Problem of excessive occupational disease risk factors
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According to the last item of Article 27 of the Law of the People’s Republic of China on the Prevention and Control of Occupational Diseases: When it is discovered that the occupational disease hazards in the workplace do not meet **occupational health standards and hygiene requirements, the employer must immediately take appropriate measures to address them. If those standards and requirements are still not met, operations involving such occupational disease hazards must be halted； Only after the occupational disease hazards have been addressed and meet the **occupational health standards and requirements** can work resume. There is such a requirement here: when the conditions are not met, control measures should be taken. Do these control measures include the five aspects of elimination, substitution, engineering controls, management measures, and personal protection? If a factory has excessive noise levels, is it sufficient to rely only on personal protective equipment? If that’s the case, then can excessive levels of toxic gases in a factory also be dealt with simply by using personal protective equipment? Is no other method needed to eliminate it? In other words, it is possible to work in an environment with excessive toxic gases by using personal protective equipment?
This is how I understand it: First of all, neither noise nor the concentration of harmful gases should exceed the limits set by the environment; if these limits are exceeded, measures must be taken to address the issue； Here’s how we handle it now: taking noise as an example, the final detection result is the equivalent noise value ； (Combined with job operation time) ； If this value exceeds the limit, it must be improved ；
What kind of company are you? Is the noise level in some machinery companies that have punching machines quite high? Do those improvement measures include personal protection?
We are a chemical company engaged in post-treatment operations; the improvement measures do not include personal protective equipment: isolation methods are employed； (It is not possible to make improvements on the device itself) ； Finally, a separate isolation booth is set up for long-term work at a fixed workstation.)
In my opinion, governance should involve elimination, substitution, engineering, and management in order to meet the requirements; personal protection is merely a unilateral measure
What can truly solve the problem are elimination, substitution, and engineering – but are governance measures limited to just these three? If so, there will be no need for loud noise operations at the construction site.
In fact, the law is clear: employers must take appropriate corrective measures immediately. There are a variety of governance measures; of course, it is not sufficient to rely only on personal protective measures. What was said on the 2nd floor is correct; first of all, the limits must not be exceeded. There are environmental standards, and there are also requirements regarding the concentration of toxins to which workers are exposed and the duration of exposure.
You can take another look at Article 15 of the new Law on the Prevention and Control of Occupational Diseases. Or check out http://bbs.hcbbs.com/thread-1553759-1-1.html
The law is clear, but this governance measure is not so clear. There are the following questions: 1. Do personal protective measures count as control measures? If it’s counted, then it’s simple. 2. The noise levels in machinery factories (especially those with punching machines) are above the allowed limits; should such factories be shut down in such cases? But it wasn’t actually turned off. Why? 3. If personal protective measures are sufficient in a noisy environment, then can the same be said for other toxic substances, where personal protective measures would also be enough? Since many factories with excessive noise levels remain open without any warnings or anything of the sort, and the only solution is to use earplugs, I raise the above issues.
This post was last edited by Wang Xiaoxiaobai Bai on 2016-3-10 at 14:31. The question raised by the original poster is very good. What you mentioned about using earplugs for control does not constitute a governance measure. PPE is an obligation and responsibility of enterprises as required by the Work Safety Law. As the last line of defense for labor protection, PPE cannot be used as a substitute for other protective measures. Risk elimination must be achieved through elimination, substitution, and engineering controls. So those many factories with excessive noise levels that you mentioned are still in operation; **the standards set limits for human exposure to noise, and when these limits are exceeded, measures must be taken to eliminate the noise at its source. This is the current state of production; indeed, there are many enterprises that fail to meet occupational health and safety standards, which is why our supervision and management are necessary.
First of all, protective measures are not governance measures. In short, governance measures are proactive actions, while protective measures can be understood as reactive actions. Secondly, I am not in the machining industry, so it is difficult for me to evaluate his working environment. But I think there are some special types of work that involve particular occupational hazards; for example, the arc light generated during welding. With current technology, it is not yet possible to create a welding environment that does not produce sparks, light, or smoke, so reliance must be placed on personal protective measures such as masks. Forging and impact operations in the machinery industry certainly also generate noise that cannot be eliminated; is individual protection the only solution in such cases?