by Enrique Medina, MS, CIH
One of the major changes in Mexico's updated Health & Safety standards, (referred to as NOMs, for Official Mexican Norms) involves the requirement to assess workplace hazards and evaluate the risks posed by processes, operations, materials, and machinery on workers' health and safety.
Job Hazard Assessments or JHAs have long been used as a safety management tool in the U.S. and other countries. They are used to identify potential safety hazards and to implement preventive and corrective measures to improve employee safety. California's Injury and Illness Prevention Program (IIPP) is one of the first U.S. regulatory standards that incorporates the requirement to develop JHAs for all job functions.
The hazard assessments mandated by Mexican standards have generally
adopted the traditional industrial hygiene model of Recognition, Evaluation,
and Control. They fall into three categories based on increasing level
of detail: verification, evaluation, and risk assessment. The table below
summarizes the requirements by standard, and list industrial hygiene monitoring
requirements, when applicable.
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A brief description of the various JHA types can help to understand their differences. Verification involves identifying the hazards through some type of periodic, walk-through inspections, and does not require quantitative monitoring. Only two standards involve verification. One is the building safety standard, which regulates ingress and egress, aisles, stairways and ladders, etc. The H&S Commission requires periodic safety inspections of the workplace conducted by a worker-management team.
Other standards mandate an evaluation of workplace conditions, which is more in line with the traditional JHA. Hazards are identified by individual job function, evaluated, and controlled by engineering and administrative measures or PPE. Some of these evaluations need to be complemented by industrial hygiene monitoring, such as the noise, non-ionizing radiation, lighting, and welding standards.
In addition to a JHA, some standards require an actual risk assessment to be performed, including the fire protection, chemical substances, PPE, air contaminant, and ionizing radiation standards. The latter two also require quantitative monitoring. The risk assessment format is a variant on the classic severity-probability matrix, although the fire protection standard's requirements are best performed by a fire inspection or loss control professional.
It should be noted that while these standards provide some guidance concerning compliance, they are basically performance standards, which leaves some room for individual interpretation. Issues such as how often to conduct JHAs, what is a reasonable inspection schedule, what operations must be monitored and how often, are not clearly defined. It is up to the H&S Manager to make sound, defensible decisions on these questions based on the results of the JHA, their knowledge of the process, and familiarity with the regulations.
If you have questions about how this article or
other health, safety or environmental issues, please contact us at (619)
297-1469 or send us an email at emedina@pulse-point.com.
PP
Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
3361 28th St.
San Diego, California 92104
(619)297-1469
(fax (619)297-1023
emedina@pulse-point.com
www.pulse-point.com/alliance
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