SIMPLE RISK

ASSESSMENT AND
CONTROL FOR
CHEMICALS
(SiRAC)
Rusnah Bt Nanyan
Chemical Management Division
DOSH, Headquarter, PUTRAJAYA

Session Objectives
State

the legal requirements for SiRAC

Explain the differences between CHRA
and SiRAC
State the scope and application of SiRAC
Concept and Steps of SiRAC

Legal Requirements

Sub-Regulations 10(1) of
USECHH Regulations 201X
An employer shall not carry out any work

which may expose or is likely to expose any

employee or any other person to any chemical
hazardous to health unless he has made a
written assessment of the risks created by the
chemical to their health.

Sub-Regulations 11(1) USECHH

Regulations 201X

The employer MAY conduct a simple

assessment for a chemical hazardous to
health, ifa)
b)

The chemical is listed in the register stipulated

under sub-regulation 6(1); and
The chemical is NOT classified as
carcinogenicity category 1, mutagenicity
category 1 or respiratory sensitizer category 1
as specified in the Occupational Safety and
Health (Chemical Classification, Labelling and
Safety Data Sheet) Regulations 2013

Sub-Regulations 11(2) USECHH

Regulations 201X
Simple

assessment shall contain the

following1.
2.
3.

the nature of the hazard to health;

the exposure potential arising from the use
of chemical hazardous to health; and
the measures and procedures required to
control the exposure of an employee to
chemicals hazardous to health.

Sub-Regulations 13(2) USECHH

201X
The

employer may appoint a trained

person to carry out a simple assessment
pursuant to sub-regulation 11(1)

Types of Assessment

Types of Assessments
Full

Assessment

Chemical Health Risk Assessment (CHRA)

Generic Assessment (GCHRA)

Simple

Assessment

Simple Risk Assessment and Control (SiRAC)

10

CHRA and SiRAC

Identify chemical used in particular
work unit and its hazard

ta
Meet criteria
in
subreg 11(1)
USECHH 20xx &
required
information
available?

YES

Conduct simple
Assessment (SiRAC)

NO
Conduct Chemical Health
Risk Assessment (CHRA)

Control
approach
1,2 or 3?

YES
Develop action plan

Implement action plan

NO
Seek specialist advice

Who to Conduct SiRAC?

Trained Person
1.
2.

3.
4.
5.

6.
7.

Knowledge, training and expertise in understanding hazard

and risk;
Ability and authority to collate all necessary and relevant
information;
Knowledge, skills and experience to make the right
decisions about risks and the necessary precautions;
Knowledge on the SiRAC manual
How the work activity uses chemicals hazardous to health;
How to interpret SDS; and
Basic requirements of OSHA, USECHH, relevant guidelines

SiRAC Methodology

SiRAC Methodology
SiRAC

is based on the control banding

approach
Other control banding approaches:

COSHH Essentials (HSE of United Kingdom)

ILO Control Toolkit (ILO)
KOSHA Toolkits (Korea)
Stoffenmanager (Dutch)

Scope & Application

Application of SiRAC

By default, USECHH 201X requires full

assessment (CHRA) to be conducted for
every place of work where chemicals
hazardous to health are used (Reg. 10(1))
SiRAC is an option given to employer who
uses chemicals meeting the following criteria:
a)
b)

chemical is listed in the mandatory register ;

chemical is NOT classified as carcinogenicity
category 1, mutagenicity category 1 or
respiratory sensitizer category 1 as specified in
the CLASS Regulations 2013

Application of SiRAC
Even though legally SiRAC is an option given to
employer who uses chemicals meeting the criteria in
sub-regulation 11(1), there is also a limitation in
applying SiRAC for the following chemicals:
Process generated dusts and fumes
E.g. wood dusts, fume released from molten metal

Organic dust

E.g. grain dust, cotton dust, paddy husk dust

Gases
E.g hydrogen sulphide, ammonia
Scheduled wastes as listed EQ (Scheduled Wastes)
Regulations 2005

Routes of Entry

Routes of Entry-SiRAC
Inhalation

Skin/Eyes

Contact

Concepts and Steps

CHEMICAL
RISKS?

Probability of harm, injury, illness or disease from

overexposure to chemicals

Risk

= Hazard x Exposure

Hazard is determined from chemical classification

Exposure is determined by the quantity of chemical
used and its ability to become airborne
Routes of exposure considered in SiRAC is

inhalation, dermal contact and absorption

HAZARD DETERMINATION
Chemicals
causing harm
when airborne
Group A
Group B
Group C
Group D

Chemicals capable
of causing harm if in
contact with
skin or eyes
Group S

23

HAZARD DETERMINATION
Hazards

are grouped into 4 groups (for

chemicals causing harm when airborne):

Group A (least hazardous)

Group B
Group C
Group D (most hazardous)

HAZARD
DETERMINATION

Group S

chemicals capable of
causing harm if in contact
with eyes or skin

H-CODE
H-code or the hazard statement code describes the
nature of the hazards of the chemicals as specified in First
Schedule of the CLASS Regulations 2013

It is assigned to
each of the
hazard
statement

used for reference purposes

Examples
of H-code:

H301: Toxic if swallowed

not part of the hazard statement text and shall not be

used to replace it.

H310: Fatal in contact with skin

H317: May cause an allergic skin reaction

Direct Advice

Specific CGS (based on task performed)

for work activities or industries covered are :

Pest Control
(Table 3.8)

Soldering
(Table 3.9)

Cleaning
Services
(Table3.10)

Lithography
Printing (Table
3.11)

EXPOSURE DETERMINATION
Magnitude of
Exposure

Scale of Use
&
Ability to Become
Airborne

Frequency &
Duration
Per Operation/Batch
Or
Per Day
Total Duration >
15 minutes per day

EXPOSURE DETERMINATION
1.

Scale of use

Determine the way chemical is handled and

how much employees are exposed
Amount used per batch/operation or per day
(continuous operation) can be described as
SMALL, MEDIUM, LARGE

Quantity

Solid
Weight

Typically received in

Liquid
Volume

Typically received in

Small

Grams

Packets or bottles

Millilitres

Bottles

Medium

Kilograms

Kegs or drums

Litres

Drums

Large

Tonnes

Bulk

Cubic metres Bulk

EXPOSURE DETERMINATION
2.

Ability to become airborne

Physical form of the chemical affects how likely it is

to get into the air.
For solids - determined by its dustiness
Depends

on its physical form-the finer the solid the more

likely for it to become airborne

For liquids-determined by its volatility

Volatility

depends on its vapour pressure - the higher the

vapour pressure, the more volatile the chemical
Volatility also depends on the operating temperature - the
higher the operating temperature, the more easily vapour
will be formed and become airborne

Table 3.4: Level of dustiness

Level

Low
Medium

High

Descriptions

Example

Pellet like solids that dont break up. Little dust is PVC pellets, waxed
seen during use.
flakes
Crystalline, granular solids. When used, dust is seen, Soap powder.
but settles out quickly. Dust is left on surfaces after
use.
Fine, light powders. When used, dust clouds can be Cement, carbon black,
seen to form and remain in the air for several chalk dust.
minutes.

Table 3.5b: Degree of volatility based on boiling point at 25oC

Degree

Descriptions

High

Boiling point below 50oC

Medium

Boiling point between 50 and

150oC

Low

Boiling point above 150oC

Example

Butadiene

Acetaldehyde, acetone,
chloroform, diethylamine

Ethylene glycol, carbon

tetrachloride, n-butyl
acetate

VAPOUR PRESSURE
Pressure exerted by a vapour.
Describes tendency of a chemical to form vapour
Useful (with evaporation rate) in estimating how
quickly a substance becomes airborne within the
workplace (estimation of the inhalation or fire
hazards)
High vapour pressure => volatile(easily vapourised)
Volatility band

Vapour pressure

Low

Less than 500 Pa

Medium

500 to 25 000 Pa

High

More than 25 000 Pa

CONTROL APPROACH
TRADITIONAL

CONTROL BANDING

Elimination
Substitution
Modification

SpecialExpert Advice

Containment

Containment

Ventilation

Engineering Control

Work Practices

General Ventilation

Personal Protective
Equipment

PPE for
Respiratory, Skin &
Eyes protections

CONTROL APPROACH
The risk controls are divided into 4 bands or
approaches:

CA 1

General ventilation

CA 2

Engineering control

CA 3

Containment

CA 4

Special

35

Control Approach 2: Engineering control

Unit
Operation
Mixing
Sieving
Screening
Surface
coating

Sheet title
Mixing
Sieving
Screening
Spray painting
Powder coating

Solids

Liquids

Small

Medium

Large

Small

Medium

Large

G201
G218

G215
G218

G216

G201

G217

G217

G220

G221

G219
G222

G222

Lamination Batch lamination

Dipping

Drying

G223

G223

Continuous lamination

G224

G224

Pickling bath

G225

G226

Vapour degreasing bath

G227

G227

Tray drying oven

G228

G228

Continuous drying
labyrinth oven
Pelletising

Pelletising
Tablet press

G229
G230
G231

G230

G229

36

07/10/2015

General or Dilution Ventilation

Allows

chemical emissions to mix with the work

room air then dilutes to acceptable exposure levels

37

Engineering
control
Local Exhaust Ventilation
(LEV)

Fume Cupboard

Spray booth

CONTROL APPROACH ADJUSTMENTS

CA is adjusted for a very short total duration of
exposure

For very short exposure duration (less than 15

minutes per day) CA drop by 1 level except if CA is
4 or 1.

CONTROL GUIDANCE SHEET (CGS)

G SERIES
(General)

GENERAL TASKS
SPECIFIC TASKS

S SERIES
(Skin)

GENERAL GUIDE
PPE SELECTION

R SERIES
(Respiratory)

GENERAL
PRINCIPLE

CONTROL GUIDANCE SHEET (CGS)

P Series
(for Pest Control)
W Series
(for Soldering)
C Series
(for Cleaning Services)

LP Series
(for Lithography Printing)

Direct Advise
SPECIFIC
TASKS

Sample of CGS

1. Gather Information &

Identify Chemical

Is Direct
Advice
Available?

Yes

No

2. Get H Code
Table 3.1 & 3.2 to get
Hazard Group

3. Use Table 3.3 for

scale of Use

Liquid

Solid

4. Use table 3.4 on

level of dustiness

or

4. Use Table 3.5a & 3.5b

and Figure 2 to decide
volatility

6. Select Relevant CGS

Table 3.8 Pest Control
Table 3.9 Soldering
3.10 Cleaning Services
3.11 Lithography Printing

5. Use Table 3.6 for selection

of Control Approach

5.

Finding The Task- Specific

CGS

7. Develop & Implement

Action Plan

Report Writing and Record

Keeping

SiRAC
Steps

Report Format
Form

SA1
Form SA2a
Form SA2b
Form SA3

SA1

Simple Assessment Form

Company :
Address :
Telephone :

Fax :

Email :

Type of industry :

Employer/Representative Name
:

Position :

Assessor Name :

Assessor Contact No. :

Assessor
Email :

Total no. of chemicals at the workplace :

No. of chemicals assessed (using simple

assessment) :

Summary of Simple Assessment

Process :

Task description

CGS

Existing
control
**

*Note: CGS: Control Guidance Sheet, EM: Exposure Monitoring, MS: Medical Surveillance
** Existing Control; Control Measure (Fill in the following code)
1.
General Ventilation
2.
Local exhaust ventilation
3.
Containment
4.
Training
5.
Safe work procedures
6.
PPE (please specify) _____________________________________________________________
7.
Others (please specify) _____________________________________________________________

Further Action
Control
Measure
**

Training
yes ()
no ()

EM*
yes ()
no ()

MS*
yes ()
no ()

Identify and Gather Information on Chemicals

SA2a

Work Area :
Date of Assessment :
Process

No. of
Worke
r

Task

Name of
Chemicals

Quantity Physical Temp. (oC)

Total
RUse
s form
phrase
B.P
O.T Duration
of
/ HUse/day
code
(min.)

Existing
control

SA2b
Simple Assessment Worksheets
Work Area :
Date of Assessment :
No.

Task

Name of
Chemical
s

Hazard
Group
(A, B, C,
D, S)
(Table
3.1&
Table
3.2)

Dustiness/Vola
Scale
Control
Control
tility
Total
of Use
Approach
Guidanc
(L, M, H)
Duratio
CA
(S, M, L)
(CA)
e Sheet
(Table
n of Use
Adjustm
(Table
(Table 3.6
(CGS)
3.4/Table 3.5a <15min
ent
3.3)
or
(Table
or
?
Table 3.7)
3.8)
Table 3.5b)

SA3
Action Plans
No.

Task

Name of
Chemicals

Existing control

Adequacy
of control

Action to be
taken

Due Date

PIC

I ______________ will be responsible for the improvements as specified in the action plan. I also promise to keep good
records of the assessment and hand it over to my successor if my company ceases to carry on business or hand it over
to the Director General of Occupational Safety and Health if there is no successor.
Signature of employer :

Position:

Date:

Review Asessment

Review

In line with USECHH Regulations

requirements
Assessment need to be reviewed under any
one of the following condition:
> Significant change in work
> New/improved control measures
implemented
> 5 years has elapsed
> Directed by DG, DDG or Director of OSH