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 or comments about this article please send us an email at members@mexregs.com. or visit our web site at www.mexregs.com.
(*) Reprinted from Pulse Point, under an affiliate agreement with
MexRegs
to provide monthly articles of interest to our readers. You can find
out
more about Pulse Point at www.pulse-point.com.
MR
MexRegs.com
Transforming Information into Knowledge
3361 28th St.
San Diego, California 92104
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