Legal Compliance Integrating the HBA Regulations into your

Legal Compliance - Integrating the HBA Regulations into your COVID-19 Risk Assessment

SARS Cov-2 Virus Classification (Regulation 3) Group 1: Unlikely to cause human disease Group 2: Can cause disease, unlikely for community spread, treatment/ prophylaxis available Group 3: Severe disease, risk of community spread, treatment available Group 4: Severe disease, high risk of community spread, NO treatment available The National Institute of Allergy and Infectious Diseases releases a series of images that offer a close up look at the novel coronavirus SARS-Co. V-2. https: //www. the-scientist. com/image-of-the-day--67114

Information & Training (Regulation 4) § Risks of exposure (Physical, Economic, Psychosocial) § Protective measures by employer (Universal or Specific) § Importance of personal hygiene and housekeeping § Precautions to be taken by employee § Necessity and maintenance of controls § Necessity of medical surveillance § Procedures of use, handling, storage, labelling and disposal § Incident and accident procedures

Information & Training

Duties of exposed persons (Regulation 5) Obey instructions: a) Prevention of uncontrolled release of HBA b) Housekeeping, hygiene practices, health policies c) Wear PPE as prescribed d) Disposal, disinfection of material and sites e) Reporting for medical surveillance f) Undergone training Report accidental exposures

Risk Assessments - Competence No competence requirement for the risk assessment but…. 6(4)(b)…. States that a competent must be involved when recommending the control measures health of persons against such agents as a result of their work person necessary in order to protect the It is recommended that the services of a registered Occupational Hygienist or certified Safety Professional is obtained to undertake the COVID-19 risk assessments. The CI agrees

Risk Assessments (Regulation 6) Review the assessment if is a reason to suspect that the previous assessment is no longer valid or change in process Done in consultation with H&S Representatives and Committees Also, importantly, consider: • Nature, dose and route of exposure of SARS-Cov-2 • Nature of work, process and possible deterioration or failure of controls • Period of exposure to C 19

Medical Surveillance (Regulation 8) • Must have a written medical protocol • Investigate and record all incidents resulting in infection or death • OHP’s must submit to H&S Committees for approval, written procedures for dealing with abnormal results

Exposure Control (Regulation 10) • Responsibility to PREVENT exposure • If not, adequate CONTROL • Standard procedures to reduce risk of transmission • Adopt appropriate measures: Ølimit amount of HBA used Ørestrict number of exposed employees Øintroduce engineering controls Øhave appropriate work procedures

Personal Protective Equipment (Regulation 11) Ø Only if previous control measures not practicable Ø Respiratory protection and clothing for airborne HBAs Ø Impermeable PPE for skin absorbed HBA Ø A basic Respiratory Protection programme for airborne agents Ø Procedures for use, cleaning and storage of PPE

THE RISK ASSESSMENT To assist a facility in complying with the Law - Occupational Health and Safety Act, 1993 (Act 85 of 1993), Regulations for Hazardous Biological Agents (R 1390 of 2001), And; to adapt the measures required by the Department of Employment and Labour ‘COVID-19 Direction on Health and Safety in the Workplace’ Issued by the Minister in terms of Regulation 10(8) of the National Disaster Regulations to specific working environments taking into account the Risk Assessment Guides published online by the National Department of Health.

THE STARTING BLOCKS COVID-19 OHS DIRECTION / HBA Regulations - COMPLIANCE AUDIT

THE DEPARTMENT OF EMPLOYMENT AND LABOUR / DOH COMPLIANCE AUDIT TOOL Guidance note Anticipated high exposure areas that will need immediate assessment, then others that will require assessment, less urgently include the following areas: 1. Entry points to the workplace 2. Change house facilities 3. On-site canteen and similar dining areas 4. Waiting areas 5. Gathering places Etc. Objectives i. To identify and assess the potential risk of exposure of employees to SARS-Co. V-2 virus at workplaces ii. To identify control measures (or the absence of control measures) and assess their effectiveness to prevent exposure iii. To inform the management of the risk of potential exposure of employees to SARS-Co. V-2 virus and additional controls that might be required.

THE DEPARTMENT OF EMPLOYMENT AND LABOUR / DOH COMPLIANCE AUDIT TOOL 1) Basic education & awareness campaigns 2) Hygiene / cleaning measures 3) Reduce physical contact (social distancing) 4) Engineering control measures 5) Administrative controls 6) Personal Protective Equipment 7) Safe work practices 8) Waste management 9) Safety equipment 10) Emergency response No Requirement 4. Engineering control measures Mechanical ventilation is in working order (inward flow, not recirculated to other areas of building, HEPA filtered when reconditioned and recirculated in any workplace, exhausted air discharged through HEPA filters). Environments that require positive pressure may only be allowed where possible and where required without the contamination of other environments Biosafety Cabinets are used for specified procedures. (Only where required) Biosafety Cabinets (Class I to III) are present and in good working order (incl. serviced and validated in last 6/12 months. (Only where required) Sufficient air changes and indoor air quality of an acceptable standard is permissible and acceptable and the responsibility of employer to maintain Physical barriers / screens as a barrier between personnel and visitors If air-conditioning must be used, disable re-circulation of internal air. Weekly clean/disinfect/replace key components and filters And when required, disinfect the internal side of ducting using acceptable engineering methods 4. 1 4. 2 4. 3 4. 4 4. 5 Status No Yes Comments NA Must be signed by CEO

COVID-19 OHS DIRECTIVE COMPLIANCE AUDIT A systematic review of the existing policies, procedures, records and related documents

VENTILATION

SOCIAL DISTANCING & BARRIERS COVID-19 OHS DIRECTIVE COMPLIANCE AUDIT

Incident Management

MASKS

The 5 key steps to assessing and controlling the health risks for C 19 IDENTIFY AND CHARACTERISE THE HAZARD (SARS-Co. V-2 VIRUS) 1 Establish the features of the SARS-Co. V-2 virus that make it hazardous (e. g. mode of transmission) ASSESS THE SEVERITY (HARMFULNESS) OF BEING INFECTED 2 Assess the severity of illness caused by SARS-Co. V-2, (i. e. the severity of COVID-19). Consideration must be given to individual employee vulnerability. This technical guideline provides a reference set of “Severity Scores” out of 1 -5 that guide this. This is used in the risk matrix when calculating Health Risk. ASSESS THE PROBABILITY OF BEING INFECTED 3 For every job, assess the probability of being infected by considering degree & frequency of human contact, fomite contact, droplet / aerosol contact and environmental confinement for each job. Where appropriate, this need to be done at task level. Using the Probability Categories (1 -5) in this technical guideline, assign a “Probability” Score to each job or task. USE A RISK MATRIX: CALCULATE THE RISKS OF BEING INFECTED (SEVERITY X PROBABILITY) 4 General COVID-19 workplace risks are calculated using a “general” severity score of 4 and the probability scores for each workplace. Individual employee risk is calculated by the Occupational Health Staff, based on employee vulnerability (known only to the OH staff) and Probability Score of their jobs. MITIGATE THE RISKS USING A HEIRARCHY OF CONTROLS 5 These controls are as follows (strongest to weakest) ELIMINATION (remove or destroy the virus) SUBSTITUTION (not a feasible option) ENGINEERING CONTROLS (isolation, ventilation) ADMINISTRATIVE CONTROLS (safe work practices, training & awareness) PERSONAL PROTECTIVE EQUIPMENT (PPE) (individual barriers of protection) Additional Notes: Keep a record of findings – keep for 40 years as per requirements of the HBA Regulations. Ensure Incident Action Plans are in place, which must be activated in the event an employee becomes infected

RISK RANKING TOOLS Expert Level – OHP Collaboration Essential

RISK RANKING TOOLS Employer Level – OHS Professional Audit Recommended Does not specifically account for severity

STEP 3: USE RISK RANKING TOOL Determine Exposure Probability - The Department’s Probability Ranking Tool

RISK RANKING TOOLS - PROBABILITY Severity is fixed Assumes healthy worker – so relies on OHP input to graduate from baseline Risk Ranking Considers Control Failures Understandable to a wide audience

RISK RANKING TOOL - SEVERITY SCALES Determine Exposure Severity – OHP Intervention

RISK RANKING TOOL - SEVERITY SCALES Determine Exposure Severity

RISK RANKING TOOL – P & S MATRIX Once the employee is placed in an exposure risk group and classified in terms of the individual’s vulnerability when contracting the disease, the above table could be used to determine the risk classification.

STEP 3: USE RISK RANKING TOOL Deployment actions by risk category (accounting for employee vulnerability)

PPE