Faculty of Science
Prohibited and
Notifiable Carcinogens
Procedure
Version
1.0
TRIM file number
09/13607
Faculty Science Document
Number
Short description
Procedure outlines how prohibited and notifiable
carcinogens are managed appropriately.
Relevant to
CSU staff, students and researchers
Authority
This Procedure has been approved by [Dean,
Faculty of Science] under the Governance (Policy
and Procedures) Rule 2005 of the Council and
sections 20 and 32 of the CSU Act.
Responsible officer
Manager, University Laboratories
Responsible office
Faculty of Science, Office
Date introduced
01 August 2011
Date(s) modified
August 2011
Next scheduled review date
August 2014
Related University documents
CSU Occupational Health and Safety Policy
CSU Risk Management Policy
CSU Privacy Management Plan
FSc Risk Assessment Procedure
Related legislation
OH &S Act 2000 and Regulation 2001,
Privacy Act 1988,
Privacy and Personal Information Protection Act
1998 (NSW)
National Model Regulations for the Control of
Scheduled Carcinogenic Substances
[NOHSC:1011(1995)]
Control of Scheduled Carcinogenic Substances
[NOHSC:2014(1995)] NCoP
Approved Criteria for Classifying Hazardous
Substances [NOHSC: 1108]
Key words
Procedure, Workcover, carcinogen, prohibited,
notifiable, chemical, substance
Prohibited and Notifiable Carcinogens Procedure
Version 1.0 Effective 08/2011
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1.
PURPOSE
In accordance with the CSU Occupational Health and Safety Policy, the CSU
Risk Management Policy, the Occupational Health and Safety Act 2000 and the
NSW Occupational Health and Safety Regulations 2001 the Faculty of Science
(FSc) shall provide a safe and healthy environment for staff, students, visitors
and contractors. Central to achieving this is the staff, students, visitors and
contractors understanding their duty of care responsibilities and the specialised
risk associated with the FSc Facilities. Prohibited and notifiable carcinogens are
a specialised risk. This procedure ensures all prohibited and notifiable
carcinogens are managed appropriately.
2.
SCOPE
All staff who intend to purchase prohibited and notifiable carcinogens (Appendix
1).
3.
PROCEDURE
3.1
Research
Consult the Workcover website:
• Guide for the notification of work involving Carcinogenic substances
• Guide for the work involving Carcinogens
3.2
Risk assessment
Complete an FSc risk assessment (see Risk Assessment Procedure). Some
considerations specific to prohibited and notifiable carcinogens include:
Eliminate if possible:
• is the use of a carcinogen essential or can it be eliminated
• can an alternative procedure be adopted to reduce exposure
• can an alternative substances be used
Minimise if elimination is not possible
• aim to minimise the use of the carcinogen
• minimise the quantity for purchase
• include waste disposal of the carcinogen or its by-products in the risk
assessment
Note - written approval and notification for intended acquisition and use of
prohibited and notifiable carcinogens must be obtained from:
• The Facility Manager
• Head of School
• Manager, University Laboratories (or delegate)
Notification of approval and intended use shall also be sent to:
• Manager, Occupational Health and Safety
Prohibited and Notifiable Carcinogens Procedure
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3.3
Notify Workcover
3.3.1
Initial application
The Authorised Person (specified on the risk assessment) must apply to
Workcover in writing at least 60 days in advance with information for each
substance and for each location at which it will be used. The carcinogenic
form is available on the Workcover website and the following information will
be required:
• name of substance
• quantity or proportion in product or preparation
• nature of the product or preparation (e.g. solid, liquid)
• estimated annual quantity of product or preparation required or used
• details of proposed use (e.g. manufacturing, therapeutic, research)
supplier declaration
• complete a risk assessment or the need to review a Risk Assessment
3.3.2
Hierarchy of Controls
Further documentation may be required, ensure consideration has been
given to:
• training and induction
• competence of persons handling the carcinogen
• engineering controls
• administrative controls particularly those to limit exposure
• monitoring and health surveillance
• risk register
• standard operating procedure of all aspects of handling the carcinogen
• the labelling, storage and containment of the carcinogen
• waste disposal procedures
• record keeping in line with legislative requirements
3.3.3
Ongoing Reporting
The written application for working with notifiable and prohibited carcinogens
to Workcover must be resubmitted by the Authorised Person if or when the
following occurs:
• change of location of work with a carcinogenic substance at a work site
(i.e. each laboratory)
• when a risk assessment has been reviewed
• when employees have been removed from their usual work activities due
to exposure
• where an adverse health surveillance result has been recorded
• every five years as renewal of a notification where the use of the
carcinogenic substance is continuous
Prohibited and Notifiable Carcinogens Procedure
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3.4
Purchasing
Purchasing shall be done through Labstore only and can proceed when:
•
•
•
3.5
written approval via the risk assessment process has been obtained from
the Facility Manager, Head of School and the Manager, University
Laboratories (or delegate).
written approval (i.e. the acknowledgement letter including the
Workcover reference number) has been received from Workcover
Workcover reference number will need to be provided to suppliers.
Record Keeping
A copy of Workcover acknowledgement letter shall be forwarded to:
• Manger, Occupational Health and Safety
• Manger, University Laboratories
• Head of School
• Facility Manager
The Notification Approval is valid for 5 years from the date of the Workcover
acknowledgement letter. If the carcinogenic substance is in continual use
beyond this date, then the notification must be renewed following the same
procedure as outlined above.
3.5.1
School/Unit record keeping
The Head of School must retain the documents included in table 1.
Documentation must also be saved to the CSU document management
system and forwarded to the Faculty Office.
Table 1
Type of record
The Prohibited and notifiable Application
form and Workcover acknowledgement
Risk Assessments for work with prohibited
and notifiable carcinogens
Training and Induction records for work with
prohibited and notifiable carcinogens
Any air monitoring or health surveillance
record (if applicable)
Record of each worker who has been or is
likely to be exposed to a prohibited and
notifiable carcinogen (including DOB, full
name and address)
3.5.2
Duration
30 years from when the application
was made
30 years from the last activity
30 years
30 years
30 years
Supplier Record Keeping
Suppliers have to keep invoices detailing supply of prohibited and notifiable
carcinogens for 5 years, including:
Prohibited and Notifiable Carcinogens Procedure
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•
•
3.6
the name and address of person supplied
the name and quantity of the substance supplied
Health Surveillance
Carcinogenic substances for which health surveillance is mandatory are
listed in Appendix 3, and all employees working with or exposed to any of
these should seek further information from the Manager of Occupational
Health and Safety.
3.6.1 Health surveillance should:
•
continue throughout the period of use of a scheduled carcinogenic
substance.
•
be repeated at the time of job transfer or termination of employment
•
always follow professional advice on whether to continue health
surveillance of employees after exposure to a scheduled carcinogenic
substance has ceased
3.6.2 Record keeping of health surveillance:
•
shall be in accordance with the CSU Privacy Management Plan, the
Privacy Act 1988 and the Privacy and Personal Information Protection
Act 1998 (NSW)
•
include the employee's date of commencement and termination, date
of birth and specify the periods of potential exposure to any scheduled
carcinogenic substance
•
include the employee's present and past job classification and area of
work
•
include the employee's previous employment records in relation to any
chemical exposure and medical condition where available.
3.7
Disposal
Disposal should be as per Risk Assessment and other relevant documents.
For further information consult the Facility Manager and/or the Chemical
Safety Committee.
3.8
Use of prohibited and notifiable substances without approval
If prohibited and notifiable substances are being used in the laboratory
without the required approvals:
•
Notify the Head of School, the Manager of University Laboratories
and the Facility Manager
•
Suspended all work
•
Work can not resume until all approvals are in place
4.0
APPENDICES
Prohibited and Notifiable Carcinogens Procedure
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1.
2.
3.
5.0
Notifiable carcinogenics
Prohibited carcinogenics
Notifiable and Prohibited Carcinogens for which Health Surveillance is
required.
Table of amendments
Version
number
0.1
0.2
0.3
0.4
0.5
1.0
Date
15/09/09
011009
26/10/09
August 2011
August 2011
August 2011
Short description of amendment
Draft
Adj as per K Munn
Ad per CS
Amendments K Kent
Amendments L Hawkins
version
Prohibited and Notifiable Carcinogens Procedure
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Appendix 1 - Prohibited carcinogens (clause 158 of the OHS regulation)
2-Acetylaminofluorene
Aflatoxins – except in foods where specifically permitted under
the Food Act 1989
4-Aminodiphenyl
Amosite (brown asbestos) – except for removal, disposal,
maintenance, encapsulation and enclosure purposes, and
situations where amosite occurs naturally and is not used for
any new application
Benzidine and its salts
(including benzidine dihydrochloride )
bis(Chloromethyl) ether
Chloromethyl methyl ether [ (technical grade which contains
bis(chloromethyl) ether)
Chrysotile (white asbestos) – except when:
• used for the purpose of research or analysis
• or being removed or disposed of
• or being handled for storage or stored awaiting disposal
• or encountered during non-asbestos mining
• or comprising or included in an item being used for the
purpose of a historical or educational display.
Crocidolite (blue asbestos) – except for removal, disposal,
maintenance, encapsulation and enclosure purposes, and
situations where crocidolite occurs naturally and is not used for
any new application
4-Dimethylaminoazobenzene]
2-Naphthylamine and its salts
4-Nitrodiphenyl
CAS
[53-96-3]
[92-67-1]
[12172-73-5]
[92-87-5]
[531-85-1]
[542-88-1]
107-30-2]
[12001-29-5]
[12001-28-4]
[60-11-7
[91-59-8]
[92-93-3]
For further information referring to the use of carcinogens other than those listed above,
refer to Guide for the work involving Carcinogens substances.
Prohibited and Notifiable Carcinogens Procedure
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Appendix 2 - notifiable carcinogens (from Workcover)
Acrylonitrile
Benzene -– when used as a feedstock containing more than 50%
of benzene by volume
Cyclophosphamide (cytotoxic drug) -– when used in preparations
for therapeutic use in hospitals and oncological treatment
facilities, and in manufacturing operations
3,3′-Dichlorobenzidine and its salts (including 3,3′ Dichlorobenzidine dihydrochloride)
Diethyl sulphate
Dimethyl sulphate
Ethylene dibromide– when used as a fumigant
4,4′-Methylene bis(2-chloroaniline) - MOCA
2-Propiolactone
o-Toluidine
o-Toluidine hydrochloride
Vinyl chloride monomer
Prohibited and Notifiable Carcinogens Procedure
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CAS
[107-13-1]
[71-43-2]
[50-18-0]
[91-94-1]
[612-83-9]
[64-67-5]
[77-78-1]
[106-93-4][101-14-4][57-57-8]
[95-53-4]
[636-21-5]
[75-01-4]
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Appendix 3 - Notifiable and Prohibited Carcinogens for which Health
Surveillance is required (From OHS 2001 Regulations clause 165)
Column 1
Column 2
Hazardous substance
Type of health surveillance
Acrylonitrile
Occupational and medical history
Demographic data
Records of personal exposure
Arsenic (inorganic)
Demographic, medical and occupational history
Exposure record
Physical examination with emphasis on the peripheral
nervous system and skin
Urinary inorganic arsenic
Asbestos
Occupational and demographic data
Medical interview
Records of personal exposure
Benzene
Occupational and medical history
Demographic data
Exposure record
Baseline blood sample for haematological profile
Cadmium
Demographic, medical and occupational history
Exposure record
Physical examination with emphasis on the respiratory
system
Standard respiratory questionnaire to be completed
Standard respiratory function tests including for
example, FEV1, FVC and FEV1/FVC
Urinary cadmium and β2-microglobulin
Chromium (inorganic)
Demographic, occupational and medical history
Physical examination with emphasis on the respiratory
system and skin
Weekly skin inspection of hands and forearms by a
competent person
Creosote
Demographic, occupational and medical history
Health advice, including recognition of photosensitivity
and skin changes
Physical examination with emphasis on the
neurological system and skin, noting any abnormal
lesions and evidence of skin sensitisation
Exposure record, including photosensitivity
Crystalline Silica
Completion of a standardised respiratory questionnaire
Standard respiratory function test, such as FEV1, FVC
and FEV1/FVC
Chest X-ray, full size PA view
Isocyanates
Occupational and medical history
Completion of a standardised respiratory questionnaire
Physical examination of the respiratory system and
skin
Standard respiratory function test, such as FEV1, FVC
and FEV1/FVC
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Lead (inorganic)
Medical and occupational history
Physical examination
Mercury (inorganic)
Demographic, medical and occupational history
Physical examination with emphasis on
dermatological, gastrointestinal, neurological and renal
systems
Urinary inorganic mercury
MOCA (4,4-Methylenebis (2chloroaniline))
Urinary total MOCA
Dipstick analysis of urine for haematuria
Urine cytology
Organophosphate pesticides
Occupational and medical history
Physical examination
Baseline estimation of red cell and plasma
cholinesterase activity levels by the Ellman or
equivalent method
Estimation of red cell and plasma cholinesterase
activity towards the end of the working day
Pentachlorophenol (PCP)
Demographic, occupational and medical history
Physical examination with emphasis on the skin, noting
any abnormal lesions or effects of irritancy
Urinary total pentachlorophenol
Dipstick urinalysis for haematuria and proteinuria
Records of personal exposure
Polycyclic aromatic
hydrocarbons
Exposure record, including photochemical skin burns
Demographic, medical and occupational history
Physical examination
Thallium
Demographic, medical and occupational history
Physical examination
Urinary thallium
Vinyl Chloride
Occupational and demographic data
Record of personal exposure
Prohibited and Notifiable Carcinogens Procedure
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