Monday, December 8, 2014

Step 6: Test

Pilot the Alternative

Plan the technical and organizational changes needed on a smaller, pilot scale, before fully implementing the alternative. This step will help you test and evaluate the change in order to identify successes and failures and recognize long-term impacts or problems.

Key Questions

  • Does the alternative perform well?
  • Does the alternative change working conditions?
  • What training do workers need to safely and effectively use the alternative?
  • Are there any unforeseen effects or trade-offs of using the alternative?
  • Is there a secure supply of the alternative?
  • How could the alternative be implemented on a larger scale?
Before shifting completely to a safer alternative, it is important to apply the change on a smaller scale, especially if you are making a complex change. For some alternatives, you may need to conduct a field testing program to make sure the preferred alternative meets your performance expectations and product quality requirements, and that any unforeseen changes in use patterns or exposure are identified. Performance and quality can be affected in the process itself, as well as in any related upstream or downstream processes.

To get the best results, it is important to involve the workers who will be impacted by the change. You should discuss when and how to make the change and ensure that workers are trained and feel comfortable working with the alternative chemical, product, or process before the testing begins.

During the pilot or field testing of the alternatives, consult and involve workers to assess the performance, cost, and health and safety impacts on the work environment. It is also important to identify and evaluate any potential unexpected problems that occur, including any shift in risks or new hazards presented by the alternative (e.g., ergonomic, noise, vibration, environmental impacts, fumes and gases formed in the process). You may also consider developing a job hazard analysis [PDF*] to describe the changes and identify hazards involved with shifting to a safer alternative. To ensure that the alternative is not negatively impacting workers, you should consult your OSHA 300 logs to identify any unexpected injuries or illnesses that may be associated with the use of the alternative. Modifications to the choice of chemical, process or work practice alternatives may be necessary as a result of this pilot testing.

Key Example

Pollution Prevention-Occupational Safety and Health Work Site Assessment (P2OSH)

Researchers from the University of Massachusetts, Lowell, developed the P2OSH strategy for identifying, implementing, and evaluating pilots of safer alternatives. A key component of this strategy is a work site assessment survey that can be used before and after piloting a safer alternative to collect information on the work environment, the materials used in the process, the potential impact of changing materials on the safety and health of affected workers, the workers’ perceptions of the pilot, and the direct costs associated with the pilot. The results of this survey can be used to compare worksite changes, evaluate the technical function of the alternative, and determine whether a full scale implementation of an alternative is appropriate or what changes are needed to better protect the health and safety of workers.
P2OSH strategy

Friday, November 7, 2014

Select a Safer Alternative: Select Alternative

Select Alternative

During the selection of alternatives, you should consider the advantages and disadvantages of each alternative with regards to hazard, performance, and cost, and identify any trade-offs that exist. You may want to develop a table or spreadsheet that outlines the pros and cons of each option and their importance in the selection process. Or you may develop some sort of scoring system that weighs different attributes – safety, performance, and cost.
The selection of a preferred alternative should be directly linked to the goals of your organization and your project. You should consult the team and use your company goals and work plan for transitioning to safer chemicals, as well as any chemical use policy, to weigh the various hazard, performance, and cost criteria or make decisions regarding trade-offs. You should also determine whether there are other impacts of the alternatives, including, but not limited to energy use, water use, environmental impacts, hazardous waste impacts, and upstream or downstream hazards to workers that are important to consider in your decision.
Worker input is also important during the selection process. It may be helpful to openly discuss any drawbacks and benefits of the options, as well as practical considerations of implementation, with the team as well as with any other workers who might be affected by a change.
Once you have selected an alternative for your particular application, you should communicate the decision to all relevant parties, particularly those who will work with the alternative chemical, material, product, or process. You should document the decision-making process, including the thought process, assumptions, and rationales used, so the decision can be clearly explained, justified, and understood by others. Conducting training might be an efficient way to communicate these changes; trainings may also fulfill legal requirements of communicating hazards to employees, depending on the alternatives selected.

Key Example

Massachusetts Toxics Use Reduction Institute’s Perchloroethylene Alternatives Assessment

In its assessment of seven alternatives to the use of perchloroethylene (perc) in drycleaning, the Massachusetts Toxics Use Reduction Institute developed a table summarizing the comparison of the alternatives and perc, based on technical, economic, environmental, regulatory and human health criteria. The table uses color coding to indicate the preferability of alternatives purely from an environmental health and safety perspective.
TURI Table Adapted from TURI’s Methods and Policy Report—Assessment of Alternatives to Perchloroethylene for the Dry Cleaning Industry.

Tuesday, October 28, 2014

Select a Safer Alternative: Key Questions & Display Results

Decisions that thoughtfully weigh the pros and cons of safer alternatives benefit your company and your workforce. This step will help you organize information on hazard, cost, and performance, as well as evaluate potential trade-offs, in order to select alternatives that will improve worker safety and health.

Key Questions:

  • What are the advantages and disadvantages of each alternative with regard to hazard, performance, and cost?
  • What trade-offs exist for each alternative?
  • How should the various criteria and impacts be weighed to select alternatives that best enhance worker safety and health?
  • Are there other considerations to weigh when determining the best option (energy use, water use, environmental impacts, hazardous waste management, upstream or downstream hazards to workers, etc.)?

Display Results:

After gathering information about potential alternative chemicals, materials, products or processes, it is important to organize the data for each alternative, including information about the data sources, quality, and gaps. Thoughtfully presenting the data gathered during an alternatives assessment can help facilitate the decision-making process. The Interstate Chemicals Clearinghouse provides some useful models for arraying data in ways that allow decision-makers to visualize gaps and identify tradeoffs.

Key Example

U.S. EPA’s Design for the Environment Program Alternatives Assessments

After completing an alternatives assessment, the Design for the Environment Program compiles hazard data for each alternative evaluated in order to facilitate decision-making. The results are presented qualitatively by endpoint and also clarify the origin of the data (i.e., experimental, estimated values, professional judgment).
Safer Alternatives Presenting

Wednesday, October 15, 2014

Assess & Compare: Assess Cost

Assess Cost

Finally, alternatives should be assessed and compared based on their cost. While a full cost-benefit analysis of all the alternative options is quite costly and not essential, it is important to thoroughly consider relevant cost impacts, both positive and negative, on your company. Completing such an economic analysis will also help you make the business case for transitioning to safer alternatives. Some costs and benefits that you might consider in your evaluation include:

Direct Costs

  • Capital expenditures
  • Operating costs
  • Material costs
  • Maintenance costs

Indirect Costs

  • Supervision and administrative costs
  • Regulatory compliance costs
  • Worker health and safety costs (PPE, lost employee time, etc.)
  • Waste management expenditures, including hazardous waste disposal costs
  • Insurance, rent, taxes

Liability Costs

  • Penalties and fines
  • Personal injury
  • Worker Compensation
  • Property damage
  • Clean-up costs
  • Natural resources damage

Less Tangible Benefits

  • Increased sales due to improved product quality, enhanced public image, consumer trust in greener products, or other effects
  • Reduced health maintenance costs due to a safer work environment
  • Improved worker productivity due to cleaner working conditions
  • Increased worker productivity due to improved employee relations

Key Example

Cost Assessment Methodology

European Commission’s Cost Assessment Methodology

The European Commission’s Guidance on Minimizing Chemical Risk to Workers’ Health and Safety Through Substitution provides a detailed table to help small and medium-sized businesses identify costs to take into account. The table includes parameters for evaluating material costs, equipment costs, safety costs, time related costs, waste costs, and the costs of risk. This table is also useful for presenting the impacts and consequences of a substitution to management.

Friday, September 26, 2014

Assess & Compare: Assess Performance

Assess Performance

Next, alternatives should be assessed and compared based on their performance. Selecting the relevant criteria is the first step of your evaluation. To ensure the alternative performs well, some performance parameters you might consider for your evaluation include:

Physical Properties

  • Density
  • Water solubility
  • Color
  • Boiling point/melting point
  • Flash point
  • Odor
  • Vapor pressure
  • Volatility
  • Viscosity
  • Size
  • Weight

Performance Characteristics

  • Durability
  • Longevity
  • Maintenance requirements
  • Energy consumption
  • Equipment requirements
  • Tensile strength
  • Tear strength
  • Compressibility
  • Flame retardancy
  • Accuracy
  • Resistance to shock/vibration
  • Noise level
  • Operating temperature
The relevant parameters may vary greatly from one application to another. Engaging the team, and any other workers, product designers, and production engineers, can help identify performance needs, as well as technical and engineering design restraints. You may also need to consult with suppliers and customers not only to identify the critical parameters for evaluation, but also to gather information about the performance of alternatives under evaluation.

Key Example

Toxics Use Reduction Institute’s Technical Performance Evaluation

As part of its 2006 Five Chemical Study, the Massachusetts Toxics Use Reduction Institute developed a model for evaluating the technical performance of alternative chemicals, materials, products, and processes. The study identified application-specific performance parameters that were required for each use of the chemicals under evaluation – including longevity, key performance requirements, key physical characteristics and key quality parameters. While applicable performance requirements vary greatly between uses, this evaluation method provides a good starting point for identifying criteria that should be considered.
Adapted from TURI Alternatives Assessment Process Guidance.

Tuesday, September 16, 2014

Step 4: Assess & Compare - Assess Hazard

Assess Hazard

After identifying the most promising alternatives, the hazard, performance, and cost of each alternative should be assessed and compared. Selecting the relevant hazard criteria is the first step of your evaluation. To improve worker health and safety, some hazards you might consider for your evaluation include:

Acute Health Hazards

  • Acute toxicity
  • Eye damage
  • Skin damage
  • Sensitization (e.g., skin, respiratory)

Safety Hazards

  • Corrosivity
  • Flammability
  • Reactivity
  • Explosivity
  • Oxidizing properties
  • Pyrophoric properties

Chronic Health Hazards

  • Chronic Toxicity
  • Target Organ Toxicity
  • Carcinogenicity
  • Mutagenicity/Genotoxicity
  • Reproductive Toxicity
  • Developmental Toxicity
  • Endocrine Disruption
  • Neurotoxicity
  • Immune System Effects

Use Hazards

  • Physical form of the chemical
  • Procedural hazards (e.g., open process, direct skin contact)
  • Ergonomic hazards
  • Noise hazards
  • Vibration hazards
Several existing resources identify hazards that could be included in your evaluation. SUBSPORT’s compilation of hazard criteria (health, environmental, and physical) provides information about which characteristics are associated with substances of concern. The EPA’s Design for the Environment Safer Product Labeling Program has also developed hazard criteria for chemicals used in formulated products. The Massachusetts Toxics Use Reduction Institute’s P2OASys Tool provides hazard criteria relevant to chemical, material, and process changes in the workplace.
As part of the hazard assessment, it is also important to understand whether alternatives will significantly change working conditions (i.e., the way in which the chemical is used by workers or the way in which workers are exposed to the chemical). This will allow you to identify any additional hazards the alternatives may present to workers. Be sure to consider upstream or downstream hazards to workers – in disassembly, making the new chemical, etc.
A number of tools are available to help you rapidly assess and compare health and physical hazards of identified alternatives. The Column Model, the Quick Chemical Assessment Tool, and the Green Screen™ can help assess and compare health, physical, and environmental hazards of identified alternatives.
Comparative chemical hazard assessment methods and tools rely on the collection of data from a variety of sources. The U.S. EPA DfE’s Alternatives Assessment Criteria *(PDF) document provides information on data quality considerations in evaluating and comparing chemical hazards and Clean Production Action’s Green Screen™ Tool identifies authoritative and screening data sources *(PDF) for each endpoint evaluated in the tool. While these resources can help you locate hazard information that is readily accessible, there are many chemicals for which this type of information is unavailable. In these cases, suppliers can also be a critical source of hazard information.

Key Example

The Column Model

The Column Model

The Institute for Occupational Safety and Health of the German Federation of Institutions for Statutory Accident Insurance and Prevention (IFA) developed the Column Model to help small and medium-sized businesses assess substitute substances on the basis of just a small amount of information derived from safety data sheets. The model is based on six hazard categories (acute health hazards, chronic health hazards, fire and explosion hazards, environmental hazards, exposure potential, and process hazards), which are divided into different risk levels, ranked from negligible to very high. Users identify the risk level for each substance using the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) hazard classifications and information about how the substance is used. Preferred substitutes are then identified by comparing the risk levels in each of the hazard categories. In most situations, alternatives do not have the lowest risk level in all hazard categories. Users must decide which potential hazards are more relevant for the workplace where the product is used, taking into consideration the possibilities to control or manage the different risks.

Key Example

Quick Chemical Hazard Assessment (QCAT)

The Quick Chemical Hazard Assessment (QCAT)

Developed by the Washington Department of Ecology, the Quick Chemical Assessment Tool (QCAT) is designed to help small and medium-sized businesses evaluate hazards associated with alternatives to toxic chemicals. QCAT uses a subset of nine high priority hazard endpoints (6 human health effects endpoints, persistence, bioaccumulation, and acute aquatic toxicity) to identify a level of concern for each chemical being evaluated. This evaluation places chemicals along a continuum of concern and assigns a chemical one of four possible grades (A, B, C, F). These results provide a quick and easy method to identify chemicals that are equally or more toxic than the chemical being reviewed, allowing users to leverage limited resources to rapidly identify chemicals that are not viable alternatives to the chemical being assessed.

Key Example

Pollution Prevention Options Analysis System (P2OASys)

The Pollution Prevention Options Analysis System (P2OASys)

The Toxics Use Reduction Institute developed the Pollution Prevention Options Analysis System (P2OASys) to help companies determine whether the options they are considering to replace chemicals, materials, products, or processes of concern may have unforeseen negative worker, public health, or environmental impacts. Companies using P2OASys input both quantitative and qualitative data on the chemical toxicity, ecological effects, physical properties, and changes in work organization as a result of the proposed option. The tool arrays data on a range of hazards and the chemical under evaluation receives a score, based on embedded formulae in an excel spreadsheet, for each type of hazard that indicates very low to very high risk. These scores can then be combined with other information sources and professional expertise to make decisions on the selection and adoption of alternatives.

Tuesday, August 19, 2014

Step 4: Assess & Compare

Systematically comparing the hazard, cost, and performance of different alternatives will enable you to make an informed decision. This step will help you assess and compare alternatives.

Key Questions

To prioritize alternatives for further assessment, consider:
  • What are the performance requirements of the chemical or process?
  • Do specific alternatives present a high risk to worker safety and health?
When assessing and comparing alternatives, consider:
  • What health and safety criteria (toxicological and physical properties) need to be compared?
  • Will workers experience changes to the performance of their work tasks when using the alternative, including any changes to the use of engineering controls, administrative controls, and PPE? Will workers experience changes in exposure when using the alternative? Will these changes present new/different hazards to workers?
  • What performance criteria need to be compared?
  • What costs need to be compared?

Prioritize

Once alternatives are identified, it is often necessary to prioritize them for further assessment. Focusing the work on the most promising alternatives is an effective way to use limited resources and avoid unnecessary research and evaluation.

Prioritizing alternatives based first on performance can help to narrow the scope of alternatives to those that have the potential to be effectively implemented in the workplace while maintaining process and product quality. To identify performance requirements for the chemical, material, or product that you are looking to replace, the planning team should consider what the chemical, material, or product needs to do and whether there are specific technical and engineering design constraints. Other functional requirements, such as quality criteria and customer or legal requirements for technical acceptability should also be considered.

Before further evaluating your options, you may also consider deprioritizing those alternatives that may result in new hazards or will not substantially improve worker safety and health. You can use existing restricted substances lists, authoritative lists of priority chemicals, and lists of chemicals of concern to rapidly identify alternatives that present worker safety and health concerns, are inconsistent with company goals, or may be subject to legal or consumer restrictions. While these options should not be the first you evaluate, they should not be completely eliminated from consideration. If you find, after further research and evaluation, that none of your first choice alternatives will work, you may decide to reconsider those options that, while having some concerns, could still be safer and healthier for workers in a particular application.

Friday, August 8, 2014

Step 3: Identify Alternatives

Further Resources

Case Studies

Danish Working Environment Authority. CatSub. This database is a catalog of more than 300 case stories describing successful substitutions with less hazardous chemicals.
Intergovernmental Forum on Chemical Safety. Substitution and Alternatives Case Studies, Examples and Tools. This resource provides case studies and examples for selected chemicals and chemical categories.
Massachusetts Office of Technology Assistance. OTA Case Studies. This website provides links to technology case studies that profile actual applications of pollution prevention technologies and processes that businesses, municipalities, and other toxics users across Massachusetts have implemented.
Massachusetts Toxics Use Reduction Institute. Toxics Use Reduction Case Studies. This website provides links to documents describing actual applications of toxics use reduction in a variety of industry sectors.
SUBSPORT. Case Story Database. This database provides substitution examples, as well as information on alternative substances and technologies from enterprises, published reports and other sources.

Databases of Alternatives

Cooperation Centre Hamburg. Cleantool. This database highlights best practices for the cleaning of metal surfaces and provides information about less hazardous parts cleaning, metal surface cleaning, component cleaning, and degreasing.
GreenBlue. CleanGredients®. This is an online database of cleaning product ingredient chemicals, providing verified information about the environmental and human health attributes of listed ingredients.
ISTAS. Alternativas de SustituciĆ³n (Spanish). This database provides information on alternative chemicals, technologies, and processes, as well as case examples of substitution.
Massachusetts Institute of Technology. Green Chemical Alternatives Purchasing Wizard. This database is designed to provide easy and quick access to information about available chemical alternatives to hazardous solvents.
Massachusetts Toxics Use Reduction Institute. CleanerSolutions Database. This database provides information about safer alternatives to hazardous solvents for surface cleaning.
U.S. EPA Design for the Environment Program. Safer Chemical Ingredients List. This list contains chemicals that meet the criteria of the Design for the Environment Safer Product Labeling Program.

Completed Alternatives Assessments

Institute for Research and Technical Assistance. Reports. This website provides links to completed alternatives assessments on a variety of topics.
Interstate Chemicals Clearinghouse (IC2). Examples of Alternatives Assessments. This website provides links to completed alternatives assessments on a variety of topics.
U.S. EPA Design for the Environment Program. Alternatives Assessments. This website provides links to completed alternatives assessments on a variety of topics.
U.S. EPA Design for the Environment Program. Publications. This website provides links to completed cleaner technologies substitutes assessments on a variety of topics.

Scientific Literature

Massachusetts Toxics Use Reduction Institute. TURI Library. This library focuses on information related to toxics use reduction. Its online public access catalog describes over 14,000 documents and provides links to documents freely available on the Web.

Friday, August 1, 2014

Step 3: Identify Alternatives

Identifying alternatives opens up the potential for finding more efficient, safer, and more sustainable solutions. This step will help you get a clear overview of your different options.

Identify

After targeting a chemical for substitution efforts, it is important to broadly consider all possible chemical alternatives, material alternatives, process changes, design changes, technological solutions, or other options to eliminate the hazardous chemical, even if particular options may be currently infeasible.
When looking for chemical alternatives, material substitutes, or process changes for a particular application/use, it is best to begin with industry-specific information and case examples about what is currently being used in the market. From there you can usually identify specific companies that are using alternatives; these companies are often good resources for identifying other alternatives they may be aware of or have tried. Talking to suppliers, workers, industry associations, government officials, professional associations, and non-governmental organizations can also provide information on existing alternatives.
Specific resources have been developed for researching alternatives to hazardous chemicals. These resources include case studies of substitution (SUBSPORT, CatSub, IFCS), databases of alternatives (Alternativas (in Spanish only), CleanGredients®, Cleantool), as well as completed alternatives assessments (Interstate Chemicals Clearinghouse). Performing a single search of multiple online resources related to substitution is another rapid way to identify possible alternatives.
Additionally, searching recent scientific literature may lead to discoveries of chemicals, materials, or processes that are being researched for the application, or for similar applications that have the same or similar performance requirements. The Massachusetts Toxics Use Reduction Institute’s technical research library of pollution prevention and chemical alternatives resources can help you locate this type of information about alternative chemicals, materials, products, and processes.
Where no alternatives exist, consider partnering with other businesses or trade associations to initiate innovative research on safer products and processes.

Key Resource

SubsPort Website

Case Story Database

SUBSPORT’s Case Story Database provides over 300 substitution examples as well as information on alternative substances and technologies from businesses, published reports and other sources. Substances mentioned in the case stories are evaluated for hazards and screened out of the database if they are identified as CMRs (carcinogens, mutagens, reproductive toxicants), PBTs (persistent, bioaccumulative, and toxic chemicals), endocrine disruptors, neurotoxicants, or sensitization agents.

Key Resource

CleanGredients

CleanGredients®

CleanGredients® is an online database of safer cleaning product ingredients that is a unique partnership between the nonprofit institute GreenBlue, the U.S. EPA, and industry. GreenBlue establishes health and environmental criteria for each chemical ingredient class with the input and approval of the U.S. EPA’s Design for the Environment Program. The database lists a variety of chemical ingredient classes necessary for formulators to make their products, including: surfactants, solvents, fragrances, chelating agents, colorants, enzymes, defoamers, starter formulations, processing aids, oxidants, polymers, and preservatives and antioxidants. Each of the listed ingredients is verified by third-party reviewers (NSF International and ToxServices) as meeting the established environmental and human health criteria. In addition, the database provides supplier contact information, links to websites, material safety data sheets, and technical fact sheets for each of the listed ingredients. This resource helps formulators identify ingredients that have potential environmental and human health benefits and helps suppliers showcase their chemicals with potential environmental and human health benefits.

Wednesday, July 23, 2014

Step 3: Identify Alternatives - Key Questions

Identifying alternatives opens up the potential for finding more efficient, safer, and more sustainable solutions. This step will help you get a clear overview of your different options.

Key Questions

  • Are there chemical alternatives that have been implemented in similar applications?
  • Are there material changes or process changes that could replace the use of hazardous chemicals?
  • Are there other businesses that are also seeking safer alternatives for the same chemical or a similar use of the chemical? Are there opportunities to collaborate?

Wednesday, July 2, 2014

Step 2: Examine Current Chemical Use - Further Resources

Creating Chemical Inventories

Massachusetts Department of Environmental Protection. Toxics Use Reduction Planning and Plan Update Guidance. *(PDF) This guidance describes and provides support for the toxics use reduction planning process, presents best management practices, and shares examples of actual toxics use reduction successes.

New Jersey Department of Environmental Protection. Industrial Pollution Prevention Planning. *(PDF) This report identifies twelve steps that can help firms identify and achieve pollution prevention opportunities.

NEWMOA. Energy and Materials Flow and Cost Tracker (EMFACT). This software tool helps companies systematically track materials and energy use; releases, discharges, and wastes; and associated costs in ways that can create value for their business.

Obtaining Product Chemical Information

Green Chemistry and Commerce Council. Meeting Customers’ Needs for Chemical Data: A Guidance Document for Suppliers. *(PDF) This document outlines resources that can assist suppliers in collecting and providing chemical information to their customers.

Assessing Chemical Hazard

ChemSec. SIN (Substitute It Now!) List. This database contains 626 chemicals identified as Substances of Very High Concern based on the criteria established by the EU chemical regulation, REACH.
Dutch Ministry of Housing, Spatial Planning and Environment. Quick Scan. *(PDF) This is a screening method that uses existing data, criteria and decision-making rules to evaluate substances and place them into categories of concern based on hazard.

European Chemicals Agency (ECHA). Classification and Labeling Inventory Database. This database contains classification and labeling information on REACH notified and registered substances received from manufacturers and importers, as well as the list of EU harmonized hazard classifications.
Healthy Building Network. Pharos. This resource includes a chemical and material library containing over 20,000 substances screened against over 40 authoritative hazard and warning lists. The library identifies health hazards that may come directly from exposure to a substance or from chemicals used or created in its production.

Interstate Chemicals Clearinghouse (IC2). State Priority Chemicals Resource. This database contains lists of priority chemicals developed under various state laws.
ISTAS. RiscTox. This database provides information about health and environmental risks for over 100,000 chemical agents.

IUE-CWA and BlueGreen Alliance. ChemHAT—Chemical Hazard and Alternatives Toolbox. This database provides information on chemical hazards, uses, exposures, and safer alternatives.
KEMI--Swedish Chemicals Agency. PRIO. This is a web-based tool intended to facilitate the assessment of health and environmental risks of chemicals so that risk reduction opportunities can be identified and prioritized.

Ministry of Social Affairs and Employment of Netherlands. Stoffenmanager. This is a tool for small and medium-sized enterprises to prioritize their health risks to dangerous substances and to determine effective control measures.

SUBSPORT. Restricted and Priority Substances Database. This database contains 32 lists of substances that are legally or voluntarily restricted or are recommended for restriction due to their hazards.
U.S. Environmental Protection Agency. ChemView. This web tool displays key health and safety data on chemicals and provides streamlined access to EPA assessments, hazard characterizations, and information on safer chemical ingredients.

U.S. National Library of Medicine. TOXNET: Toxicology Data Network. This database provides information on toxicology, hazardous chemicals, environmental health, and toxic releases.

Friday, June 27, 2014

Step 2: Examine Current Chemical Use - Prioritize

Prioritize

While it is important to consider transitioning to safer alternatives for each of the hazardous chemicals used in your workplace, you do not have to pursue substitution activities for every chemical immediately. Instead, you should work with your team to identify priorities to maximize the use of limited resources. Chemicals can be prioritized based on various criteria, including, but not limited to: hazard, exposure, risk, regulation potential, established company policies, interests of relevant stakeholders, and substitution potential. OSHA 300 logs may also provide helpful information about what chemical uses and exposures are of greatest concern in your workplace. Setting these priorities could reflect the larger goals in your work plan for transitioning to safer chemicals or help you further refine your work plan.

Key Resource

Prioritization Matrix

European Commission's Prioritization Matrix

The European Commission’s Guidance on Minimizing Chemical Risk to Workers’ Health and Safety Through Substitution provides a risk matrix tool that can be used for prioritization. The tool combines a qualitative evaluation of hazard and exposure potential to identify chemicals that could be good targets for substitution efforts. The matrix uses hazard categories found on a Safety Data Sheet to rank the hazard level of the chemical from1 (low hazard) to 5 (very high hazard). The matrix uses information about where, how often, and in what way the chemical is used to rank exposure potential from 1 (low exposure) to 5 (very high exposure) with regards to working/process conditions, physical properties affecting exposure, frequency or duration of use, quantity used, and accident potential. Combining the qualitative hazard and exposure potential scores allows you to identify chemicals with the highest risk and greatest potential for substitution.

Accessibility Assistance: Contact OSHA's Directorate of Standards and Guidance at (202) 693-1950 for assistance accessing DOC, EPS, GIF, MP4, PDF, PPT or XLS documents.

Monday, June 23, 2014

Step 2: Examine Current Chemical Use - Inventory

First, you should work with your team to develop an up-to-date inventory of all the chemicals used in your workplace, including chemicals used during production, performing service tasks, and during cleaning and maintenance operations. This should include information about how the chemical is made, handled, stored, disposed, or transported. You should also describe the function the chemical performs, as well as the physical form of the chemical, the frequency and duration of the chemical use, and the quantity of the chemical used. It is important to understand whether the use of the chemical is actually necessary in your operation. The safety data sheets (SDSs) required for hazardous chemicals under OSHA's Hazard Communication standard (29 CFR 1910.1200(g)(1)) can provide a helpful starting point for your inventory; however, ensure your inventory is updated so that it includes all uses of all chemicals in your workplace, and ensure your supplier has provided you with a manufacturer’s SDS for each chemical. Incomplete SDSs or SDSs that do not include information about ingredients below a certain concentration are good examples of why all chemicals, not just those classified as "hazardous," should be inventoried in this step. The chemical use inventory can be as simple as a list or spreadsheet or as sophisticated as a process flow diagram. A process flow diagram graphically illustrates the chemical inputs, products, and non-product output streams for a particular manufacturing process and may point out upstream changes that could help reduce or eliminate the use of hazardous chemicals. While it may be easier to compile information about chemicals used in the processes in your workplace, it is also important to know which chemicals are contained in products used by workers and the hazards associated with them. Workers in non-manufacturing industries – such as cleaners, plumbers, floor installers, and construction workers –encounter chemicals in such products on a regular basis.

Next, you should identify the hazards associated with the chemicals used in your workplace. This should be a rapid evaluation of the hazards using existing resources, rather than an in-depth assessment requiring interpretation of toxicological test results or other scientific literature. Cross-referencing chemicals in your workplace to those on restricted substances lists and reviewing the hazard categories listed on safety data sheets can help you identify the most hazardous chemicals. Other chemical databases, such as ChemHAT and RISCTOX can help you quickly identify the hazards associated with chemicals you use in the workplace.

Key Resource

ChemHAT.org

Chemical Hazard and Alternatives Toolbox (ChemHAT)

ChemHAT helps workers and employers understand whether a chemical can impact their health and whether safer alternatives exist.
The chemical information provided by ChemHAT allows you to rapidly understand the types of health effects related to a chemical and the strength of those effects. This information can help you examine your chemical use and identify which hazards you should eliminate or reduce first. ChemHAT also provides information on existing case studies of safer alternatives. This information can help you quickly understand where the potential for substitution exists and what alternatives you should consider evaluating further.

Key Resource

SubsPort Website

Restricted and Priority Substance Database

Lists of restricted and priority substances can provide a good starting point for identifying the most hazardous chemicals in your workplace. These lists generally include chemicals that are currently restricted by a government body anywhere in the world, as well as chemicals of concern that are not yet regulated. Through SUBSPORT's Restricted and Priority Substance Database, you can simultaneously search 32 lists of substances that are legally or voluntarily restricted or are recommended for restriction due to their hazards. The database includes lists from international agreements, EU regulatory lists, governmental lists, non-governmental organization and trade union lists, and internal company lists.

Key Resource

RISCTOX: Toxic and hazardous substances database

RISCTOX

Databases that compile multiple sources of chemical information can help you quickly understand the hazards associated with the chemicals used in your workplace. RISCTOX is a database of over 100,000 chemical substances that provides clear, organized, and concise information about health and environmental risks. The database includes data on a substances’: classification by the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), specific health risks, specific environmental risks, and environmental and health-related regulations.

Monday, June 16, 2014

Step 2: Examine Current Chemical Use - Key Questions

To identify targets for informed substitution, you need to know how you use chemicals in your workplace and the hazards associated with each of these chemicals. This step will help you examine your current chemical use.

Key Questions

For each chemical, consider:
  • Where is the chemical being used?
  • What function does the chemical perform?
  • Is the chemical necessary in the process or product? Could the chemical be eliminated without adversely affecting product or process performance?
  • What are the hazards associated with the chemical and how could its use harm workers?
  • How are workers potentially exposed to the chemical (i.e., during manufacturing of the chemical or product, when using a product containing chemicals, when applying the chemical in a service industry, or during chemical disposal)?
To identify priorities, consider:
  • What hazards should be eliminated or reduced first?
  • What uses of chemicals are of greatest concern?
  • What potential chemical exposures to workers are of greatest concern?
  • Could a chemical or process change help improve workplace safety and health?
  • Are the identified priorities consistent with the work plan for transitioning to safer chemicals?

Accessibility Assistance: Contact OSHA's Directorate of Standards and Guidance at (202) 693-1950 for assistance accessing DOC, EPS, GIF, MP4, PDF, PPT or XLS documents.
*These files are provided for downloading.

Wednesday, June 11, 2014

Transition to Safer Chemicals: Explore the Steps - Step 1

Step 1: Form a Team to Develop a Plan

Creating a systematic change in chemical use is best accomplished by establishing a team to develop a work plan and set goals. This step will help you develop your plan.

Key Questions

  • How will workers be involved in the team and throughout the planning process?
  • Who should be involved in developing the work plan and setting goals for transitioning to safer chemicals (e.g., managers, supply chain partners, customers, marketers, health and safety committee members, occupational health nurse or physician, occupational health consultant)?
  • What goals should be included in the plan? Consider specific goals such as eliminate carcinogens, reduce the use of hazardous chemicals by a certain percentage in a set number of years, substitute chemicals of concern from government or sector lists, etc.
  • What policies, tasks, responsibilities, deadlines should be included in the plan?
  • What particular drivers should you be aware of in developing the plan (existing or new laws, consumer pressures, new science)?
  • How will external stakeholders be involved?
Assemble an internal team to take responsibility for developing the work plan for transitioning to safer chemicals. Consider who should be involved in the team (e.g., existing safety and health committee members, workers, managers, union representatives). It is important to involve workers that perform various functions in your workplace (e.g., designers; engineers; and service, maintenance, and research and development staff). Also identify any external stakeholders who should be included in the planning process (e.g., designers; engineers; service, maintenance, research and development staff).
There is no one-size-fits-all method for developing a work plan for transitioning to safer chemicals. Setting goals is an important part of a work plan; these goals could be long-term, industry-specific, or chemical-specific. Your plan also may include company- or industry-specific policies on safety or chemical management, targets for chemical use, and approaches for prioritizing and managing chemical hazards. This will help make decisions easier when comparing different types of hazards and deetermining how hazards should be prioritized and evaluated.

Key Example

Goal Setting

There are a variety of examples of goals for chemical management. These range from long-term goals, to industry-specific goals, to chemical-specific goals. Some examples include:
"To act responsibly, Dell believes that if reasonable scientific grounds indicate that a substance (or group of substances) could pose significant environmental or human health risks, then Dell should avoid using the substances."
Dell’s Chemical Use Policy
"Where there are reasonable grounds for concern that a chemical used in our product could be harmful to human health or the environment, we will always take appropriate precautionary measures."
Boots Chemical Working Group
"We envision and strive to create a world in which all consumer products are produced using Sustainable Chemistry practices, ultimately using inherently safer chemicals and reducing or eliminating hazardous chemicals, in order to preserve human health and a clean environment."
Outdoor Industry Association Chemical Management Working Group
"Commitment to collaborate and lead the apparel and footwear industry towards zero discharge of hazardous chemicals for all products across all pathways in our supply chains by 2020."
Footwear and Apparel Industry’s Roadmap to Zero Discharge of Hazardous Chemicals
"Reduce the use of carcinogens or mutagens at the place of work, in particular by replacing it, in so far as is technically possible, by a substance, preparation or process, which under its condition for use, is not dangerous or is less dangerous to worker’s health or safety."
EU Carcinogens and Mutagens Directive

Key Example

Developing a Work Plan

The National Pollution Prevention Roundtable’s 2025 Safer Chemistry Challenge Program established a seven step program that companies can use to eliminate or reduce chemicals of concern. Setting performance goals and creating an action plan are key elements of the program. As such, the program provides a simple and useful method for visualizing and operationalizing a company’s goals and work plan.
Sample Work Plan
Chemical Reduction Goal Achievments to Date Action Steps Timeline Metrics Alternative Assessment Tools Used
Methylene Chloride 100% Have begun to research alternatives
Identify Alternative
Test alternative
Convert to alternative solvent
December 2011
March 2012
May 2012

Wednesday, June 4, 2014

Systematically evaluating hazardous products and transitioning to safer alternatives

Seattle City Light

Seattle City Light, one of the nation’s largest municipally-owned electric utilities, has successfully developed and implemented a chemical use reduction policy and procedure for moving to safer products and processes. Under this policy, the utility is required to reduce the overall use of hazardous materials to the extent practical, to phase out the use of products that pose human health or environmental risks, and to increase the use of safer alternatives. To implement the policy, Seattle City Light reviews new products, as well as its existing chemical inventory, based on chemical acceptability criteria developed by the utility. The approval process uses this hazard evaluation to place the product into tiers and determine whether it should be classified as a preferred product. Only products that have made it through this approval process can be utilized by the utility in its operations. After the selection and implementation of preferred alternatives, Seattle City Light frequently conducts evaluations of product performance in particular applications, collaborating with workers to determine the impact of the alternatives on shop floor operations.
Seattle City Light Through this ongoing process, the utility has been able to identify and transition to preferred products in a variety of applications. For example, when Seattle City Light reviewed its welding operations in steel shops, the utility identified a substitute for the use of thoriated tungsten electrodes, which expose workers to radiation. Seattle City Light utilized an alternatives assessment developed by the American Welding Society to select and replace these electrodes with ones containing lanthanum, a less toxic alternative that can be used in a wide range of applications. This move reduced worker exposures, as well as met the performance needs of the operation, without significantly increasing costs.

Friday, May 30, 2014

Chemical Alternatives in Wire and Cable Industry

AlphaGary Corporation

AlphaGary Corporation AlphaGary specializes in the design and development of plastic compounds for a variety of applications. Internal company initiatives combined with external factors, including European and Massachusetts laws, influenced AlphaGary to collaborate with its supply chain partners and other stakeholders to investigate less toxic alternatives for lead compounds used as heat stabilizers in formulations for wire and cable products. Investments in research and internal capacities for product design, evaluation, and testing resulted in: the development of new lead-free product formulations that maintained quality and performance; reduced risk to workers handling lead-based materials; reduced medical monitoring and personal exposure monitoring for lead; improved product development capabilities; streamlined product certification processes; and enhanced the company’s competitive global supply position.

Transitioning to Safer Chemical Alternatives in Laundry Detergents

Washing Systems, LLC

Washing Systems Washing Systems, LLC is a chemical supplier to the laundry industry in the U.S. and Canada. In 2005, the company’s leadership made a critical decision to focus 100% of all research and development on new chemical technologies that exhibit safer, environmentally sustainable profiles. The initiative to develop a new "green" line of detergents became an immediate outgrowth of this decision and focused heavily on their use of nonylphenol ethoxylates (NPEs). The challenge of this initiative was set in seven critical project objectives:
  1. Detergents must be 100% free of NPEs
  2. Detergents must be used as one for one direct replacements for NPE detergents
  3. Detergents must have the same ounce for ounce cost to NPE detergents
  4. Detergents must exhibit the same “end-use” cost to the customer as NPE detergents
  5. Cleaning performance must be equal to or improved over NPE detergents
  6. Wash formulas must maintain the same “rapid rate” wash formulas as NPE detergents
  7. Detergents must be certified by the EPA’s Design for Environment (DfE)
At the end of 2007, Washing Systems’ R&D successfully met each of these objectives. In 2008, Washing Systems launched a new line of NPE-Free detergents into the commercial laundry market. Today, the success of this R&D project is evident to all Washing Systems customers, as all are 100% free of NPEs. This effort has reduced over 4.5 million lbs of NPEs/year from being discharged to the environment.
In addition to eliminating the use of NPEs in its products, Washing Systems has eliminated the use of butyl cellosolve and petroleum hydrocarbon based solvents in detergents, eliminated the use of phosphates and ethylenediaminetraacetic acid (EDTA) within the laundry builders, and reduced the petroleum hydrocarbon based solvents by 46% in other specialty products. The new formulations are not only less hazardous to workers and the environment, but also provide economic and efficiency benefits to Washing System’s customers (i.e., reduced water and energy usage, increased wash productivity, lower chemical costs).
To identify alternatives, the company’s scientists and engineers use CleanGredients®, a database of safer cleaning products ingredients that meet specific health and environmental criteria. The company also uses the GreenScreen, a comparative chemical hazard assessment method, to evaluate and compare hazards of alternative chemicals. Washing Systems carries out extensive in-house performance testing as well as field trials in customers’ facilities to ensure that the alternatives demonstrate superior levels of cleaning quality and operational performance compared to the chemistry it replaces.

Friday, May 23, 2014

Transition to safer chemicals success story:Safer Processes

Designing a Safer Process for Chemical Manufacturing

DuPont Corporation

DuPont is a large chemical manufacturer that makes products for many industries — agriculture, marine, healthcare, energy, food and beverage, and mining, to name a few. Methyl isocyanate (MIC) is a highly toxic, irritating and flammable chemical that is commonly used to produce the carbamate pesticide methomyl; it is often manufactured in a separate production unit at facilities and stored in large pressure vessels. Following the 1984 deadly MIC release from the Union Carbide facility in Bhopal, India — where approximately 30 metric tons of toxic MIC escaped from a storage tank into the atmosphere in less than an hour killing thousands and injuring hundreds of thousands — DuPont implemented a new technology for producing methomyl at its plant in LaPorte, Texas. DuPont converted the less acutely toxic chemical methylformamide into MIC as a vapor-phase (rather than liquid) on an as-needed basis, which was immediately consumed in a subsequent reaction, leaving very little MIC in the system at one time and removing phosgene from the production process. DuPont's method reduced worker handling of several toxic chemicals; eliminated the need to transport, store, and transfer MIC and phosgene; and addressed lifetime cost issues.

Thursday, May 15, 2014

Executive Order 13650: Improving Chemical Facility Safety and Security

Background

On August 1, 2013, President Obama signed Executive Order 13650, entitled Improving Chemical Facility Safety and Security. The Executive Order directs the Federal Government to improve operational coordination with state and local partners; improve Federal agency coordination and information sharing; modernize policies, regulations, and standards; and work with stakeholders to identify best practices.
The Executive Order working group includes representatives from:
Executive Order 13650

Federal Workgroups Formed in Response to the Executive Order:

Section 3 - Improving Operational Coordination (Co-chaired by EPA and DHS, U.S. Coast Guard)
Section 4 - Improving Federal Agency Coordination (Co-chaired by EPA and DHS, U.S. Coast Guard)
Section 5 - Improving Information Collection and Sharing (Chaired by DHS, Infrastructure Security Compliance Division)
Section 6 - Modernizing Policies, Regulations, and Standards (Chaired by DOL, Occupational Safety and Health Administration)
  • Request for Information on Process Safety Management and Prevention of Major Chemical Accidents
    • Click here to comment on the OSHA RFI
  • Section 6(a) – Solicitation of Public Input on Options for Policy, Regulation, and Standards Modernization
    • Click here to comment on the EO Section 6(a) Document
Section 7 - Stakeholder Outreach and Identifying Best Practices (Chaired by DHS, Infrastructure Security Compliance Division)

Resource Materials

Public comments and additional materials are available in the public docket for Section 6 of the Executive Order. To access the docket, you can go to www.regulations.gov and perform a search for OSHA-2013-0026.
Executive Order
  • Executive Order 13650: Improving Chemical Facility Safety and Security
  • EPA's Webpage on Executive Order 13650
Request for Information
  • Request for Information on Process Safety Management and Prevention of Major Chemical Accidents*
Guidance Documents
  • Chemical Advisory: Safe Storage, Handling, Management of Ammonium Nitrate*
  • Fertilizer Industry Guidance on Storage and Use of Ammonium Nitrate
Listening Sessions
  • Announcement of Listening Sessions is published in the Federal Register [Docket No. DHS–2013–0075]

Friday, May 9, 2014

Health & Safety for Onshore Emergency Responders

Severe Weather and the Deepwater Horizon Oil Spill:
Health and Safety for Onshore Emergency Responders

How can operations in response to severe weather be affected by the Deepwater Horizon Oil Spill?

The high winds associated with severe weather (including hurricanes and tropical storms) may distribute spilled oil over a wider area. Storm surges may carry oil into the coastline and inland as far as the surge reaches. Debris resulting from a hurricane may be contaminated by oil from the Deepwater Horizon incident. (For more information, see the National Oceanic and Atmospheric Administration's factsheet Hurricanes and the Oil Spill [1 MB PDF, 2 pages])
Hurricane responders, such as damage assessors, urban search and rescue teams, debris management contractors, and local fire, police and emergency medical personnel, may come in contact with the deposited oil. Responders need to be aware of their surroundings and, if weathered oil is present, take proper precautions.

What Hazards is the Weathered Oil Likely to Present?

The oil that may be deposited inland by the storm surge is likely to be weathered oil, meaning that any lighter and more acutely toxic components of the crude oil have evaporated. Weathered oil on bare skin can cause rashes.

What Actions Should be Taken to Protect Workers from Weathered Oil?

It is likely that most emergency responders will not need to come in contact with weathered oil. For operations where contact with weathered oil can be avoided, there is no need for additional training and equipment. However, if the operation involves contact with weathered oil (such as cleaning up oil-contaminated debris), employers will need to provide training on the hazards of the operation prior to beginning work.* In addition, the proper personal protective equipment (e.g., boots and gloves) will also need to be provided.

Workers who do not have the necessary training and equipment should avoid contact with the weathered oil.
* For more information, see OSHA's guidance for cleaning up weathered oil and for general protection information on hazards associated with the response to severe weather, see OSHA's Hurricane Preparedness and Response website.

Tuesday, April 29, 2014

Classification of cumbustible dust under Ammended 29 CFR 1910.1200 Hazcom

December 27, 2013
MEMORANDUM TO: REGIONAL ADMINISTRATORS
THROUGH: Dorothy Dougherty
Acting Deputy Assistant Secretary
FROM: Thomas Galassi, Director
Directorate of Enforcement Programs
SUBJECT: Classification of Combustible Dusts under the Revised Hazard Communication Standard 
This memorandum provides guidance for compliance safety and health officers (CSHOs) to use in determining whether manufacturers or importers have properly classified their products1 for combustible dust hazards under the revised Hazard Communication Standard (HCS). This guidance shall be used when inspecting manufacturers and importers, usually from referrals concerning inadequate or inappropriate labels or SDSs are conducted, not inspections of downstream users. Until OSHA addresses these issues through rulemaking, CSHOs shall use this document to determine if manufacturers and importers (from now on "classifier") are in compliance with the obligations of 1910.1200(d) for combustible dust. CSHOs may direct any questions that arise in applying this guidance to the Directorate of Enforcement Programs or the Salt Lake Technical Center (SLTC). 

Background

On March 26, 2012, OSHA amended the HCS to align with the Globally Harmonized System for the Classification and Labelling of Chemicals (GHS). However, the GHS does not contain a classification for combustible dust hazards, and to maintain coverage of this hazard under the HCS, OSHA amended the standard's definition of "hazardous chemical" to include "combustible dust2 ." Noting ongoing efforts at the United Nations (UN) and in the Agency's own combustible dust rulemaking, OSHA did not adopt a definition of the term combustible dust in the final rule. Rather, as an interim measure, OSHA stated that it had already provided guidance on combustible dust, including the Combustible Dust National Emphasis Program (NEP), which "includes an operative definition." 77 FR 17705. OSHA also noted that a number of voluntary consensus standards exist, "particularly those of the NFPA," which provide further guidance. Id.

Compliance Guidance

Under the HCS, classifiers are required to "evaluate chemicals produced in their workplaces or imported by them to classify the chemicals in accordance with this section." 29 CFR 1910.1200(d)(1). Any such classification must "identify and consider the full range of available scientific literature and other evidence concerning the potential hazards." 1910.1200(d)(2). However, there "is no requirement to test the chemical to determine how to classify its hazards." Id. The classifier must consider not only the hazards of the chemical in the form it is shipped, but also consider the hazards that arise under normal conditions of use and foreseeable emergencies. When performing inspections of classifiers, CSHOs must ensure that the requirement to consider normal conditions of use and foreseeable emergencies is followed by the classifier.
The combustible dust NEP defines combustible dust as a solid combustible material, composed of distinct pieces or particles, that "presents a fire or deflagration hazard when suspended in air or some other oxidizing medium over a range of concentrations, regardless of particle size or shape." A number of voluntary standards prepared by the National Fire Protection Association (NFPA), FM-Global, and ASTM International suggest various tests, data, and criteria that may be used to determine whether a material presents a combustible dust hazard.
As noted above, classifiers must consider any hazards posed by the product in normal conditions of use and foreseeable emergencies, and must consider the full range of available information about those hazards. For combustible dusts, often the best information is actual experience with the product. If the classifier knows that its product has been involved in a deflagration or dust explosion event, the classifier should classify the product as a combustible dust unless the classifier can show that the conditions surrounding the event are not expected in normal conditions of use or foreseeable emergencies. In the absence of information on a deflagration or dust explosion event, classifiers may use one or more of the following approaches in determining whether such hazards exist, depending on the information that is available.
  1. Laboratory Testing.

    All of the voluntary standards recognize that reliable test data for a material, based on scientifically validated tests, is strong evidence for determining whether a material presents a combustible dust hazard and should be used for classification if available. Reliable screening tests, such as that described in ASTM E12263 , showing a positive normalized rate of pressure rise (Kst), and tests for Class II dusts may be used to determine whether a material presents a combustible dust hazard, and classification should be based on such data if it is available. Many voluntary standards recognize the ASTM E1226 and E15154 methods as reliable means to establish a combustible dust hazard. When performing inspections of classifiers CSHOs must obtain and evaluate any appropriate and available test results for the product to ensure the classification accurately reflects the hazards of the chemical.

    OSHA's combustible dust NEP describes its own test method for determining the Kst, and the NEP treats a dust as presenting the hazard when the Kst is greater than zero. In addition, the NEP describes OSHA's method for determining whether a dust is a Class II dust for purposes of the electrical standard, which is also an indication that a dust presents a combustible dust hazard. If laboratory data (e.g., company-generated data or regulatory body test results for the product) are available and the classifier chooses not to classify based on this data, the CSHO must ensure that classifier can adequately explain why this data was not used in the classification.
  2. Published Test Results.

    NFPA 615 , 686 , 4847 , and 4998 publish lists of test results for various materials. Though the NFPA documents caution care in the use of these results because the extent of explosibility can vary even for different dusts of the same solid material, they nonetheless can "aid in the determination of the potential for a dust hazard to be present in [an] enclosure." NFPA 61, A.6.2.1 (2013).

    As a part of a poster about combustible dust hazards, OSHA has published a list of combustible materials based on the information provided in the NFPA standards (https://www.osha.gov/Publications/combustibledustposter.pdf). In addition, there are public databases of dust explosibility characteristics that may be consulted, such as the "Gestis-Dust-EX" database maintained by the Institute for Occupational Safety and Health of the German Social Accident Insurance (http://www.dguv.de/ifa/en/gestis/expl/index.jsp).

    In the absence of any test data for a particular product, the classifier may rely on published test data for the classification of dusts if the data is for a material that is substantially similar to the product under review. Where the classifier has not classified its product as presenting a combustible dust hazard and the CSHO finds positive published data for a material that appears similar, the CSHO must ensure that the classifier has an adequate explanation for discounting the data.
  3. Dust Particle Size.

    For many years, NFPA 6549 defined combustible dust as a "finely divided solid material 420 microns or smaller in diameter (material passing a U.S. No. 40 Standard Sieve) that presents a fire or explosion hazard when dispersed and ignited in air." OSHA used this definition in earlier combustible dust guidance, such as its 2005 safety and health information bulletin, and uses a similar criterion in defining "fugitive grain dust" in its Grain Handling Facilities Standard (see 29 CFR 1910.272(c)). Some NFPA standards still use a size criterion in defining combustible dust, such as NFPA 61 (2013) and NFPA 704 (2012)10 .

    Other NFPA standards, however, have changed their combustible dust definition to remove the size criterion, but discuss size in their explanatory notes. In general the notes concerning particle size state that dusts of combustible material with a particle size of less than 420 microns can be presumed to be combustible dusts. However, certain particles, such as fibers, flakes, and agglomerations of smaller particles, may not pass a No. 40 sieve but still have a surface-area-to-volume ratio sufficient to pose a deflagration hazard. In the most recent revisions, the explanatory notes in many of the NFPA standards have moved from a 420 to 500 micron size threshold. See NFPA 484 (2013), NFPA 654 (2013), NFPA 66411 (2012) and FM Global Data Sheet 7-76 (2013)12 .

    Where there is no test data, or if the testing is inconclusive, classification may be based on particle size, if particle size information is available. If the material will burn and contains a sufficient concentration of particles 420 microns or smaller to create a fire or deflagration hazard, it should be classified as a combustible dust. A classifier may, if desired, instead use the 500 micron particle size (U.S. Sieve No. 35) threshold contained in more recent NFPA standards. Care must be used with this approach where the particles are fibers or flakes, or where agglomerations of smaller particles may be held together by static charges or by other means that would prevent the dust from passing through respective sieves No. 40 and 35, but would still present a fire or deflagration hazard.

Summary

In summary, when conducting inspections of classifiers, CSHOs should determine how classifiers have handled the available evidence about a product's explosibility. Where there is evidence that the product has actually been involved in a deflagration or dust explosion event, it should be classified as a combustible dust. Similarly, where results of accepted tests on the product are available, the dust should be classified in accordance with those results. Finally, in the absence of actual events or test data on the product, the classifier may either rely on the published test data on similar materials or use the available information about particle size to determine the combustible dust hazard of the product.
This guidance is not intended to be exclusive, and classifiers may have other reliable methods to establish whether their product does or does not present a combustible dust hazard in normal conditions of use and foreseeable emergencies. CSHOs should consider such claims carefully, and in such cases consultation with the Directorate of Enforcement Programs and/or the SLTC is strongly encouraged.

Wednesday, April 23, 2014

Hazard Communication Final Rule

New changes to the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard are bringing the United States into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), further improving safety and health protections for America's workers. Building on the success of OSHA's current Hazard Communication Standard, the GHS is expected to prevent injuries and illnesses, save lives and improve trade conditions for chemical manufacturers. The Hazard Communication Standard in 1983 gave the workers the ‘right to know,' but the new Globally Harmonized System gives workers the ‘right to understand.'

The new hazard communication standard still requires chemical manufacturers and importers to evaluate the chemicals they produce or import and provide hazard information to employers and workers by putting labels on containers and preparing safety data sheets. However, the old standard allowed chemical manufacturers and importers to convey hazard information on labels and material safety data sheets in whatever format they chose. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets. 

Benefits: The new standard covers over 43 million workers who produce or handle hazardous chemicals in more than five million workplaces across the country. The modification is expected to prevent over 500 workplace injuries and illnesses and 43 fatalities annually. Once fully implemented it will also:
  • Improve the quality and consistency of hazard information in the workplace, making it safer for workers to do their jobs and easier for employers to stay competitive;
  • Enhance worker comprehension of hazards, especially for low and limited-literacy workers, reduce confusion in the workplace, facilitate safety training, and result in safer handling and use of chemicals;
  • Provide workers quicker and more efficient access to information on the safety data sheets;
  • Result in cost savings to American businesses of more than $475 million in productivity improvements, fewer safety data sheet and label updates and simpler new hazard communication training: and
  • Reduce trade barriers by harmonizing with systems around the world.
Rulemaking background: OSHA published a Notice of Proposed Rulemaking to update the Hazard Communication Standard in September 2009 and held public hearings in March 2010.
Major changes to the Hazard Communication Standard:
  • Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
  • Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
  • Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
  • Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.
Changes from the Proposed to the Final Rule: OSHA reviewed the record and revised the Final Rule in response to the comments submitted. Major changes include:
  • Maintaining the disclosure of exposure limits (Threshold Limit Values [TLVs]) established by the American Conference of Governmental Industrial
  • Hygienists (ACGIH) and carcinogen status from nationally and internationally recognized lists of carcinogens on the safety data sheets;
  • Clarification that the borders of pictograms must be red on the label;
  • Flexibility regarding the required precautionary and hazard statements to allow label preparers to consolidate and/or eliminate inappropriate or redundant statements; and
  • Longer deadlines for full implementation of the standard (see the chart below):
What you need to do and when:
  • Chemical users: Continue to update safety data sheets when new ones become available, provide training on the new label elements and update hazard communication programs if new hazards are identified.
  • Chemical Producers: Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets.
Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and SDS format. Employers
June 1, 2015*

December 1, 2015
Comply with all modified provisions of this final rule, except:

Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.
Chemical manufacturers, importers, distributors and employers
June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers
Transition Period Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors and employers
* This date coincides with the European Union implementation date for classification of mixtures.
Other U.S. Agencies: The Department of Transportation (DOT), Environmental Protection Agency, and the Consumer Product Safety Commission actively participated in developing the GHS. DOT has already modified its requirements for classification and labeling to make them consistent with United Nations transport requirements and the new globally harmonized system. 

Global implementation: The new system is being implemented throughout the world by countries including Canada, the European Union, China, Australia, and Japan.

Additional information: More information on the hazard communication standard, including the link to the Federal Register notice, can be found on OSHA's hazard communication safety and health topics page at www.osha.gov/dsg/hazcom/index.html.