risk assessment.
 Determination of HEGs: SAMOHP Codebook information is included in this section
(step-by-step). Baseline risk assessment is to be used to identify HEGs and the
rewording of the criteria for the revision of the HEG classification.
 Personal exposure monitoring: representative employee exposures within a shift and
between shifts should not be combined. There will be a cost implication for the
volume of individual personal samples as per the new milestones.
 Sampling, analysis, methodology and quality control: the sampling strategy from the
SAMOHP Codebook is included in this section. Chemical analysis of individual
samples done by a SANAS-accredited laboratory (South African National
Accreditation System). Weighing laboratories do not have to be accredited.
 Reporting and recording are mandatory according to the requirements of the
guideline.
 Personal exposure measurements will be linked to medical records.
 Employees to be trained on specific issues identified.
 Some of the documents that were listed in Annexure D of the guideline could not be
found via a search on the Internet.
The research team wanted to understand why some of the changes had been made and
requested the minutes of the Occupational Health Technical Task Team’s (OHTTT)
meetings. However, the minutes did not contain justifications for the changes. The
stakeholders were consulted but no substantiating information could be provided to the
team. As a result, no explanations were given in the manual for the reasons of the changes.
One of the aspects that required confirmation was the continuation of the SAMOHP
Codebook. During the revision of the current guideline, the intention was to discontinue the
SAMOHP Codebook and adopt relevant information in an operations manual for the revised
guideline. However, since the completion of the revision there have been some concerns
about the discontinuation of the SAMOHP Codebook. The Codebook contains information
that is not captured in the guideline or the associated regulations, e.g. commodity and
pollutant codes. The SAMOHP also contains information that is relevant to Noise and
Thermal Stress.
The research team requested confirmation from the Mining Occupational Health Advisory
Committee (MOHAC) on the status of the SAMOHP Codebook. At a meeting held on 30
September 2015, the MOHAC made a decision that the SAMOHP Codebook would be
continued. However, it was decided that the SAMOHP should be reviewed as soon as
possible to update the reporting periods and the reporting forms to align the occupation
codes with SAMRASS (South African Mines Reportable Accidents Statistical System) codes
and to revise the document in general.
When the revised guideline was compared to the current guideline, some minor editorial
errors were found. It would be advisable to correct these minor editorial errors in the revised
guideline prior to its release. Recommendations on these corrections can be found in
Annexure E.
c. Compare revised guideline with International Best Practice
The revised guideline was compared with International Best Practice. Similar guidelines and
international standards were sourced for the comparison. The following international
documents were used:
 The Occupational Exposure Sampling Strategy Manual (OESSM) from the National
Institute of Occupational Safety and Health (NIOSH) of the USA.
 The Sampling Guide for Air Contaminants in the Workplace of the Institut de
recherche Robert-Sauvé en santé et en sécurité du travail (IRSST) in Canada.
 The European standard EN 689 “Workplace atmospheres — Guidance for the
assessment of exposure by inhalation of chemical agents for comparison with limit
values and measurement strategy”.
 Guidance on the interpretation of workplace exposure standards for airborne
contaminants from SafeWork Australia.
 ISO 18158 “Workplace air — Terminology”.
 BOHS/NVVA Sampling Strategy Guidance – Testing Compliance with Occupational
Exposure Limits for Airborne Substances (UK and the Netherlands).
 Good Practice Guidance on Occupational Health Risk Assessment from the
International Council on Mining and Metals (ICMM).
Please refer to Annexure C for a detailed comparison. For the purposes of this report, a few
matters are highlighted:
 Some guideline definitions are either lacking or the definitions are not in ISO/DIS
18158. There is scope to include more detailed definitions in the revised guideline.
 The DMR revised guideline does not provide enough statistical data to enforce
decisions on the accuracy and variability of the measured exposures and there is a
lack of guidance on the interpretation of the data.
 Although the risk assessment steps are specified in the revised guideline, the sample
size is not specified when compared to international best practice. However, the
revised guideline does specify the sample size for continuous monitoring.
 Some international documents contain specific information on airborne pollutants
such as their OELs, how to sample, which analysis methods to use and any
additional information that is relevant to the user. This leads to standardised
implementation in the countries that make use of this guideline.
 One of the international documents provided very good statistical explanations and
examples. The document provides information on how to statistically evaluate the
validity of the HEGs and also when to repeat the baseline risk assessment. This
document also guides the user on how to deal with analysis values below the limit of
detection.

During the next revision of the guideline, these documents may provide information for
consideration.

d. Develop Operations Manual
The intention was to develop an operations manual for the revised guideline that would give
end-users sufficient supporting information to allow them to develop a COP for their
respective mining operations. The revised guideline was included in the operations manual
so that the end-user would have all the information at hand when using the manual.
The approach was to develop an electronic, web-based manual that can be operated off-line
(i.e. without Internet access) and stored on a CD or other portable device. Where possible,
several examples were given, video tutorials were included to explain complex matters and,
where relevant, references to reputable standards were provided.
Three examples of the operations manual were completed:
 The following link contains the completed operations manual in electronic (i.e. eBook)
format:
https://www.dropbox.com/sh/ntvslljf3f699pr/AACrBdZVoehrSOI24A45CeyOa?dl=0
 A printable version was created and is available in Annexure D.
The scope to develop the operations manual did not include:
 The training of occupational hygienists, ventilation officers or engineers on the
principles of their respective disciplines;
 The revision of the revised guideline;
 Being prescriptive of every aspect of the guideline for every type of mining operation;
 Information that may contradict what was contained in the guideline, associated
regulations or the SAMOHP Codebook.

e. Informal piloting and testing of the manual
At the start-up presentation of this project, MOHAC requested that the research team should
conduct an informal piloting of the operations manual to obtain inputs from all stakeholders.
Throughout the project there were interactions with the different stakeholders and inputs
were requested from various parties. The draft manual was presented to the DMR and the
GEEs in separate sessions. ASPASA received the draft manual via e-mail as a meeting
could not be arranged in time.
The DMR had six representatives at the session and each of them received a copy of the
operations manual on CD. The comments received from the DMR and the research team’s
responses are as follows:
 The tutorials should be separate from the guideline
Response: the guideline content was included for ease of use by the end user.
 More explanation on how the guideline should be implemented e.g. how files should
be “readily available”
Response: It was requested that the MHSI specify their requirements. But Section 6
discusses Quality Control Systems that may be implemented to ensure that
documents are ‘readily available’ during audits.
 Uniform methodologies should be specified especially how to do biological
monitoring
Response: Section 8.1.2 Step 3 guides the user to standard methodologies that may
be used for different airborne pollutants. Biological monitoring is not within the scope
of the revised guideline but in the Guideline for Medical Surveillance.
At the GEEs session there were 16 representatives from various South African mining
operations. All of them were given CDs of the draft operations manual. The following
comments were received from one mine and the research team responded as follows:
 HEG determination is still open for interpretation
Response: Examples of HEGs for different commodities were included in the HEG
tutorial to assist users. In addition, the statistical analysis method is described in
detail and should be done at the end of the sampling cycle to refine the HEG
classification.
 Not sufficient guidance on the number of samples that should be sent for quartz
analysis
Response: In Reporting Tutorial 9 it is explained that all the samples that are
included in the sampling schedule for quartz, should be analysed for quartz.
 Which percentage of quartz to use for the dose allocation; the current year or the
previous year’s percentage?
Response: The percentage quartz of an individual sample should be calculated and
allocated to the individual sample only. This is explained in Reporting Tutorial 9.
 Quality of the tutorial videos
Response: The Reporting videos were professionally recorded after the piloting
stage.
 The headings of the Reporting Forms are not clearly explained and are interpreted
differently by the users.
Response: Reporting Tutorial 8 discusses each heading and guides the end user
through the completion of the form.
 Milestone reporting and how it should be done
Response: The Milestones are not covered by the guideline and should be
addressed through the Mine Health and Safety Summit structures.

The draft manual was sent to ASPASA after the DMR and GEE sessions and an extended
deadline was granted. Unfortunately, no comments were received from them either.

4. Conclusion
The MHSC requested the development of an operations manual for the revised guideline.
The revised guideline was compared to the current guideline. Besides the editorial changes,
there were a few aspects that will have a significant impact on the mines, e.g. HEG