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.