Occupational Hygiene Practice & Legal Compliance in Health and Safety Auditing
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ERM is a Global Environmental and Health & Safety Consultancy
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ERM Southern Africa has around 150 offices in main centres throughout the
world, employing around 4000 staff
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Offices in Johannesburg, Cape Town and Durban (around 150 staff)
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Performance & Assurance and Transactional Services (PATS) Team:
Team of around 15, including environmental lawyers, certified H&S
auditors, an occupational hygienist, registered safety practitioners,
many with extensive industry experience
EHS legal compliance, risk and MS audits
EHS MS system development
Sustainable development assurance
IFC Compliance
Waste management consultancy
Occupational health and hygiene consultancy
EHS Due Diligence and Transactions
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ERM conducts many EHS audits during the course of a year, both in South
Africa and throughout sub-Sharan Africa
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Assesses many occupational health and hygiene programmes
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Has opportunity to view many occupational hygiene reports
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Often have audit findings relating to occupational hygiene
Most due to gap in employer’s responsibilities
Do have findings relating to occupational hygienist’s work
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This presentation is a summary of the findings for audits I have been
involved in as relates primarily to occupational hygienist’s work
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Have conducted over 100 H&S audits since 2009
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Including mining and non-mining industries
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For this exercise:
Looked at non-mining industries only
46 occupational hygiene reports
Reports covering 2009 – 2015
12 different occupational hygiene consultancies
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Focus primarily on scope of occupational hygienist’s responsibility
(as opposed to employer’s responsibility)
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Have not included findings around the basis for the types of surveys
done (ie output of risk assessment, whether to sample for respirable
dust, Cr(VI), noise etc etc) as in many cases occupational hygienist
is directed by the employer for this
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Reviewed contents of occupational hygiene reports (where available)
and the findings in our audit reports
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Results will be skewed a little towards audit findings as in many
cases the occupational hygiene reports aren’t available and haven’t
always included results from reports which had no findings
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46 Occupational hygiene reports:
Asbestos surveys (2)
Thermal stress (6)
HBA survey (1)
HCS survey (13)
Illumination (6)
Noise (11)
Ventilation (7)
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Reports with findings: 29 (63%)
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Reports without findings 17 (37%)
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Note previous comments – not an accurate reflection of overall picture for
occupational hygiene performance in SA
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42 Findings
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13 reports, 12 have findings
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22 Findings total relating to HCS Surveys
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11 reports, 7 have findings
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10 Findings total relating to Noise Surveys
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7 reports, 5 have findings
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5 Findings total relating to Ventilation Surveys
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Asbestos: 2 cases where “Suspected asbestos material not identified
or excluded in report”
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Heat stress: 2 cases where heat stress measurements performed
during cooler months
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Many different people scrutinise occupational hygiene reports
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Sites are heavily audited
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The quality of the report in terms of technical content, attention to detail, grammar,
relevance of recommendations, etc gives a good indication of the quality of the work
done on site
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A poorly written report and work not conducted in accordance with legal requirements
has a number of implications for operations
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ERM Southern Africa, a global Environmental and Health & Safety consultancy, conducts numerous audits focusing on occupational hygiene. This presentation by Mike Valentine highlights key findings from audits conducted from 2009 to 2015 in non-mining industries, emphasizing the responsibilities of occupational hygienists. The scope primarily delves into the hygienist's role and their reports.
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Presentation Transcript
SAIOH Gauteng Branch Workshop Occupational Hygiene Practice Legal Compliance from a Health and Safety Auditor s Perspective 25 November 2015 Mike Valentine ERM Southern Africa 1
Background - ERM ERM is a Global Environmental and Health & Safety Consultancy ERM Southern Africa has around 150 offices in main centres throughout the world, employing around 4000 staff 2
Background - ERM Offices in Johannesburg, Cape Town and Durban (around 150 staff) Performance & Assurance and Transactional Services (PATS) Team: Team of around 15, including environmental lawyers, certified H&S auditors, an occupational hygienist, registered safety practitioners, many with extensive industry experience EHS legal compliance, risk and MS audits EHS MS system development Sustainable development assurance IFC Compliance Waste management consultancy Occupational health and hygiene consultancy EHS Due Diligence and Transactions 3
Background ERM conducts many EHS audits during the course of a year, both in South Africa and throughout sub-Sharan Africa Assesses many occupational health and hygiene programmes Has opportunity to view many occupational hygiene reports Often have audit findings relating to occupational hygiene Most due to gap in employer s responsibilities Do have findings relating to occupational hygienist s work This presentation is a summary of the findings for audits I have been involved in as relates primarily to occupational hygienist s work 4
Scope and Approach Have conducted over 100 H&S audits since 2009 Including mining and non-mining industries For this exercise: Looked at non-mining industries only 46 occupational hygiene reports Reports covering 2009 2015 12 different occupational hygiene consultancies 5
Scope and Approach Focus primarily on scope of occupational hygienist s responsibility (as opposed to employer s responsibility) Have not included findings around the basis for the types of surveys done (ie output of risk assessment, whether to sample for respirable dust, Cr(VI), noise etc etc) as in many cases occupational hygienist is directed by the employer for this Reviewed contents of occupational hygiene reports (where available) and the findings in our audit reports Results will be skewed a little towards audit findings as in many cases the occupational hygiene reports aren t available and haven t always included results from reports which had no findings 6
Sample Size 46 Occupational hygiene reports: Asbestos surveys (2) Thermal stress (6) HBA survey (1) HCS survey (13) Illumination (6) Noise (11) Ventilation (7) Asbestos surveys Thermal stress 2 7 6 1 HBA survey 11 13 HCS survey 6 Illumination 7
Results Reports with findings: 29 (63%) Reports without findings 17 (37%) Note previous comments not an accurate reflection of overall picture for occupational hygiene performance in SA 37% Findings No Findings 63% 8
Findings - General 42 Findings 25 22 20 15 10 10 5 5 3 2 0 0 0 Asbestos survey Thermal stress HBA survey HCS survey Illumination Noise Ventilation 9
HCS Surveys - Results 13 reports, 12 have findings 22 Findings total relating to HCS Surveys 12 10 10 8 6 4 4 4 2 2 1 1 0 Sampling number basis not established Use of "BDL" without stating the detection limit Result not reported as 8hr TWA Irrelevant details from another report in site report OEL wrongly stated Laboratory analysis method not stated 10
Noise - Results 11 reports, 7 have findings 10 Findings total relating to Noise Surveys 6 5 5 4 3 2 2 1 1 1 1 0 Not reported as an 8- hour rating level Numeric summing to obtain average noise levels Failure to highlight in report of noise zone Sampling not done by AIA Incorrect statement regarding peak sound levels 14
Ventilation - Results 7 reports, 5 have findings 5 Findings total relating to Ventilation Surveys 4.5 4 4 3.5 3 2.5 2 1.5 1 1 0.5 0 Carbon dioxide measurements incorrect Not all LEV systems on site were tested 16
Others - Results Asbestos: 2 cases where Suspected asbestos material not identified or excluded in report Heat stress: 2 cases where heat stress measurements performed during cooler months 17
General Comments - Reports Many different people scrutinise occupational hygiene reports Sites are heavily audited The quality of the report in terms of technical content, attention to detail, grammar, relevance of recommendations, etc gives a good indication of the quality of the work done on site A poorly written report and work not conducted in accordance with legal requirements has a number of implications for operations 18
Questions? 19
Thank you! ER Team 20
