Summary of results of Canadian federal/provincial/territorial survey on chemicals and workplace exposures
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- Data availability
- Risk assessment
- Risk management
- Research and monitoring
- Occupational exposure limits
The Chemicals Management Plan (CMP) will reach a major milestone in 2020, which provides an opportunity to renew and modernize current program elements. Enhancing the protection of workers from exposure to chemicals is one area being explored. Health Canada has been working with federal/provincial/territorial (FPT) representatives from the Canadian Association of Administrators of Labour Legislation, Occupational Safety and Health Committee (CAALL-OSH) to identify potential opportunities to enhance the protection of workers using the information, tools, and/or technical expertise of the CMP. In the Fall of 2018, as part of this initiative, FPT jurisdictional members of the Committee of Workplace Hazardous Materials Information System (WHMIS) Coordinators (CWC) were surveyed to identify potential opportunities to leverage the expertise and data accumulated on hazardous substances used in Canadian commerce through the CMP to benefit worker health and safety.
Note: the results of this survey represent the views of the CWC members interviewed at the time of the survey. The survey is one part of a broader opportunities analysis and the views expressed in this report do not reflect the official positions of the provincial or territorial Governments, the Government of Canada nor its present or future policy direction.
The survey results indicate that expanding the role of and broader collaboration within Health Canada in both the Existing and New Substances Programs would serve to advance a more preventive or proactive approach to occupational health and safety program delivery. Key benefits identified by the respondents include supporting the jurisdictions in their:
- priority setting [for example, for inspections, compliance monitoring, Occupational Exposure Limits (OEL) development]
- development of materials and methods to educate employers and assist them in fulfilling their occupational health and safety responsibilities, especially small employers
It would also help support jurisdictions in:
- addressing the risk management challenges posed by the WHMIS excluded products, especially consumer products
- achieving pan-Canadian harmonization of occupational exposure limits
The survey was structured into 5 sections to better understand potential opportunities in the areas of data availability, risk assessment, risk management, research and monitoring and occupational exposure limits.
The data sources that most jurisdictions are currently using to identify priorities for action related to worker exposure are mainly reactive (for example, American Conference of Governmental Industrial Hygienists (ACGIH®) OEL changes, stakeholder reports, inspection reports). CWC respondents for all jurisdictions felt that leveraging federal authorities under the Canadian Environmental Protection Act, 1999 (CEPA 1999) to require manufacturers, importers or users of chemical substances to submit information on chemicals in the workplace would be helpful to their programs. Respondents for most jurisdictions felt that having access to health hazard information submitted under the New Substances Notification Regulations would be of value to their jurisdiction.
For all jurisdictions, risk assessment for workplace chemical exposures is an employer responsibility and it is the role of the jurisdiction to verify or monitor that the employer has done the risk assessment correctly. Respondents for all jurisdictions felt there would be value in Health Canada expanding the scope of their chemical risk assessments to include the characterization of worker exposure and risk for both new and existing chemicals.
The most frequent risk management challenge identified by respondents was information deficiencies for WHMIS excluded products, especially consumer products. This challenge exists because employers do not have access to the same level of information for these products as they do for WHMIS regulated products in order to support the development of safe work practices, and to educate and train workers.
Research and monitoring
In all jurisdictions, exposure monitoring, biological monitoring and medical surveillance are employer responsibilities. Respondents for most jurisdictions indicated that collaboration or sharing of information related to sampling and analysis of chemical exposures would be of benefit to their jurisdiction.
Seven jurisdictions have research funding programs that are or could be targeted to worker chemical exposure issues and 7 do not. Respondents for most jurisdictions welcomed the support of Health Canada by carrying out research and monitoring in key sectors to identify and address issues and to inform policy.
Occupational exposure limits
There is significant interest in the harmonization of Canadian OELs; however there is currently no pan-Canadian organization that develops OELs for potential use across the country. Respondents in most jurisdictions agreed that there is an opportunity for Health Canada to play a role in the development of OELs similar to the way Health Canada supports the FPTs in the development of drinking water guidelines. Respondents in many jurisdictions indicated that there are specific chemicals of concern that are used in their jurisdiction's workplaces for which existing OELs are lacking.
Collaboration on all of the potential opportunities identified in the survey was of interest to the CWC respondents for most jurisdictions. With respect to their top 3 priorities, data sharing was the opportunity most often identified with respondents for 10 jurisdictions identifying it as a top 3 priority, closely followed by risk assessment (respondents for 9 jurisdictions), and OEL development (respondents for 7 jurisdictions).
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