OSHA Takes on Hazardous Chemical Substitution and PELs
Last week, OSHA announced the release of two new Web Resources aimed at protecting workers against hazardous chemical exposures in the work environment. OSHA took this proactive measure because, as the 2012 Government Accountability Office (GAO) report found, its current rulemaking process is so complex that it’s difficult to update chemical standards and issue new standards in a reasonable amount of time. These new Web resources represent the alternative means OSHA is taking to address voids in worker protections due to nonsexist standards and outdated Permissible Exposure Limits (PELs), some of which are more than 40 years old and based on outdated information.
OSHA's Two New Resources for Protecting Workers from Hazardous Chemicals
1) A Chemical Substitution Identification Toolkit. The toolkit outlines a seven-step process for making informed decisions on eliminating hazardous chemicals or substituting them with safer alternatives. The seven steps are: Step 1- Form a Team to Develop a Plan; Step 2- Inventory & Prioritize; Step 3- Identify; Step 4- Assess & Compare; Step 5- Select; Step 6-Test; and Step 7- Evaluate.
2) Annotated Permissible Exposure Limits Tables, or annotated PELs tables. These tables provide newer, more protective workplace exposure limits for some of the PELs in place under OSHA's existing standards. The new PEL tables are: California Division of Occupational Safety and Health (Cal/OSHA) Permissible Exposure Limits (PELs); National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limits (RELs) and ACGIH® Threshold Limit Values (TLVs®) and Biological Exposure Indices (BEIs®). According to the announcement, "OSHA’s mandatory PELs in the Z-Tables remain in effect. However, OSHA recommends that employers consider using the alternative occupational exposure limits because the Agency believes that exposures above some of these alternative occupational exposure limits may be hazardous to workers, even when the exposure levels are in compliance with the relevant PELs." In addition to utilizing these new Web resources, OSHA Director Dr. David Michaels recommends using another alternative to protecting workers from hazardous chemicals — an Injury and Illness Prevention Program (I2P2) approach. Since the I2P2 approach includes "finding and fixing" hazards, it's a great way to reduce or prevent chemical-related occupational injuries and illnesses. Dr. Michaels has long been a proponent of this approach, and he confirmed during the teleconference on the release of these resources, that the agency is still moving forward with its I2P2 rulemaking initiative. During the teleconference Dr. Michaels was asked several times about the implications of these new resources on enforcement. He was consistent in his response, which was that OSHA's enforcement procedures are not changing and that the new resources do not replace any existing regulations.
What's in Your Inventory?
OSHA is doing what it can to help protect workers against exposures to hazardous chemicals and MSDSonline allows customers to do the same. If you're interested in cross-referencing your inventory with regulatory lists like the EPA’s (TSCA) Toxic Substances Control Act (TSCA) Inventory list; OSHA's List of Highly Hazardous Chemicals, Toxics and Reactives; and the CDC National Institute for Occupational Safety and Health (NIOSH) Carcinogen List as a way to identify chemicals to ban or substitute in your workplace, contact an MSDSonline Representative at 1.888.362.2007 to learn about our HQ RegXR Account. If you're looking for a way to use the OSHA-recommended I2P2 alternative for protecting workers from chemical hazards, be sure to ask a representative about VelocityEHS’ Incident Management application. The application can analyze your incident data to help you pinpoint high-hazard areas and implement corrective actions to remove hazards that have already contributed to injuries and illnesses, as well as eliminate those that could potentially cause future incidents.
Today's article was written by Melissa McCaffrey and comes from the October edition of MSDSonline's Customer Newsletter "Safety Counts"