Guidelines for Risk Assessment
LSB Notification No. 0310001, March 10, 2006
Greater diversification and complexity in production processes as well as increased use of new machinery, equipment and chemical substances have been giving rise to a wide variety of causes of industrial accidents, and have been making it difficult to identify any specific cause.
In view of this situation, to raise the level of safety and health in workplaces, Paragraph 1 of Article 28-2 of the Industrial Safety and Health Act (Act No. 57, 1972; hereinafter referred to as the “Act”) requires employers to comply with the standards for preventing hazards that are specified in laws and ordinances related to industrial safety and health as minimum requirements. In addition, these provisions also require employers to voluntarily conduct assessment of risks in each workplace that may be associated with structures, facilities, raw materials, gases, vapors, dust, etc., or that may be attributable to working behaviors or other work-related factors (hereinafter referred to as “risk assessment”), and mandate that they take necessary measures to prevent workers from being exposed to risks or health impairments based on the results of such risk assessment.
Pursuant to the provisions of Paragraph 2 of Article 28-2 of the Act, these Guidelines specify the basic concept and actions to facilitate the appropriate and effective implementation of these measures at each workplace, thereby encouraging employers to more often conduct voluntary safety and health activities.
Based on these Guidelines, more detailed guidelines focusing on specific types of risks or hazards shall be separately developed. Such detailed guidelines include the Guidelines for the Necessary Measures to Prevent Health Impairments to Workers Due to Chemical Substances, Etc. and guidelines on machinery safety stipulated by the director general of the Labour Standards Bureau of the Ministry of Health, Labour and Welfare.
These Guidelines shall be designed to address the risk assessment and associated measures as stipulated in the Guidelines on Occupational Safety and Health Management Systems (Ministry of Labour Notification No. 53, 1999).
These Guidelines shall be applicable to all hazards inherent in work performed by workers that may be associated with structures, facilities, raw materials, gases, vapors, dust, etc., or that may be attributable to working behaviors or other work-related factors (hereinafter referred to as “hazards”).
The employer shall implement the following items as part of the risk assessment and measures to be taken based on the results of such risk assessment.
- The identification of hazards relative to job performance by workers
- An estimation of the severity and the extent of possibility of occurrence of injuries or diseases that might be caused by the hazards identified in item (1) (hereinafter referred to as “risks”)
- Setting priorities to reduce the risks estimated under item (2), and examining measures to reduce risks (hereinafter referred to as “risk reduction measures”)
- Implementing risk reduction measures in accordance with priorities set under item (3)
- The employer shall implement risk assess-ment and control measures under the following organization.
- The employer shall have the person who supervises and manages an overall business undertaking (who assumes the highest position in a workplace), such as a general safety and health manager, supervise and manage the implementation of risk assessment and control measures.
- The employer shall have a safety supervisor, a health supervisor, etc., in a workplace manage the implementation of risk assessment and control measures.
- The employer shall have workers participate in related activities through opportunities such as a safety and health committee, a safety committee or a health committee.
- In implementing risk assessment and control measures, the employer shall strive to assign a person who is well acquainted with specific work details such as a foreman to identify hazards, estimate risks and examine risk reduction measures.
- In implementing risk assessment and control measures relative to machinery and equipment, the employer shall strive to have person(s) who have technical knowledge regarding the relevant machinery or equipment participate in such activities.
- The employer shall provide education and training programs necessary to implement risk assessment and control measures to persons designated in item (1) above.
- The employer shall implement risk assessment and control measures when work specified in “a” through “e” below is conducted.
- When a structure is installed, relocated, modified or dismantled
- When a facility is newly introduced or a change is made to a facility
- When a raw material is newly adopted or changed
- When a working method or working procedures are newly adopted or changed
- Otherwise, when risks perceived in a workplace change or are likely to change, such as in the following cases:
- If an industrial accident occurred and problems were found in the contents of risk assessment and control measures conducted in the past
- Because of the elapse of a certain period after the most recent risk assessment and control measures, when the quality of machinery, equipment, etc., has been degraded due to aging, when workers do not have adequate knowledge and/or experience relative to safety and health due to turnover, or when new safety and health expertise is acquired
- The employer shall recognize that it is necessary to implement risk reduction measures before the start of work specified in “a” through “d” of item (1) above.
- It is also desirable for the employer to conduct risk assessment and control measures when plans relative to “a” through “d” of item (1) above are formulated.
Determination of Risk Assessment and Control Measures
Based on the following considerations, the employer shall determine what work is subject to risk assessment and control measures.
- Work in which the occurrence of injuries or diseases due to hazards associated with that specific work is reasonably foreseeable, such as work in which an industrial accident or a hazardous incident occurred in the past, shall be subject to risk assessment and control measures.
- Of work specified in item (1) above, work that is expected to cause only minor injuries or diseases such as walking on a flat walkway can be excluded.
Collection of Information
- When implementing risk assessment and control measures, the employer shall gather the materials listed below and make use of the information contained in such materials. In gathering the materials, the actual situation of work sites shall be taken into consideration, and not only materials concerning routine work but also those related to non-routine work shall be gathered.
- Work standards, operation procedures, etc.
- Information concerning hazards relative to machinery, equipment, materials, etc., that are used, such as specifications and material safety data sheets (MSDS)
- Information on the peripheral work environment such as the layout of machinery and equipment, etc.
- The results of working environment measurements, etc.
- Information on situations where multiple employers conduct work in one place, such as danger arising from several kinds of operations performed in a single location
- Actual cases of occurrences of accidents and statistics on accidents, etc.
- Other materials and information relevant to implementing risk assessment and control measures
- When gathering information, the employer shall take note of the following matters.
- When the employer plans to introduce new machinery, equipment, etc., the employer shall require the manufacturer of such machinery, equipment, etc., to conduct risk assessment and control measures at the design and production stages of said facility and shall obtain the results of such risk assessment and control measures.
- When the employer plans to use or remodel machinery, equipment, etc., that is not owned by the employer, the employer shall obtain the results of risk assessment and control measures conducted by the person or company that owns management title over such facilities.
- When multiple employers conduct work in one location, each employer shall obtain the results of risk assessment and control measures conducted by the principal employer to prevent an industrial accident due to the performance of different types of work at one location.
- When multiple employers conduct work in a hazardous location such as a place where machinery, equipment, etc., may overturn, each employer shall obtain the results of risk assessment and control measures conducted by the principal employer regarding such hazardous location.
Identification of Hazards
- Based on work standards, etc., the employer shall examine work in detail on units necessary to identify hazards associated with job performance by workers, and shall identify hazards inherent in each work unit in accordance with the classification of hazards that is predetermined according to specific machinery, equipment, work, etc., in the workplace.
- In identifying risks or hazards as specified in item (1), the employer shall take into consideration the additional effect of worker fatigue, etc., on risks or hazards.
Estimation of Risks
- In order to determine priorities to reduce risks, the employer shall estimate risks using a method such as those described below, taking into consideration the severity and the extent of possibility of the occurrence of injuries or diseases that may be caused by hazards. However, with respect to diseases caused by chemical substances, etc., the employer can estimate risks in consideration of the level of toxicity of and the extent of exposure to chemical substances, etc.
- A method in which the severity of injuries or diseases and the extent of possibility of the occurrence of injuries or diseases are measured and plotted on vertical and horizontal axes, and risks are estimated by using a table in which risks are predetermined according to the severity and the degree of possibility
- A method in which the extent of possibility of the occurrence of injuries or diseases and the severity of such injuries or diseases are numerically expressed based on prescribed criteria, and such numerals are added or multiplied to estimate the degree of risk
- A method in which risks are estimated by separating the severity of injuries or diseases and the extent of possibility of the occurrence of injuries or diseases on a phased basis
- In estimating risks as specified in item (1), the employer shall take note of the following matters.
- Accurately identifying those persons who may suffer estimated injuries or diseases and the details of such injuries or diseases
- Estimating the severity of the most serious injuries or diseases by assuming the worst possible case, rather than using the severity of injuries or diseases that actually occurred in the past
- Because it is desirable to use common criteria to measure the severity of injuries or diseases regardless of their type, the employer shall principally use the number of days absent, etc., due to such injuries or diseases as the measurement criteria.
- Even if the existence of hazards is not proved, if there are reasonable grounds for suspecting hazards, the employer shall strive to estimate risks by assuming the existence of hazards based on such grounds.
- The employer shall estimate risks as specified in item (1) according to the characteristics of machinery, equipment, work, etc., for each type of injury or disease listed below.
- Physical accidents such as being caught in machinery or falling
- Physical effects of chemical substances that cause explosion and/or fire
- Poisoning by toxic chemical substances
- Physical hazards such as disorders caused by vibration
During this estimation process, the employer shall also consider the following matters.
- Reliability of functions or measures to prevent industrial accidents (hereinafter referred to as “safety functions, etc.”) such as the installation of safety devices and “off limits” measures as well as the ability to maintain such functions or measures.
- Possibility of undoing or ignoring safety functions
- Possibility of foreseeable intentional or accidental incorrect use or dangerous behavior, such as deviation from work procedures or errors in handling
Study and Implementation of Risk Reduction Measures
- The employer shall ensure that the measures required by applicable laws and ordinances are fully implemented. In addition, the employer shall study and implement measures for reducing risks in the order of priority given below.
- Measures to reduce or eliminate hazards associated with job performance by workers, starting from the design and planning stage, such as elimination or change of dangerous work
- Engineering measures to prevent or reduce risks such as the installation of interlocks and local exhaust ventilation systems
- Administrative measures such as the preparation of instruction manuals
- Use of personal protective equipment
- In studying measures as specified in item (1), the risk reduction measures to which a higher priority is given must be implemented in as many cases as possible, except for cases in which the burden incurred to reduce such a risk is substantially greater than the expected effect of preventing an industrial accident, leading to a significant imbalance between the cost and effect, and where the implementation of such measures is considered highly irrational.
- If a long time is required to implement appropriate risk reduction measures for risks that might lead to fatalities, residual disability or severe diseases, provisional measures shall immediately be taken.
The employer shall maintain a written record of the following activities.
- Examined and identified work
- Estimated risks
- Priorities established for risk reduction measures
- Contents of implemented risk reduction measures