WORKING WITH CARCINOGENIC SUBSTANCES
The University of Sydney is committed to safe use of carcinogenic substances. Acquisition and use of known and suspected carcinogens will be minimised. Acquiring, storing, using and disposing of these substances will be carried out in accordance with relevant legislation, guidelines, Australian Standards and established good practice. Heads of departments and those in charge of research projects in which carcinogenic substances are used are responsible for ensuring compliance with statutory requirements, guidelines, standards and good practice.
The nature of University work means that some staff and students handle known and suspected carcinogenic substances and highly toxic chemicals. There are many types of laboratories where such substances may be found, including all types of chemical laboratories, histology laboratories, biochemistry laboratories, pharmaceutical laboratories, pharmacological laboratories, cancer medicine laboratories, microbiological laboratories, medical science laboratories, veterinary science laboratories, physics laboratories, etc.
Known and suspected carcinogenic substances can be kept and used safely if appropriate precautions are taken. Some carcinogenic substances are regulated by the WorkCover Authority of NSW, and in this case WorkCover must be notified prior to obtaining or using the substance.
The information on this section of the website provides basic guidance on safe practices and legal requirements for the use of carcinogenic substances and highly toxic chemicals. The acquisition, use and disposal of these substances at the University of Sydney must comply with relevant legislative requirements, applicable guidelines and established standards.
The Occupational Health and Safety Regulation 2001 includes a number of clauses specifically relating to carcinogenic substances, as well as a whole chapter on hazardous substances in general.
In addition, WorkCover has issued a WorkCover Guide for Notification for Work Involving Carcinogenic Substances.
For the purposes of this information, there are two categories of carcinogenic substances:
- known or suspected carcinogenic substances, including those listed by the International Agency for Research on Cancer, are covered by the general precautions and regulatory requirements for hazardous substances.
- there are additional requirements for substances listed in the the Regulation as notifiable or prohibited carcinogenic substances. This latter category is referred to as WorkCover listed carcinogenic substances.
General precautions - known and suspected carcinogens and highly toxic chemicals
In accordance with Chapter 6 of the Regulation, the following general precautions apply when working with substances known or suspected to be carcinogenic and/or highly toxic:
- Undertake and document a risk assessment in consultation with those who will handle the substance.
- Implement the controls resulting from the risk assessment.
- Follow standard safe laboratory practices and techniques.
- Ensure laboratory facilities are adequate and appropriate, particularly in relation to containment, ventilation, segregation from other activities and security.
- Ensure those working with the substances receive adequate information, instruction, training and supervision appropriate to their level of experience and competence with required laboratory techniques.
- Ensure those working with the substances receive appropriate training and supervision in relation to the hazards and safe techniques, standard operating procedures, use of personal protective equipment, etc, needed to minimise risks to health.
- Be prepared for emergencies, including spills and accidental exposures, as well as routine decontamination.
- Document and implement local rules, standard operating procedures, access controls etc.
- Plan for safe hazardous waste disposal before commencing the project.
- Store the substance safely and securely and follow all labelling requirements.
- In assessing risks and determining safe operating procedures and other controls, refer to other suitable reference sources, eg:
*substance Material Safety Data Sheet
*equipment operating manuals
*specific references for experiment protocols, techniques, etc.
Note that undergraduate students, including honours students, may lack experience in laboratory techniques and procedures. A mistake when handling a carcinogenic substance could result in an exposure with serious long-term health consequences. The risk assessments for any projects proposing that undergraduate students work with carcinogenic substances must consider and document the particular training and supervision measures that will be implemented to take account of this inexperience. This should include details of who will provide in-lab oversight to ensure the student is or becomes competent in the required laboratory techniques and safe operating procedures.
WorkCover listed carcinogenic substances
WorkCover listed (notifiable and prohibited) carcinogenic substances may not be kept or used without first notifying WorkCover using the approved form at least 60 days prior to the intended use or acquisition. The list of notifiable and prohibited carcinogenic substances can be found in Clause 158 of the Regulation. The list is also published in the WorkCover Guide.
Note that prohibited carcinogenic substances can be used for research and analysis purposes, provided WorkCover is notified and all other statutory and University requirements are met.
WorkCover listed carcinogenic substances may only be supplied to people who can provide evidence that WorkCover has been notified of the intended use as defined in Clause 159 of the Regulation. The supplier is required to keep supply records under Clause 160 of the Regulation.
Keeping WorkCover listed substances
WorkCover requires renewal of notification every 5 years using the approved form if there is continuing use of the carcinogenic substance. This also applies to ongoing use of WorkCover listed carcinogens for which a WorkCover permit was issued under previous legislation.
Notification, risk assessment and control
WorkCover listed carcinogenic substances are subject to the same general requirements for risk assessment and control as all other hazardous substances, as well as some additional requirements.
Clause 10 of the Regulation requires the employer to assess risks to the health of employees and others arising from identified hazards.
Clause 12 requires the employer to review risk assessments and control measures.
Clause 168 requires the employer to record the results of risk assessments relating to the use of a hazardous substance.
Clause 171 requires that certain records be kept for periods of 5 or 30 years.
A research risk assessment record must be produced for each project involving the use of a notifiable or prohibited carcinogen, regardless of whether the project falls under the University's Research Office protocols. A copy of this summary risk assessment and the completed WorkCover notification form must be lodged with Work Health & Safety Services (WHS Services) at the same time that WorkCover is notified. Under Clause 171 of the Regulation, these records must be kept for at least 30 years after the date of notification.
As specific measures will be necessary to control the risks associated with exposure to a WorkCover listed carcinogen, a detailed risk assessment must be conducted in consultation with those staff, students and others who could be exposed to the substance. The control measures to be adopted as a result of the risk assessment must be adhered to as a condition of using the listed carcinogen. The risk assessment, including details of control measures, must be fully documented, including relevant training and in-lab oversight arrangements to take account of the relative inexperience of any undergraduate students involved in the project. The risk assessment report, material safety data sheets, standard operating procedures, safe work methods and other relevant documentation must be kept in a location that is readily accessible by those potentially exposed to the carcinogenic substance.
Under Clause 169 of the Regulation, employers must keep records of each employee who has been or is likely to have been exposed to a WorkCover listed carcinogen. In order to comply with these requirements, as well as privacy and confidentiality requirements, any actual or suspected exposure to a listed carcinogen must be immediately notified to WHS Services using the standard incident reporting procedures. WHS Services will notify WorkCover as required by Clause 341(f). The exposure must be investigated locally to determine whether the risk controls need to be changed. WHS Services will review the incident report and may refer an exposed person to an occupational physician for a medical assessment.
The records required to be kept include the full name and date of birth of the employee and their address whilst employed. Under Clause 170 of the Regulation, when an employee who was or is likely to have been exposed to a listed carcinogen leaves the employment, the employer must provide a written statement to the employee. This statement must include details of:
- name of the carcinogen(s) involved
- period of exposure or potential exposure
- how and where records of the exposure or potential exposure can be obtained
- any advisable periodic health assessments and the type of health tests that are relevant.
These records should also be kept for any research students or honorary researchers exposed or likely to have been exposed to a listed carcinogen. Details of the exposure from incident reports and related documents will be placed on the staff member’s personal file (or the student’s file), which will be specially marked for retention as these records must be kept for at least 30 years from the last entry date.
If injury or illness results from exposure to the carcinogen, the risk assessment must be reviewed and WorkCover must be notified in writing of the review and the changes resulting from it (Clause 346(a) of the Regulation).