UV Protection Safety Compliance & OHS Requirements

Ensuring compliance with South African occupational health and safety regulations for UV radiation protection is both a legal requirement and a moral obligation to protect workers from preventable harm.

Legal Compliance Notice

Under the Occupational Health and Safety Act (OHSA) 85 of 1993, employers are legally required to provide a safe working environment, including protection from UV radiation hazards.

South African Regulatory Framework

OHSA Act 85 of 1993

General Duties of Employers (Section 8)

  • Provide and maintain a working environment that is safe and without health risks
  • Identify hazards including UV radiation exposure
  • Eliminate or mitigate any hazard before resorting to PPE
  • Provide necessary PPE including UV protection

Environmental Regulations for Workplaces

Regulation 2: Assessment of Exposure

  • Employers must assess UV radiation levels in workplaces
  • Document exposure times and intensity
  • Identify all workers at risk
  • Review assessments when processes change

Hazardous Chemical Substances Regulations

UV-Reactive Chemicals

  • Additional protection required when UV interacts with chemicals
  • Risk assessments must consider photochemical reactions
  • Special measures for coal tar, creosote, and solvents
  • Enhanced protection protocols required

Construction Regulations 2014

Specific UV Requirements

  • Principal contractor must address environmental hazards
  • Health and safety specifications must include UV protection
  • Site-specific safety plans must address outdoor work
  • Mandatory provision of sun protection measures

Employer Legal Obligations

1. Risk Assessment Requirements

UV Radiation Risk Assessment Must Include:

  • Source identification: All UV sources (natural and artificial)
  • Exposure duration: Time workers spend in UV conditions
  • Intensity measurement: UV index levels and artificial source output
  • Worker categories: Identify high-risk job positions
  • Existing controls: Evaluate current protection measures
  • Chemical interactions: Assess photosensitive substance use

2. Hierarchy of Controls

1. Elimination

Remove UV exposure where possible (e.g., relocate work indoors)

2. Substitution

Replace high UV processes with safer alternatives

3. Engineering Controls

Install UV shields, provide shade structures, use UV-filtering glass

4. Administrative Controls

Rotate workers, schedule work during low UV times, implement procedures

5. Personal Protective Equipment

UV barrier cream, protective clothing, UV-rated eyewear

3. Provision of UV Protection

Employers Must Provide:

  • ✓ Broad-spectrum UV barrier cream (UV-A, UV-B, UV-C protection)
  • ✓ Adequate quantities for all exposed workers
  • ✓ Application facilities and time for reapplication
  • ✓ Training on proper application techniques
  • ✓ Storage facilities to maintain product effectiveness
Non-Compliance Risk: Failure to provide adequate UV protection can result in work stoppage orders, fines, criminal prosecution, and civil liability for resulting health conditions.

UV Protection Implementation Standards

Minimum Protection Requirements

UV Type Required Protection Level Application Standard
UV-A Minimum 90% blockage All exposed skin areas
UV-B Minimum 95% blockage 2-hourly reapplication
UV-C 100% blockage required Before any exposure

Application Protocols

  1. Pre-shift application: 15 minutes before UV exposure
  2. Coverage: All exposed skin including neck, ears, face, hands
  3. Quantity: 2mg/cm² of skin (approximately 30ml per application)
  4. Reapplication: Every 2 hours or after sweating/washing
  5. Documentation: Log application times and quantities

Mandatory Training Requirements

UV Safety Training Programme Content

Module 1: UV Hazard Awareness

  • Types of UV radiation and sources
  • Health effects (immediate and long-term)
  • High-risk activities and areas
  • UV index understanding

Module 2: Protection Methods

  • Proper application of UV barrier cream
  • PPE selection and use
  • Engineering control utilisation
  • Safe work procedures

Module 3: Emergency Response

  • Recognising UV overexposure symptoms
  • First aid for UV burns
  • Reporting procedures
  • Medical surveillance requirements

Module 4: Compliance & Documentation

  • Legal requirements overview
  • Record keeping obligations
  • Incident reporting
  • Worker rights and responsibilities

Training Frequency:

  • Initial training: Before first UV exposure
  • Refresher training: Annually
  • Update training: When processes or regulations change
  • Toolbox talks: Monthly UV safety reminders

Required Documentation & Record Keeping

Risk Assessments

  • UV exposure assessments
  • Job hazard analyses
  • Control measure evaluations
  • Review dates and updates

Retention: 5 years minimum

Training Records

  • Attendance registers
  • Training content covered
  • Competency assessments
  • Trainer qualifications

Retention: 5 years minimum

Medical Surveillance

  • Pre-employment skin examinations
  • Annual skin checks
  • UV exposure history
  • Incident reports

Retention: 40 years

PPE Records

  • UV cream issue registers
  • Usage quantities
  • Product specifications
  • Effectiveness testing

Retention: 3 years minimum

UV Protection Compliance Checklist

Use this checklist to ensure full compliance:

Assessment & Planning

  • □ UV radiation risk assessment completed
  • □ All UV sources identified and documented
  • □ Worker exposure times recorded
  • □ Control measures hierarchy applied
  • □ Written safe work procedures developed

Protection Provision

  • □ Broad-spectrum UV barrier cream stocked
  • □ Adequate quantities for all workers
  • □ Application facilities available
  • □ Storage conditions appropriate
  • □ Reapplication schedule implemented

Training & Communication

  • □ All workers trained on UV hazards
  • □ Application training completed
  • □ Signage posted in UV areas
  • □ Safety talks include UV topics
  • □ Emergency procedures communicated

Monitoring & Records

  • □ Medical surveillance programme active
  • □ Training records maintained
  • □ Incident reporting system in place
  • □ Regular compliance audits conducted
  • □ Documentation retention compliant

Legal Consequences of Non-Compliance

Criminal Liability

  • Fines up to R100,000
  • Imprisonment up to 2 years
  • Personal liability for directors/managers
  • Criminal record implications

Civil Claims

  • Worker compensation claims
  • Common law damages
  • Loss of income claims
  • Medical expense liability

Operational Impact

  • Work stoppage orders
  • Prohibition notices
  • Increased insurance premiums
  • Reputational damage

Ensure Compliance Today

Don't risk worker health, legal consequences, or operational disruptions. Implement comprehensive UV protection measures that meet all regulatory requirements.

Benefits of Compliance:

  • ✓ Legal protection for your business
  • ✓ Reduced worker compensation claims
  • ✓ Improved worker health and productivity
  • ✓ Enhanced company reputation
  • ✓ Lower insurance premiums