AMENDED OCCUPATIONAL EXPOSURE LIMITS IMPOSSIBLE TO COMPLY WITH
The Department of Employment and Labour (DoEL), on 5 April 2024, published new Draft Regulations for Hazardous Chemical Agents for public comment.
One of the most concerning amendments contained in the draft regulations, is the lowering of the occupational exposure limit (OEL) for Styrene from 40ppm to 20ppm. The OEL for Styrene was originally, in the Hazardous Chemical Substances (HCS) Regulations of 1995, set at 100ppm, which was changed in 2021 to 40 ppm.
Synthetic Styrene is an important raw material for various industries because it is the chemical ‘building block’ for creating a multitude of versatile plastics and synthetic rubbers with beneficial properties including strength, durability, comfort, lightweight, safety, and energy efficiency.
As a result, nearly everyone encounters Styrene-based products in some form every day.
Materials made with Styrene can be found in many items, across various industries, including but not limited to:
- Leisure: marine equipment and boat hulls.
- Transport: car- and truck parts, tanks and rubber tyres.
- Construction and building: rebar, building insulation, gratings, pipes and swimming pools.
- Mining: mine bolts.
- Coatings: adhesives and carpet backing.
- Sanitaryware: baths, basins, shower stalls and countertops.
- Packaging: polystyrene.
- Renewable energy: batteries and wind turbines.
- Information Technology and manufacturing: computer parts.
Employees who manufacture or use any of the above items may breathe in Styrene in the workplace. Workers may also absorb Styrene through the skin.
The effects of this lowering of the OEL of Styrene has the following implications on all businesses in industries that manufacture or use any of the above listed products and/or materials:
- all policies and procedures regarding a business’ occupational health and safety will have to be amended to adhere to the new OEL of the relevant hazardous materials;
- all tests of employees for exposure to these materials will have to ensure that the results of these tests adhere with the new lowered limits;
- all workstations and -environments where exposure to these materials occur, will have to be redesigned or re-equipped in order to ensure that exposure is limited, in order to comply with the relevant limits, which may include but is not limited to:
- introduction of, or increasing of ventilation;
- introduction of, or increasing of personal protective equipment (PPE);
- improved packaging and/or transportation of the relevant hazardous materials;
- decreasing of employees’ long- and short time exposure to the materials by amending their shift durations; and
- adapting or shifting to the use of alternative, safer materials, where and if possible.
Naturally, these implications come with great costs and expenses to all businesses in industries that use or manufacture any of the relevant materials. In addition, adapting their operations to the new OELs and complying with the new regulations will be extremely time consuming for these businesses.
NEASA’s members in the boating industry have confirmed that they will be requesting the DoEL not to implement the regulations for another ten years, so as to allow all stakeholders to start their processes of adaptation to the new requirements.
Consequently, NEASA urges all affected stakeholders, employers and businesses to submit their written comments and representations, in the prescribed format, to the DoEL on or before 4 July 2024, by sending it via email to
