HAZARDOUS CHEMICAL AGENTS & DUST MONITORING
Employers need hazardous chemical agents monitoring wherever employees may breathe a dust, fume, vapour or gas with a legal exposure limit. It includes dust monitoring for respirable crystalline silica and other dusts, welding fume monitoring, and sampling for vapours and gases. Exposure often arises during manufacturing, processing, maintenance and cleaning, and it is not always obvious.
Qualitas Occupational Consulting is registered with the Department of Employment and Labour (DEL) as an Approved Inspection Authority (AIA) for hazardous chemical agents. We are also a SANAS-accredited ISO/IEC 17020 inspection body for this work. Our survey provides the air monitoring required by regulation 6 of the Hazardous Chemical Agents (HCA) Regulations, 2021, and recommends practical controls.
WHY DUST, FUME AND VAPOUR EXPOSURE MATTERS
Hazardous chemical agents can cause short-term effects, such as irritation and dermatitis, and long-term occupational disease. Respirable crystalline silica raises the risk of silicosis, an incurable lung disease, and of lung cancer and kidney disease. Stainless steel welding fume contains hexavalent chromium and nickel, both listed as carcinogens. Manganese in mild steel fume can cause symptoms similar to Parkinson's disease. Some agents are also absorbed through the skin or cause respiratory sensitisation.
For the business, uncontrolled exposure means a higher compensation risk, more absenteeism and lower productivity. A contravention of the HCA Regulations can lead to a fine or up to six months' imprisonment (regulation 16).
The HCA Regulations, 2021 set these duties and intervals:
• Risk assessment (regulation 5): immediately, then at least every 24 months. Review it immediately after a change in process, equipment or controls. The regulations do not say who must do it, so use a competent person.
• Air monitoring (regulation 6): at least every 24 months, by an AIA. It applies wherever employees may be exposed to an agent with an exposure limit in Table 2 or 3 of Annexure 2.
• Engineering controls (regulation 12(b)): local exhaust ventilation, fume cupboards, spray booths and spray cabinets must be examined and tested by an AIA at least every 24 months. Keep the test and repair records for at least 3 years (regulation 9(g)).
Review these with your occupational health risk assessment under section 8(2)(d) of the Occupational Health and Safety Act, 1993, which has no fixed interval. Our free Compliance Gap Assessment shows which of these apply to your workplace and which are overdue.
WHAT THE HCA REGULATIONS REQUIRE
HOW WE MONITOR HAZARDOUS CHEMICAL AGENTS
Every survey is led by Christo de Wet, an occupational hygienist with 15 years of experience. He is registered with the Southern African Institute for Occupational Hygiene (SAIOH), ROH 0953. Our AIA registration is OH0253 - CI 072, and our SANAS accreditation number is OH0253.
Before the visit, we review your safety data sheets, process description and previous reports, and plan representative sampling with you.
On the day, employees wear personal air sampling pumps in the breathing zone during normal production, for most of the shift. Where an agent has a short-term limit, we also sample peak tasks. Each sampler collects the fraction its limit refers to. For dust, we sample according to MDHS 14/4, using IOM samplers with foam inserts for the respirable fraction. Welders wear the sampler behind the visor. The samples then go to a SANAS-accredited laboratory for analysis.
Afterwards, we compare every result with the correct Annexure 2 limit and recommend controls for the tasks that cause exposure. On mines and quarries we work under the Mine Health and Safety Act, 1996. Christo can take the section 12(1) appointment for surface operations only.
- • The agents measured, their sources, the sampling strategy, and where and when each sample was taken
• Personal exposure results for each employee or group, against the correct Annexure 2 limit
• Laboratory certificates for every sample
• Each instrument's serial number and last calibration date
• A risk rating that highlights high exposures
• Practical control recommendations linked to the tasks that cause exposure
• A report written for management, SHEQ teams and auditors, laid out according to DEL's guideline for monitoring reports and signed on every page
What affects the quote: the time on site, the number of samples and travel. Time on site depends on the size of the site and the number of work areas or employee groups to cover. Each sample sent for laboratory analysis is priced as one item, including media and analysis. The quotation lists each service as its own line item.
WHAT YOUR SURVEY REPORT INCLUDES
- How often must hazardous chemical agents be monitored?
At least every 24 months for each agent with a limit in Table 2 or 3 of Annexure 2 that employees may breathe (regulation 6). Low results do not extend the interval. After a change, such as a new product, a switch to stainless steel welding or failed extraction, review the risk assessment and measure the changed process.
Who may carry out the air monitoring?
Only an AIA approved for hazardous chemical agents. Approval in one field does not cover another. Check the firm's entry on DEL's list of approved inspection authorities and its SANAS schedule of accreditation.
What must we prepare before the survey?
Safety data sheets for the products in use, a process description, a list of exposed employees per task and your previous reports. Plan for a normal production day, and inform your health and safety representative or committee beforehand.
What happens if a result is above the limit?
The report names the tasks responsible and the controls needed, such as extraction, wet methods or substitution. For agents with a maximum limit, such as respirable crystalline silica at 0,1 mg/m³, exposure must be kept as low as reasonably practicable below the limit. Respirators do not count as adequate control for these agents. Where a restricted limit would be exceeded without respirators, the area must be a demarcated respirator zone.
FREQUENTLY ASKED QUESTIONS
Free online tool: Compliance Gap Assessment. See what is due at your workplace
Occupational hygiene for manufacturing, engineering and foundries
Occupational hygiene for automotive plants, spray booths and workshops
Occupational hygiene for mines and quarries
What do the Regulations for Hazardous Chemical Agents, 2021 require?
What must a chemical risk assessment cover under the HCA Regulations?
How often must hazardous chemical agent monitoring be done?
Occupational exposure limits explained: what the numbers mean
Welding fume monitoring: what is measured and why
Silica dust at work: exposure, monitoring and controls
FREE TOOL AND ARTICLES
REQUEST A QUOTE
Tell us where your site is, which processes release dust, fume or vapour, and how many employees are exposed. We are based in Pretoria, work in all nine provinces and quote travel upfront.
