Environmental Hygiene

The mixing of glazes and the handling of dry clay may expose workers to crystalline silica dust, which is linked to silicosis – a serious lung disease. In compliance with the requirements of the Occupational Health and Safety Regulations 2017 (Part 4.5 – Crystalline silica) and the criteria referred to in regulation 319J(2), the department has determined that the crystalline silica processes undertaken as part of pottery ceramics classes across schools in Victoria are not considered to be high-risk crystalline silica work as defined in the Regulations.

Policy

The purpose of this policy is to prevent illnesses and injuries by identifying, assessing and controlling environmental hygiene risks associated with exposure to contaminants in schools (for example, mould, dust, radiation, gases and fumes).

Summary

• The Occupational Health and Safety (OHS) Act 2004 (Vic) requires the department to provide or maintain systems of work and a working environment that is, so far as is reasonably practicable, safe and without risk to health, including in relation to environmental hygiene.
• The principal and/or their delegate (as the local management representative) must manage the risks associated with environmental hygiene in the workplace by reducing exposure to contaminants (e.g. mould, dust, radiation, gases and fumes).
• Under the OHS Act 2004, employees while at work must take reasonable care for their own health and safety and the safety of others who may be affected by their actions or omissions.
• Central and regional offices provide a range of supports and services to assist principals and employees to be safe and well, including access to the OHS Advisory Service and local OHS regional officers, who can provide free advice on environmental hygiene management.
• The Environmental Hygiene Procedure must be followed and sets out the practical step-by-step instructions for implementing this policy.
• This policy forms part of the department’s OHS Management System, see OHS Management System (OHSMS) Overview for further information.

Details

The principal and/or their delegate, in consultation with the Health and Safety Representative (HSR) and employees, must ensure that:

• all potential contaminants in the school are identified and entered in the ‘Hazard Description’ column of the OHS risk register (XLSX) or equivalent
• all means of exposure are considered (for example, inhalation, ingestion, absorption or injection) when identifying potential contaminants (for example, inhaling mould spores)
• risks of exposure to contaminants are assessed:
  • to accurately determine the level of risk, specific workplace monitoring may need to be considered and the services of an occupational hygienist may be required — the OHS Advisory Service can provide advice
• where specific hazards have been identified from exposure to contaminants, controls are to be implemented and reviewed, and recorded in the OHS risk register or equivalent:
  • high risk work involving contaminants, such as the cleaning of mould, may require safe work procedures to be developed using the Safe Work Procedure Template (DOCX) — the OHS Advisory Service can provide advice.

In some scenarios, there may be advice provided to the principal or their delegate by the OHS Advisory Service, central or regional offices to implement monitoring of contaminants. The school will be supported to implement section 2 of the environmental hygiene procedure. As the local management representative, the principal or their delegate must ensure that:

• monitoring is organised so that it is specific to the contaminant and route of exposure
• personal monitoring rather than static monitoring is conducted to define potential exposure
• monitoring is conducted and analysed by a competent person
• the assessment results of the monitoring are clearly communicated to employees, their representatives (HSR) and health and safety committees (if relevant to the school)
• the results of monitoring are displayed on the workplace OHS notice boards (see OHS Consultation and Communication Policy)
• recommendations (if available) are implemented (so far as reasonably practicable).

Definitions

Competent person
A person with suitable qualifications and experience to conduct the required work for example, an occupational hygienist.

Contaminants
Airborne substances and other work environment hazards including dust, lighting, radiation, gases, vapours, mould and fumes.

Mould
A type of fungi that lives on plant and animal matter. It grows best in damp and poorly ventilated conditions, and reproduces by making spores which can be a health hazard for humans. Airborne mould spores are commonly found in both indoor and outdoor environments. When they land on damp spots they can begin to grow and spread. There is no practical way to eliminate all mould indoors. The way to control indoor mould growth is to control the source of moisture.

Mould can trigger nasal congestion, sneezing, cough, wheeze, respiratory infections and worsen asthma and allergic conditions. People with weakened immune systems — allergies, severe asthma, chronic, obstructive or allergic lung diseases are more susceptible to these symptoms and other serious health effects.

Occupational hygienist
Utilises the teachings of both science and engineering in order to identify and understand hazards in the workplace and the risk to the health and safety of employers and employees. It is their role to identify potential risks from exposure to biological, chemical, psychosocial, physical and ergonomic hazards within the workplace and the course of work-related duties.

Hazards are anticipated based on precedent in certain industries or environments where it can be foreseen that there may be danger to those exposed. From here, the occupational hygienist would then review the workplace or environment and recognise and evaluate whether there is a presence of a threat.

Occupational hygienists are trained in hazard management and risk assessment and apply the hierarchy of control approach when recommending control measures to prevent ill health.

Personal monitoring
The method used to determine an employee's exposure to workplace contaminants. In this method the air sample is collected within the breathing zone of the employee. The breathing zone is defined as being within a 30cm radius of the employee's nose and mouth. The sampler is usually attached to the collar of an employee's shirt as high up as possible. Personal samples ensure as far as possible that the air sampled best represents the air inhaled by the employee.

Static monitoring
Involves the sampler fixed to an employee's workstation or source of contaminant. Static monitoring is ideal for monitoring effectiveness of control measures within a particular work area.

Related policies

• Contractor OHS Management
• Occupational Health, Safety and Wellbeing Management in Schools
• OHS Consultation and Communication
• OHS Risk Planning and Management

Relevant legislation

• Occupational Health and Safety Act 2004 (Vic)

Environmental Hygiene Procedure

The Environmental Hygiene Procedure must be followed and sets out the practical step-by-step instructions for implementing the Environmental Hygiene Policy.

It contains the following chapters:

1. Identify potential exposure
2. Risk management
3. Controlling risks
4. Communication
5. Monitor and review controls
6. Legislation, codes of practice, standards and guidance

1 Identify potential exposure

The principal and/or their delegate, in consultation with the Health and Safety Representative (HSR) and employees, must identify all potential contaminants that employees may be exposed to in the school.

In all instances the principal and/or their delegate must record the identified contaminants in the ‘Hazard Description’ column of the OHS risk register (XLSX) and assess the level of risk and document risk controls.

Examples of contaminants that may be found in the school include:

1. Physical:
   Radiation, Vibration, Temperature, Light / UV, Humidity, Ventilation, Noise (see Noise Management Policy)
2. Chemical:
   Vapour, Gases, Dust, Mist, Fumes, Corrosives, Solvents
3. Biological:
   Fungi including Mould, Bacteria, Mites, Yeasts, Viruses, Enzymes, Body fluids

The principal and/or their delegate should consider all means of exposure when identifying hazards, for example, inhalation, ingestion, absorption and injection. Contaminants may be identified when:

• previous school monitoring results are reviewed
• an incident or illness is reported in the school
• requested by regulatory authorities or external auditors
• a new task or chemical is introduced into the school
• the work environment is changed e.g. suspected mould (see Note below)
• new or additional information relating to acceptable exposure standards becomes available.

Note: Mould is not always easy to recognise. It often appears to be a stain, smudge or discolouration. The most common moulds are black, green or white. However, mould can be many other colours ranging from grey to orange to brown. Mould is associated with damp buildings and is commonly found:

• on roof materials above ceilings
• around windows
• near water fountains
• on walls and ceiling tiles
• in books and carpet.

2 Risk management

2.1 Workplace monitoring

In order to accurately determine the level of risk, the principal and/or their delegate may need to consider specific workplace monitoring and engage the services of an Occupational Hygienist. Specific monitoring will provide results on the actual level of exposure, which can be used as a representative sample to compare against legislated maximum exposure standards.

If monitoring is required, the principal and/or their delegate should ensure that:

• the monitoring is specific to the contaminant and means of exposure (i.e. inhalation would require a different sampling method to ingestion)
• personal monitoring rather than static monitoring is conducted to define potential exposures. Static monitoring should only be used for measuring exposures when a strong correlation is found with personal monitoring
• monitoring is conducted and analysed by a competent person (e.g. Occupational Hygienist)
• the assessment is representative — neither worst case nor best case scenarios

2.2 Contaminant monitoring and exposure limit findings

Once the monitoring is completed, the reported findings should be provided to the principal and/or their delegate. The principal and/or their delegate are responsible for ensuring the implementation of the recommendations in the report in order to reduce the risk of exposure to employees.

If the principal and/or their delegate are provided with only the results of monitoring, they can compare them to the Occupational Exposure Limit (OEL) for that specific contaminant to determine the need for corrective actions and follow-up surveillance.

The principal and/or their delegate should contact the OHS Advisory Service on 1300 074 715 if they require assistance to interpret the findings in reports provided.

3 Controlling risks

Where specific hazards have been identified from exposure to contaminants, controls are to be established and implemented by the principal and/or their delegate in consultation with the HSR and employees. This is to be documented in the OHS Risk Register.

As part of the control process the principal and/or their delegate should ensure that:

• recommendations for placement of personnel in medical surveillance programs are considered
• consideration is given to whether periodic monitoring of the contaminant or the controls is required and the nature of such monitoring

They should also ensure that existing controls are adequate, whether additional or alternative controls are needed, and if so, what these should be e.g. managing exposure to mould:

• If mould is a problem in the school, the principal or their delegate needs to eliminate sources of moisture and by ensuring:
  • mould is washed off hard surfaces and allowed to dry completely by opening windows and doors or by using portable heaters to minimise re-growth. Absorbent materials, such as carpet, may need to be replaced if they are contaminated with mould
  • leaky plumbing and other building faults are fixed
  • exhaust fans or open windows are used in the bathroom and kitchen areas when showering, cooking or using a dishwasher
  • conditions that encourage mould growth are avoided by using heat insulation and ventilation
  • small areas of mould are cleaned using a damp wipe with detergent solution, vinegar solution or alcohol solution (one part vinegar or alcohol to three parts water). Commercially available mould treatments can bleach the mould white, but may not remove the mould. Do not try to brush the mouldy area as the brush can flick mould spores into the air, which may cause health problems
  • PPE is provided to clean up the areas where mould is present e.g. safety glasses, long rubber gloves protective clothing

The principal and/or their delegate in consultation with the HSR and employees must ensure that risk controls to reduce employee exposure are identified and implemented using the order of the hierarchy of controls.

3.1 Safe Work Procedures

The principal and/or their delegate in consultation with the HSR and employees must identify interactions between employees and contaminants (e.g. PE teacher coaching sport outdoors in the sun) that may require the development and implementation of a safe work procedure.

Refer to the Safe Work Procedure Template (DOCX) and the OHS Risk Management Procedure.

4 Communication

If workplace monitoring of contaminants is required, the principal and/or their delegate should ensure that the results of the monitoring are clearly communicated by:

• verbally informing employees of the results and controls required following the monitoring
• including report findings from monitoring on the agenda and minutes of Health and Safety Committee Meetings (if relevant) and/or regular staff meetings
• displaying and communicating the results of monitoring on the workplace OHS Notice Boards (see OHS Consultation and Communication Policy)

5 Monitor and review controls

The principal and/or their delegate in consultation with HSR and employees is responsible for:

• monitoring and reviewing the effectiveness of hazard controls
• ensuring that the OHS risk register (XLSX) is kept up to date and is reviewed when hazards associated with exposure to contaminants are identified, assessed, controlled and reviewed.

In the event that further / ongoing monitoring is required, the principal and/or their delegate should contact the OHS Advisory Service for advice and support on 1300 074 715.

6 Legislation, codes of practice, standards and guidance

• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)
• WorkSafe Victoria Compliance Code: Hazardous Manual Handling, Edition 2, December 2019
• NIOSH Manual of Analytical Methods
• AS 2985:2009 - Workplace atmospheres – Method for sampling and gravimetric determination of respirable dust
• AS 3640:2009 - Workplace atmospheres – Method for sampling and gravimetric determination of inhalable dust
• NOHSC 3008 (1995) 3rd Edition – Guidance Note on the Interpretation of Exposure Standards for Atmospheric Contaminants in the Occupational Environment
• NOHSC 1003 (1995) Adopted National Exposure Standards for Atmospheric Contaminants in the Occupational Environment

Resources

Templates relevant to this policy and procedure

• OHS risk register (XLSX) – schools must ensure that all potential contaminants in the school are identified and entered in the ‘Hazard Description’ of this register
• Safe Work Procedure Template (DOCX) – high risk work involving contaminants, such as the cleaning of mould, may require safe work procedures to be developed using this template – the OHS Advisory Service can provide further advice