What is an occupational health risk assessment, and who needs one?
Short answer: it is a structured assessment of the health hazards in a workplace, who is exposed to them and how much, and whether the controls are adequate, and in practice every employer needs one. Section 8 of the Occupational Health and Safety Act applies to every employer, and separate regulations require exposure risk assessments for chemicals, noise, physical agents, ergonomics, biological agents, lead and asbestos, each repeated or reviewed at intervals of no more than two years.
Section 8(1) of the Occupational Health and Safety Act, 1993 requires every employer to provide and maintain, as far as is reasonably practicable, a working environment that is safe and without risk to the health of employees. Section 8(2)(d) requires the employer to establish what hazards to health or safety are attached to the work, substances, plant and machinery in the business, and what precautionary measures should be taken, and to provide the means to apply them. Section 8(2)(b) puts eliminating or mitigating hazards before personal protective equipment. The Act sets no interval; the regulations below do.
The risk assessments the regulations require
Each set of regulations has its own exposure risk assessment and maximum interval:
Hazardous chemical agents: Regulations for Hazardous Chemical Agents, 2021, regulation 5(1): an assessment immediately, and thereafter at intervals not exceeding two years.
Noise: Noise Exposure Regulations, 2024, regulation 7(1): before exposure, as far as is reasonably practicable, then at intervals not exceeding 24 months, by a competent person.
Physical agents: Physical Agents Regulations, 2024, regulation 6(1): a documented assessment before exposure, as far as is reasonably practicable, then at intervals not exceeding 24 months, by a competent person.
Ergonomics: Ergonomics Regulations, 2019, regulation 6: by a competent person before work that may expose employees to ergonomic risks starts, and at intervals not exceeding two years.
Biological agents: Regulations for Hazardous Biological Agents, 2022, regulation 6: conducted by a competent person and reviewed at intervals not exceeding 24 months.
Lead: Lead Regulations, 2001, regulation 6(1): an assessment at intervals not exceeding two years.
Asbestos: Asbestos Abatement Regulations, 2020, regulation 5(1): once asbestos is identified, immediately by a competent person, then at intervals not exceeding 24 months.
Several also require an immediate review when things change. The chemical agents regulations require one where there is reason to suspect the previous assessment is no longer valid, or where a process, method, equipment or procedure has changed (regulation 5(5)). The biological agents regulations add incidents and medical surveillance findings (regulation 6(6)).
What a health risk assessment covers
A health risk assessment brings these duties together for one site. A sound one:
identifies every health hazard: chemical, physical, biological and ergonomic;
groups employees by area and task, and identifies who may be exposed and how;
estimates how much and how often each group is exposed, using existing monitoring results;
evaluates the controls in place, with engineering controls ahead of personal protective equipment;
ranks the risks and sets an action plan with owners and dates;
shows where monitoring, medical surveillance and training are required.
The ergonomics regulations spell out a similar minimum: a complete hazard identification, the persons who may be affected and how, the analysis and evaluation of the risks, and their prioritisation (regulation 6(2)(b)).
Who may do it
The noise, physical agents, ergonomics, biological agents and asbestos regulations require a competent person. The noise, physical agents and ergonomics regulations define one as a person with the required knowledge, training and experience in that specific agent, and relevant qualifications where applicable, who is familiar with the Act and the applicable regulations. The chemical agents and lead regulations do not say who must carry out the assessment, but require the employer to consult the health and safety representative or committee.
None of these regulations requires the risk assessment itself to be done by an approved inspection authority, but for asbestos an approved inspection authority must review and endorse the assessment and inventory at intervals not exceeding six years, unless one did the work (regulation 5(7)). Some monitoring also requires one: noise monitoring by an approved noise inspection authority (Noise Exposure Regulations, regulation 8(2)(b)), and lead air monitoring by an approved lead inspection authority or a person it has verified (Lead Regulations, regulation 7(1)(c)).
A quick self-check
List the hazards on your site against the seven areas above, and find the date of the last assessment for each.
Book a new assessment for any that is older than two years, or soon will be.
Check who did each assessment, and whether they have knowledge, training and experience in that specific hazard.
List what has changed since: new chemicals, processes, machines, buildings, incidents or medical findings. Each may require an immediate review.
Check that the findings were turned into monitoring, medical surveillance and training programmes.
How Qualitas can help
Our health risk assessments cover chemical, physical, biological and ergonomic hazards per area and task, each against the regulation that applies to it. The report, written for management, SHEQ teams and auditors, gives risk ratings, existing controls, the monitoring each regulation requires and an action plan for your medical surveillance programme.
Where monitoring is needed, Qualitas Occupational Consulting is a Department of Employment and Labour Approved Inspection Authority and a SANAS-accredited (ISO/IEC 17020) inspection body for asbestos, lead, noise and hazardous chemical agents. See also our guides to approved inspection authorities and competent persons and preparing for a Department of Employment and Labour inspection.
Not sure what your site needs? Start with our free Compliance Gap Analysis, request a quote, or call or WhatsApp 082 649 6599.
This article is general guidance based on section 8 of the Occupational Health and Safety Act, 1993 and the regulations named above. It is not legal advice; refer to the Act and the regulations for the full requirements.
Christo de Wet is a SAIOH-registered occupational hygienist with 15 years' experience and the founder of Qualitas Occupational Consulting.
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