Published on UQ Policy and Procedures Library (https://ppl.app.uq.edu.au)
Hom e > C arcinogens: Managing C om pliance with Prohibited and Restricted - Procedures
Carcinogens: Managing Compliance with
Prohibited and Restricted - Procedures
Document Number:
2.70.11b
Topic:
2.70.11 Carcinogens: Manage Compliance of Prohibited and Restricted [1]
Approval Authority:
Director Occupational Health and Safety
Audience:
All Staff
All Students
Keywords:
mutagenic
carcinogenic chemicals
cytotoxic
Document Web Links:
Chemwatch: SDS database [2]
Work Health and Safety Regulation 2011 [3]
Application for authorisation to use, handle or store prohibited or restricted carcinogens (Form 74)
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[4]
1. Purpose and Objectives
The purpose of this document is to provide the University of Queensland with the process to manage
compliance with the Prohibited and Restricted Carcinogen legislation documented in the Queensland
Work Health and Safety Regulation 2011.
2. Definitions, Terms, Acronyms
Chemwatch - Is a proprietry database used by the University of Queensland to access safety data sheets
and other information to control chemical risks.
Hazardous chemicals and hazardous materials - Chemicals and other materials that can cause harm
to workers and other people, property or the environment through fire, explosion, reaction or release.
Restricted Carcinogen - Prohibited and Restricted Carcinogens as defined by Schedule 10.1 and 10.2
of the Queensland Work Health and Safety Regulation 2011 and duplicated in section 7.1.1 of this
procedure.
Risk Management - Coordinated activities to direct and control an organisation with regard to risk.
Risk Management Database – The University of Queensland online database for recording standard
and chemical risks, control measures, training requirements and other details relevant to risk
management. The database includes a risk management console tab for detailing and recording a risk
assessment.
Risk Control - Taking action to eliminate health and safety risks so far as is reasonably practicable, and
if that is not possible, minimising the risks so far as is reasonably practicable. Eliminating a hazard
should be the first consideration in managing risks associated with a hazard.
SDS - Safety data sheet. A document containing information on the health, safety and environmental
aspects of a material or chemical for the purposes of storing, using and disposing of the substance in a
safe way.
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WHSQ - Workplace Health and Safety Queensland
Workers - Under the Work Health and Safety Act 2011, includes any person who undertakes work, in any
capacity, in or as part of a business or undertaking (e.g. an employee, a contractor or subcontractor, an
employee of a contractor or subcontractor, an employee of a labour hire company who has been assigned
to work in the person’s business or undertaking, an outworker, an apprentice or trainee, a student gaining
work experience, a student performing work on behalf of the University, and a volunteer).
3. Guidelines Scope/Coverage
This procedure applies to all UQ staff, research students and other personnel working within UQ facilities
to which the Prohibited and Restricted Carcinogen legislation applies. This document will define the
processes to use, handle or store restricted and prohibited carcinogens stated in the Queensland Work
Health and Safety Regulation 2011, Division 8, parts 381 & 384 to 388 (inclusive).
The procedure applies to prohibited carcinogens and restricted carcinogens that meet the restricted use
criteria. See section 7.1.1 of this procedure for a list and classification criteria for these carcinogens.
4. Guidelines Statement
This procedure for working with carcinogens ensures the following:
Compliance with all health and safety legislation including the recording and provision of a
statement of exposure for the carcinogen that the worker may have been exposed to.
Exposure to all workers who handle, store and use the carcinogen is eliminated, or if this is not
practicable, then exposure minimised to ensure the workers health and safety is not affected.
5. Responsibilities and Accountabilities
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5.1 The OHS Division of UQ is Responsible for Ensuring
That a system is in place to ensure copies of the employee records detailing possible exposure to
prohibited or restricted carcinogens are maintained for 30 years.
That a system is in place to facilitate a ‘letter of exposure’ provided to workers at the end of their
engagement, detailing the names of prohibited or restricted carcinogens the worker may have been
exposed to and the time of this possible exposure, in accordance with section 6.6 of this procedure.
5.2 Managers, Supervisors and Principal Investigators are
Responsible for Ensuring
That suitable information, training and instruction, including induction and on-going training, must
be provided to a worker who may possibly be exposed during the storage, use and handling of the
prohibited or restricted carcinogen.
That all prohibited or restricted carcinogens are authorised according to the Work Health and Safety
Regulation 2011.
That all requirements identified in the risk assessment and relevant UQ policies, procedures and
guidelines are complied with.
That all usage and tracking requirements as defined in the risk assessment and relevant UQ
policies, procedures and guidelines are complied with.
That a record detailing the name of the prohibited or restricted carcinogen the worker may have been
exposed to and the time of this possible exposure is compiled and added to the employee’s staff file
on completion of the project or work within that laboratory, transfer to another position or completion
of engagement as an employee within the organisation.
Where workers not employed by UQ have been working with the carcinogen, a record detailing the
name of the prohibited or restricted carcinogen the worker may have been exposed to and the time of
this possible exposure is to be sent to the worker’s employer to retain on completion of the work. The
Faculty, Institute or School where the worker was engaged is responsible for implementing a system
for this.
Employee records detailing possible exposure to prohibited or restricted carcinogens are
maintained for 30 years.
A letter is provided to staff at the end of their engagement detailing the names of prohibited or
restricted carcinogens the worker may have been exposed to and the time of this possible exposure
in accordance with section 6.6 of this procedure.
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Note: The University Chemical Store will be responsible for ordering the chemical and must check that the
person ordering has the required authority. The store is not required to be an authority holder as any
store or transport activities undertaken will be for sealed packages where exposure cannot occur. A link
giving further information about the UQ Chemical Store is attached to this document.
5.3 All Workers are Responsible for Ensuring
That they comply with all of the requirements detailed in the risk assessment for the use, handling or
storage of the prohibited or restricted carcinogen.
6. Process
6.1 Overview of Compliance Requirements
Under the Restricted Carcinogen requirements of the Work Health and Safety Regulation a workplace must
not use, handle, or store, or direct a worker to use handle or store, a restricted carcinogen, unless the
regulator has authorised the use, handling or storage of the restricted carcinogen. To gain authorisation
there are specific requirements for induction and training, recording of spills and other events where
actual exposure was likely to occur, issuing of statements of exposure to workers, and record keeping.
Refer to the UQ OHS Division website for details of the responsibilities for these activities,
Carcinogens - Summary of Responsibilities
[5]
Note: this document deals with legislative compliance only. There is a specific procedure covering
general requirements for carcinogens and similarly related substances, e.g. cytotoxic drugs and
mutagenic chemicals. In most cases meeting legislative requirements detailed in this document will fulfil
the procedure requirements, with the exception of the National Health and Medical Research Council
approval process if this is applicable to the research work being undertaken. The procedure document
can be referred to for further information,
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2.70.10 Carcinogens Safety Procedure
[6 ]
6.2 Induction and Training
The induction, information and training provided must include the following:
Labelling of containers of the carcinogen to ensure the carcinogen and other chemical hazards are
identified, along with reasons why the information on each part of the label has been provided.
How to locate and use an SDS using Chemwatch, along with accessing and interpreting information
contained in each part of the SDS.
The nature of the hazards and properties of the carcinogen to which workers are or may be exposed
including routes of entry into the body and potential health risks.
Safe work practises to be followed when using, handling, storing, cleaning up and disposing of the
carcinogen.
Measures used to control exposure to the carcinogen including the correct use and maintenance of
these controls. A sign must be displayed within the work area when the carcinogen is in use. Refer
to Form D - Template: ' Carcinogen in Use' sign [7] [docx] for an example of a suitable sign.
The proper use, fitting and maintenance of personal protective equipment (PPE).
Ensuring workers are competent in emergency procedures, including evacuation and special
decontamination procedures.
Ensuring workers are competent and aware of first aid and incident reporting procedures to be
followed in the case of exposure, injury or illness.
Reasons for air monitoring (if required), type of monitoring used and how to obtain the results from
any monitoring conducted.
Reasons for health surveillance (if required) and the type of surveillance used.This training must be
provided to staff, students, contractors or volunteers working with the carcinogen. Refresher training
is also required.
6.3 Application for Authorisation to Use, Handle or Store Prohibited or Restricted
Carcinogens
Where a prohibited carcinogen is to be used, handled or stored or where a restricted carcinogen is to be
used, handled or stored for a purpose mentioned in column 3 (see table 10.2, section 7.1.1), an
authorisation to use, handle or store must be obtained by the principal researcher using Form 74, which
includes a guide on the information that must be provided:
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Form 74 Application for authorisation to use, handle or store prohibited or restricted carcinogens.
Completion of this application requires the following information to be compiled:
Hazardous Chemicals Risk Assessment. The risk assessment must be comprehensive and include all
information as detailed in the following checklist: Form A - Risk Assessment Checklist [8] [docx].
Completion of the support document: Form B - Detail for Workplace Health & Safety Qld [9] [docx]
for submission with Form 74 [4] [pdf] that is sent to WHSQ.
Completion of Form 74.
Method of tracking usage: Form E -Template: Carcinogen Usage Log [10 ] [docx].
Method of recording possible exposure to the carcinogen - usually the UQ injury, illness, and
incident reporting system database.
Method for recording and communicating possible exposure to the carcinogen to workers (as
detailed in sections 6.4, 6.5 and 6.6 of this procedure).
When the authorisation from WHSQ is obtained this form is to be completed and forwarded to the
Occupational Health and Safety Division Form C - Details for UQ OHS Division [11] [docx].
6.4 Tracking Carcinogen Usage
A process must be documented to track the usage according to the requirements specified in the risk
assessment.
To track individual worker’s possible exposure to the carcinogen the minimum data to be stored is:
Name of carcinogen the worker may have been exposed to (and concentrations if applicable).
Date of this possible exposure to the carcinogen (or start and end dates).
Full name of worker
Date of birth Address
To track usage of the carcinogen the following records must be kept:
Name of carcinogen
Date of use
Quantity
Full name of worker
Date of birth of worker, or Aurion [12] Number to complement identification along with name.
Any incident involving actual exposure to the carcinogen.
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Recoding carcinogen usage on the Risk Management database:
The UQ risk management database has a tick box for flagging the use of a restricted carcinogen, and
this needs to be checked along with the completion of the field in the risk assessment for entering
the WHSQ authorisation number.
Establishment of a carcinogen record on UQ Aurion
Database:
[12]
employment database & Occupational Health
Once the Users-Form C is received by the Occupational Hygiene Advisor at OHS the risk assessment and
other supporting documentation will be reviewed and the file submitted to Occupational Health section of
OHS.
An Occupational Health admin officer will enter the details on Aurion [12] and create a carcinogen
record on the OHS Health Surveillance database. The Aurion [12] record ensures that when an
exposed individual ceases employment their departure can be identified and a letter of exposure
generated. The Health Surveillance database records all usage details of the exposed person along
with their employment history. This record may contain the relevant exposure history for multiple
carcinogens the individual has used while employed at UQ.
Guidance on record keeping for carcinogen usage:
Only UQ employees are on the UQ Aurion [12] database and there is no provision for entering non-UQ
employees onto the database. Therefore, for students, visiting scholars and some research higher
degree people working with carcinogens, but not directly employed by UQ; the responsibility for
notifying OHS Division that work has ceased will be the supervisor or the Workplace Health and
Safety Co-ordinator for the facility where the work is being undertaken. Procedures should be in
place within the facility to ensure this occurs.
The usage logs for a carcinogen are valuable for documenting individual exposure and it is
recommended that they be kept in hardcopy for a period of 10 years. When and individual ceases
work or leaves employment at UQ. Copies of the usage logs should be submitted to the OHS Division
where they will be attached electronically to the Health Surveillance Database. It would also be
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valuable to give consideration to attaching electronic copies of the logs on a regular basis to the
carcinogen process risk assessment on the risk management database.
6.5 End of Period of Possible Exposure to the Carcinogen
At the end of an employee’s period of possible exposure to the carcinogen (e.g. by end of engagement,
end of project or transfer to another area), a record of the carcinogen the worker may have been exposed
to and the time of this potential exposure must be submitted by the Principal Researcher of the Faculty,
Institute or School where the worker was engaged to the OHS Division for inclusion with the employee’s
personnel file.
For workers not employed by UQ a record of the carcinogen the worker may have been exposed to and the
time of this potential exposure must be supplied to their employer to maintain according to their system to
comply with the Queensland Work Health and Safety Regulation 2011.
This record of possible exposure to the carcinogen must include:
A copy of the authorisation to use, handle or store a prohibited or restricted carcinogen.
The name of the prohibited or restricted carcinogens the worker may have been exposed to.
Start and end date of this possible exposure to the carcinogen.
How and where the worker may obtain records of the possible exposure.
Whether the worker should undertake regular health assessments and the relevant tests to
undertake.
6.6 Compilation of End of Engagement Letter
At the end of their engagement the Occupational Health and Safety Division will supply to an employee
who has used, handled or stored a prohibited or restricted carcinogen a letter detailing:
The name of the prohibited or restricted carcinogen they may have been exposed to.
The time when they may have been exposed.
How and where they may obtain records of the possible exposure.
Whether the worker should undertake regular health assessments, and the relevant tests to
undertaken.
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It is important this statement of exposure is issued by the Occupational Health and Safety Division only.
The statement must be signed by the Director of the OHS Division. The template for statement of
exposure is not included in this procedure.
A copy of the signed statement will be uploaded into the OHS ‘carcinogen use’ database and a copy will
also be entered into UQ employee records.
7. Application Guidance
7.1 Carcinogenic Chemicals to which this Document Applies
7.1.1 Tables from Schedules 10, Tables 10.1 and 10.2, Work Health and Safety
Regulation 2011
Table 10.1 Prohibited carcinogens
Item
1
Prohibited carcinogen [CAS number]
2-Acetylaminofluorene [53-96-3]
2
Aflatoxins
3
4-Aminodiphenyl [92-67-1]
4
Benzidine [92-87-5] and its salts (including benzidine dihydrochloride [531-85-1])
5
5
bis(Chloromethyl) ether [542-88-1]
6
Chloromethyl methyl ether [107-30-2] (technical grade which contains bis(chloromethyl) ether)
7
4-Dimethylaminoazobenzene [60-11-7] (Dimethyl Yellow)
8
2-Naphthylamine [91-59-8] and its salts
9
4-Nitrodiphenyl [92-93-3]
Table 10.2 Restricted carcinogens
Restricted carcinogen
Item
[CAS number]
Restricted use
1
Acrylonitrile [107-13-1]
All
2
Benzene [71-43-2]
All uses involving benzene as a feedstock
containing more than 50% of benzene by volume
Genuine research or analysis
3
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Cyclophosphamide [50-18-0]
When used in preparation for therapeutic use in
hospitals and oncological treatment facilities, and
in manufacturing operations
Genuine research or analysis
4
3,3' -Dichlorobenzidine [91-94-1] and its
salts (including 3,3' -Dichlorobenzidine
dihydrochloride [612-83-9])
All
5
Diethyl sulfate [64-67-5]
All
6
Dimethyl sulphate [77-78-1]
All
7
Ethylene dibromide [106-93-4]
8
4,4' -Methylene bis(2-chloroaniline) [10114-4] MOCA
All
9
3-Propiolactone [57-57-8] (Betapropiolactone)
All
10
o-Toluidine [95-53-4] and o-Toluidene
hydrochloride [636-21-5]
All
When used as a fumigant
Genuine research or analysis
6
11
Vinyl chloride monomer [75-01-4]
All
8. Contacts for Further Information
Occupational Hygiene Advisors:
[email protected]
[13]
University of Queensland Chemicals Store:
https://chemstore.science.uq.edu.au/LoginStore.aspx
[14]
telephone extension 51418, 52345, or 52528;
e-mail at [email protected]
All Staff
[15]
carcinogenic chemicals
cytotoxic
mutagenic
All Students
Source URL (retrieved on 2014-06-30 16:02): https://ppl.app.uq.edu.au/content/carcinogens-managing-compliance-prohibited-andrestricted-procedures
Links:
[1] https://ppl.app.uq.edu.au/content/2.70.11-carcinogens-manage-compliance-prohibited-and-restricted#Procedures
[2] http://www.uq.edu.au/ohs/?page=141354
[3] https://www.legislation.qld.gov.au/LEGISLTN/CURRENT/W/WorkHSR11.pdf
[4] http://www.deir.qld.gov.au/workplace/resources/pdfs/form74-appfor-carcinogens.pdf
[5] http://www.uq.edu.au/ohs/carcinogens-summary-of-responsibilities
[6] http://ppl.app.uq.edu.au/content/2.70.10-carcinogens-safety
[7] http://www.uq.edu.au/ohs/PPL/2-70-11/FormD.docx
[8] http://www.uq.edu.au/ohs/PPL/2-70-11/FormA.docx
[9] http://www.uq.edu.au/ohs/PPL/2-70-11/FormB.docx
[10] http://www.uq.edu.au/ohs/PPL/2-70-11/FormE.docx
[11] http://www.uq.edu.au/ohs/PPL/2-70-11/FormC.docx
[12] Glossary: Aurion - The University's Human Resource Management System
[13] mailto:[email protected]
[14] https://chemstore.science.uq.edu.au/LoginStore.aspx
[15] mailto:[email protected]
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