5.1.3    Non-chemical Hazards

            The OPCW Health and Safety Office will give attention not only to chemical hazards, but to any hazard which a working environment may present to OPCW personnel. The dangers of explosives in working areas, including unexploded ordnance, may be a particular hazard to OPCW personnel, and must receive attention in the health and safety plan for any activity.  Attention will also be given to aspects such as radiation, noise, dust, mechanical, electrical and environmental hazards, the use of pressure vessels and lasers, etc.

5.2       RISK MANAGEMENT

5.2.1    General Considerations on Risk Management

            The fundamental principle to be observed in any location or operation involving hazardous environments (such as hazardous chemicals or explosives) is to limit the potential exposure to a minimum number of personnel, for a minimum period of time, and to a minimum amount of the hazardous material consistent with safe and efficient operations.

5.2.2    Detection and Monitoring

            Monitoring of the environment for the presence of hazards will be undertaken whenever possible, both before and during any operation. Monitoring shall be subject to national, site-specific and, when relevant, OPCW Regulations, as well as confidentiality. Approved monitors for Schedule 1 chemicals, preferably with alarms or, when appropriate, suitable, approved and agreed industrial equipment will be used at the inspection site to monitor  the presence of hazardous chemical substances. When selecting monitoring devices, consideration must be given to national and, when relevant, OPCW standards.

5.2.3    Protection

(a)        The use of protective clothing and equipment is the least desirable method of preventing exposure of personnel to hazardous chemicals.  Efforts must be made to reduce dependence upon protective clothing and equipment in hazardous environments through the reasonable use of engineering and administrative controls such as ventilation, isolation, and elimination of all non-essential entries into hazardous areas.  The appropriate risk assessment must demonstrate that such alternatives have been explored.

(b)        In addition to the initial risk assessment based on available information on possible hazards, the selection and use of protective clothing and equipment will also be based on monitoring results and operational requirements, bearing in mind the physiological limitations imposed by certain environments.

(c)        Keeping in mind that inspection teams will have to perform their duties in a wide range of locations and environments, the procurement of an appropriate range of safety and protective equipment is required.  No OPCW personnel shall be in a toxic industrial or Schedule 1 chemical operating area without being issued with appropriate safety and ocular/cutaneous/respiratory protection equipment.  Consideration must be given as required to other protective requirements (e.g. hard hats or safety shoes).

(d)        All protective clothing and equipment used by OPCW personnel must be approved by the Director-General or his designated representative on the advice of the Health and Safety Office of the OPCW. Such approval shall be based upon appropriate tests and procedures for certification and the provision of certificates of approval. During an inspection any specific protective clothing and equipment used by OPCW personnel must be approved by the Director-General or his designated representative on the advice of the Health and Safety Office of the OPCW.

5.2.4    Contamination Control

            All operations must be conducted with the objective of avoiding contamination, or limiting the spread of contamination where it already exists.  If contamination is unavoidable, appropriate decontamination equipment and procedures will be used, as identified in the health and safety plan for the operation in accordance with standards approved by the Director-General.

            5.2.5    Equipment

(a)        During the equipment procurement process by the OPCW, due consideration shall be given to the provisions contained in this Policy and complementary OPCW health and safety documents.  Equipment with the least amount of hazard to the operator that is consistent with specific inspection requirements shall be selected.

(b)        All OPCW equipment (not covered by paragraph 5.2.3 (d)) for use in hazardous environments must be approved by the Health and Safety Office. Only equipment that sufficiently ensures the health and safety of OPCW personnel, in accordance with OPCW requirements, will be selected.

5.3       HEALTH AND SAFETY REQUIREMENTS

5.3.1    OPCW Standards

            The means by which this policy will be implemented is contained in the OPCW Health and Safety Regulations. Guidance for the application of these Regulations is contained in the OPCW Health and Safety Guidelines document.

5.3.2    National Health and Safety Standards

(a)        Considerable variation exists in national health and safety standards.  The Head of the Health and Safety Office shall ensure that due regard is given to meet these standards by the OPCW during the planning and conduct of activities. The Health and Safety Office shall establish and maintain a database of the relevant, principal health and safety regulations of Member States. Subject to the approval of relevant national or local authorities, on the basis of inspected site safety and confidentiality, additional health and safety measures may need to be provided or arranged as appropriate to comply with OPCW standards.

(b)        States Parties are obligated to render all possible agreed assistance to OPCW personnel in medical, health or safety-related issues. Where national health and safety standards are different from those adopted by the OPCW, the provisions of paragraphs 3.3 and 5.5.1 will apply.

(c)        Inspections will be preceded by the preparation and adoption of a written health and safety plan that will include provision for compliance with required OPCW and, where appropriate, national health and safety standards.  Decisions on the need to include health and safety personnel and equipment on the inspection will be based on the type of inspection and its location. Compliance with national standards and site regulations during all types of inspections, particularly in the absence of prior relevant agreement (e.g. challenge inspections or alleged use) will require discussion with representatives of the inspected State Party and the possible modification of the health and safety plan at the POE or at the site.

5.3.3    Local Health and Safety Considerations

(a)        OPCW personnel engaged in inspection activities in various parts of the world will encounter varying degrees of health and safety risk.  The Head of the Health and Safety Office must ensure that due regard is given to such variations during the planning and conduct of activities, and must also ensure that appropriate measures are contained in the written health and safety plan.

(b)        Health and safety planning must take account of the unique requirements presented by specific types of OPCW inspections or other activities.

5.3.4    Packaging and Transportation of Hazardous Chemicals

            The overall objective of packaging and labelling is to ensure that materials can withstand the risks of handling, the shocks of transportation, and can be correctly identified.  Adequate packaging and labelling must be accomplished prior to any movement of hazardous substances or environmental samples, and must be in accordance with the relevant national or international codes or regulations.

5.4       HEALTH AND SAFETY WITHIN THE OPCW

5.4.1    Medical Support

(a)        A comprehensive medical and health plan must be developed for the OPCW by the Health and Safety Office, and must take account of the health requirements for the OPCW as a whole.  Its basic elements would include provision for preventive medicine measures, a protective programme, and up-to-date medical care/treatment/rehabilitation aspects. Effective procedures must be developed for emergency medical evacuation from deployment sites.

(b)        A medical surveillance programme must be implemented, including pre-employment, periodic, episodic and termination examinations as appropriate for the job description of individual persons. The plan shall also contain procedures for the co-ordination of the efforts, rights and obligations of the medical service of the inspected State Party (or Host State) and of the medical representatives of an inspection team.

(c)        A medical documentation system will be adopted that makes appropriate provision for the proper maintenance of personal medical records.  Records will be maintained of cumulative exposures and monitoring/surveillance results during deployments, and a medical summary record will be compliled to accompany deployments for all personnel.   Non-confidential statistical data on accidents, illness, etc. will be collected and provided to the management of the Technical Secretariat at regular intervals. All data concerning an inspector's health, including the dynamics of its changes, as well as information about acute and cumulative effects should be placed in a specially designed database.

(d)        Medical support for OPCW operations will include provision for health maintenance based on local conditions, medical response to toxic exposures, and medical treatment and evacuation after accidents, trauma, and serious illness. A heat-illness prevention programme will be developed and implemented during all operations using protective clothing.

5.4.2    General OPCW Building and Office Safety

            The OPCW Health and Safety Office will consider the health and safety of all OPCW personnel in all working environments.  This extends from hazardous inspection locations to administrative offices. The Health and Safety Office will implement a comprehensive OPCW Building safety plan.

5.4.3    Laboratory Safety

            Hazardous chemical operations and storage which are performed in the OPCW Laboratory will be subject to the OPCW Health and Safety Regulations. When operating in other national laboratories, the provisions of para. 3.3 above will apply.  Regarding the OPCW Laboratory, due regard must be given to safe design features, access control, and good laboratory practice.

5.5       HEALTH AND SAFETY PRINCIPLES DURING INSPECTIONS

5.5.1    Inspection Team Members

            To ensure the health and safety of inspection team members and of the inspected site without impairing confidentiality during all inspections, particularly challenge inspections, and subject to the provisions of the Convention, the following procedures shall apply whenever the inspected State Party deems appropriate:

(a)        the use of any safety equipment shall be subject to agreement before the inspection begins. The agreement (e.g. facility agreement, managed access rules) shall be subject to the need to meet site-specific safety and confidentiality considerations in accordance with site safety rules and regulations, particularly when pertaining to sensitive areas of an inspected site;

(b)        after reaching agreement on the use of health and safety equipment the inspected State Party will provide the health and safety equipment, including, inter alia, personal monitors, protective clothing and masks, provided the equipment meets OPCW standards and Regulations, as applicable; and

(c)        at the end of an inspection, if the inspected State Party so requests, any piece of health and safety equipment involved in the inspection activities will be left on the site of the inspected State Party in order to comply with Health and Safety Regulations and/or in order to prevent the disclosure of confidential information. Where this provision is invoked, the inspected State Party shall make arrangements for the immediate replacement of the OPCW equipment. In the particular case of a challenge inspection, any replacement of health and safety equipment could be subject to the provisions of Article IX, para. 23.

            5.5.2    Health and Safety Considerations for Observers

(a)        Due to the unique situation of the observer participating in a challenge inspection, including the lack of control over health and safety background and training, neither the OPCW nor the inspected State Party can take full responsibility for the observer's health and safety.  However, where reasonable and practical, the OPCW and the inspected State Party will provide the observer with medical care, assistance and information to ensure compliance with the OPCW health and safety plan for the inspection and any relevant national or site-specific regulations, as the inspected State Party deems appropriate. Costs so incurred shall be borne by the requesting State Party.

(b)        The requesting State Party shall take all necessary measures prior to departure to prepare the observer within the area of health and safety, according to the identified or anticipated level of risk to be encountered during the challenge inspection. Documentation of such preparation (e.g. medical and training records, etc.) in the format specified in the OPCW Health and Safety Regulations shall be provided by the observer to the inspected State Party prior to the commencement of inspection activities. The inspected State Party shall provide the observer with, as appropriate, the same health and safety information  as provided to the inspection team.

(c)        The observer, with the guidance of the inspection team leader, shall at all times comply with the relevant provisions of the OPCW health and safety plan, as well as with any  national or site-specific regulations.  The observer cannot take any independent actions during inspections.

6.         Training

6.1       Training is the single most important tool available to the OPCW to enable individuals to take responsibility for their own health and safety and to make optimum use of the equipment and procedures provided by the OPCW.

6.2       The Director-General of the OPCW is responsible for ensuring that health and safety protection issues are adequately covered in training programmes, and that re-training/update courses occur on a regular and adequate basis. Standards of training in safety-related subjects must be monitored by the Health and Safety Office of the OPCW, wherever such training may occur.  The Director-General is responsible for the safety of training methods used by the OPCW, which must be approved by the Director-General or his designated representative on the advice of the Head of the Health and Safety Office.

6.3       Training in all safety-related procedures must be practically oriented, with an adequate theoretical background.  For those personnel that need certification for the use of protective clothing and equipment, training must include test exposures to a challenge agent (using 2-Chlorobenzal malanonitrile [CS] or other suitable training agents).  There must be emphasis on the development of equipment familiarity and confidence.

6.4       The OPCW shall provide specialist training modules for the training and qualification of OPCW health and safety personnel. 

6.5       Safety-related training must be followed by assessment and

qualification of personnel.

6.6       It is essential that minimum proficiency standards for key safety-related activities are specified, achieved, and maintained.  The range of activities for which an individual will be expected to maintain proficiency will depend on the duties assigned, and will be specified in the relevant post description.  The Head of the Health and Safety Office will be responsible for ensuring that proficiency standards are met and maintained.

7.         WAIVERS

7.1       A fundamental principle of the OPCW is strict adherence to its Health and Safety Policy and Regulations and the Health and Safety Guidelines, and the  avoidance of all waivers. 

7.2       In situations where it is necessary to deviate from strict compliance with the OPCW Health and Safety Regulations in order fully to meet the object and purpose of the Convention, a team leader may seek a temporary release from the Regulations. Any such release would have to be fully evaluated and justified in a formal request for the granting of a waiver by the Director-General on the advice of the Head of the Health and Safety Office.

7.3       Waivers may be granted only by the Director-General of the OPCW, who:

(a)        will ensure the existence of compelling operational reasons for the granting of a waiver;

(b)        will ensure that adequate compensatory or complementary measures are in effect, when applicable; and

(c)        will take note of an inspected State Party's right to protect sensitive installations, and to prevent the disclosure of confidential information and data, not related to the Convention.

7.4       The Director-General may delegate waiver authority to a designated representative if he believes it to be necessary for operational reasons or to meet specific provisions of the Convention.

8.         AMENDMENTS

8.1       Proposed amendments to the OPCW Health and Safety Policy shall be submitted by the Director-General to the Conference of States Parties for formal approval.

8.2       Proposed amendments to the OPCW Health and Safety Regulations shall be submitted to the Executive Council for approval pending confirmation by the next meeting of the Conference of State Parties.

8.3       Amendments to OPCW Health and Safety Guidelines, in line with the approved Policy and Regulations, shall be approved and implemented by the Director-General.

8.4       Once approved, amendments shall be implemented by the Director-General as soon as practicable, or in any case within 30 days.

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