Association for Occupational
Hygiene Approved Inspection
Authorities NPC
AIA and Exposure Data Collection
By:
Jaco van Rensburg
Or more specific, what is an Occupational Hygiene (OH) AIA?
The Occupational Health and Safety Act, 1993 (Act No. 85 of 1993), defines an
Approved Inspection Authority as:
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“any person who with the aid of specialised knowledge or equipment or
after such investigations, tests, sampling or analyses as he may consider
necessary, and whether for reward or otherwise, renders a service by
making special findings, purporting to be objective findings, as to:
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the exposure of any person,
the safety or risk to health of any work, article, substance, plant or machinery, or
any condition prevalent on or in any premises
the question of whether any particular legislated standard has been or is being
complied with, …………., and by issuing a certificate, stating such findings, to the
person to whom the service is rendered.”
…………., an Inspection Authority can only operate if it has been
approved by the Chief Inspector (of the DoL). The AIA with respect
to any particular service shall be an Approved Inspection
Authority with respect to that service only.
DoL’s explanatory notes on the above: “The meaning of a
“certificate” should also be read as a report/statement/certificate
as pertaining to each specific situation“.
Actually, DoL has very strict requirements on the format and
contents of an Occupational Hygiene Survey Report, issued by and
AIA – and it goes way beyond the traditional understanding of a
“certificate” – “Scientific Report” is probably the only and best
fitting term to use in this context.
What is required to become an OH AIA?
An inspection authority, which has the necessary competency in the field of
occupational hygiene monitoring and has the appropriate facilities and
equipment, may apply…..
Very Important - The use of the term “monitoring” (according to DoL) means
more than just measuring an occupational hygiene stress factor.
It includes the collection (and thus recording) of data associated with a
measurement:
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Identification of workplaces which could cause or exacerbate adverse health
effects
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Measurement of prevailing conditions
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Scientific interpretation of those measurement results
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Evaluation of the potential impairment of health or well-being
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Formulation of recommendations for alleviation of such problems.
Any application to the Dol for approval will, in general, be
evaluated in terms of the following:
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must hold a certificate of accreditation from the South African National
Accreditation System (SANAS) – i.e. SANS 17020:2012;
Personnel must be currently registered with a professional occupational
hygiene organisation recognised by the Chief Inspector (e.g. SAIOH);
Personnel must hold a valid legal knowledge certificates;
The AIA must have the basic suitable monitoring and analytical equipment
pertinent to the service/s rendered;
The AIA must keep a logbook of calibration and maintenance schedules and
records for all relevant equipment for a period of five years
The AIA must have suitably documented, methods and procedures relating
to the regulated services they wish to render.
The AIA must have suitably documented record keeping and control system.
Regarding documentation (including records of
Inspection/OH Survey data), DoL requires that:
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the OH AIA implements a quality management system in
accordance with SANS 17020;
A formal system is in place for indexing and retrieving all
reports and other records (i.e. data);
All records are kept secure and in confidence;
Procedures are in place to protect and back-up any data that is
held on computers.
The word “record” (or related terms; records, recorded) appears
19 times in SANS 17020 (the contents of document itself is less
than 18 pages) – recording of data and keeping of records (of data)
is thus extremely important to the OH AIA.
So why is DoL so obsessed with the
requirement that AIAs must record “data”
and keep records of that?
(also expressed through its requirement that AIAs must
be SANAS accredited)
Because - being DoL Approved, these reports
compiled by an OH AIA, on exposure measurements,
are “legal documents” and can be presented as
evidence in a court of law.
And, any evidence presented in a court of law, must be able to
withstand the “acid test”, meaning, one must be able to prove that
the result is a true reflection of that what it represents:
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one must be able to prove that the result obtained is “accurate”
– there must thus be a trail of evidence (recorded data) that can
prove that the correct methodology and procedures were
followed when the measurement was conducted (and that is
was conducted with the aid of valid, calibrated instruments);
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there must be a trail of evidence (recorded data), that can
“recall” the conditions under which the measurement was made
– exposure (and process) related conditions, as well as
environmental conditions;
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sufficient evidence (recorded data) to conclude whether the
measured exposure result is representative of “normal”
exposure conditions, or whether the reported result is
representative of higher or lower than normal exposure levels.
This type of “data” is thus very valuable; hence the requirement for
safe-keeping for extended periods of time.
It is further a requirement (as per SANS 17020) that all
data, in its raw form as well as results from calculations,
collected by one person, are checked and verified by
another person (of a higher competence level).
To that end, all AIAs have developed aides and tools to
ensure that for each measurement, sufficient data is
collected to be able to recall and re-trace (even at a
much a later stage), what was measured, how it was
measured, by whom, when, where, under which
circumstances, using which tools and verified by
whom……..the so-called “field data collection sheet”, as
well as standardized, validated Excel spreadsheets that
are used for calculations.
Exposure Data collected by an OH AIA must:
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be collected by a competent person (SAIOH registered professional),
be traceable to the person that collected the data,
be traceable to the person that reviewed the data and calculations,
be traceable to a specific result in a report,
accurately describe the equipment (traceable to their calibration
certificates) used in the processes and procedures followed to make the
exposure measurement,
be able to demonstrate that the correct measurement methodology was
followed correctly,
be able to accurately reflect where and when the measurement was
collected and for how long,
be able to “recall” the conditions that prevailed during the measurement,
be able to accurately recall the person who’s exposure level was
measured,
include sufficient detail to demonstrate that either no systematic errors
were incurred, or be able to conclude on the extent of the impact of such
“upset condition” on the result,
be stored safely, but also be easily retrievable.
Exposure data should be able to outlive the
person that collected it, so, it must be accurate
and detailed enough to ensure that the result
that it supports will be able to withstand the
“acid test”, even in the absence of the person that
actually performed the measurement.
The motto is (or should be); “It is impossible to
collect too much data (when conducting an OH
measurement), because as with many other
things in life, it is better to have too much and not
need all of it, than to need it (to withstand the
acid test) and not have enough”.
Association for Occupational Hygiene
Approved Inspection Authorities
Reg. No.:2014/212083/08 NPC
Vat Registration: Not VAT Registered
PO Box 7211
Centurion
0046
[email protected]