Introduction to Hazard Communication, Part Six: Overcoming Common Challenges by Putting Your HazCom Program to Work
Jun 26, 2019
Welcome to the sixth and final installment in our “Intro to HazCom” series! If you missed our previous posts in this series or want to refresh your memory, just follow the hyperlinks to read about the basics of HazCom (Parts One and Two), the challenges of chemical container labeling (Part Three), the requirements for a written HazCom plan (Part Four), or strategies for getting your HazCom training right (Part Five).
All caught up with our previous posts? Then let’s talk about some common HazCom challenges that don’t always get attention they deserve. A common theme will be the importance of making sure your HazCom program is effective — and by that we mean that your people actually act on the hazardous chemical information, resources, and training you’ve provided.
Are you ready? Right this way.
Let’s start with a quick story. Once, during my years as an EHS consultant, I was doing a compliance assessment of a manufacturing location, and the facility EHS manager escorted me into their main chemical storage room. I immediately noticed that many drums of chemicals were stacked on top of each other. Wondering what these chemicals might be, I took a look at the labels and received a shock, because the top drum in one stack was sulfuric acid, and the drums beneath it contained sodium hydroxide.
If you’ve had a chemistry course before, you’ll probably see the problem here. Sulfuric acid (a strong acid) and sodium hydroxide (a strong base) react strongly, and should not be stored near each other – let alone on top of each other!
My shock wasn’t as great as it would’ve been if I hadn’t been consulting for a while, and seen similar (if less extreme) storage scenarios. And the chemical management at these facilities followed a typical pattern: they’d done a lot of what they were supposed to do regarding HazCom, such as maintaining a written plan, a chemical inventory and an SDS library, even if they tended to make certain common mistakes in those areas. But they’d received their SDSs and simply filed them away, making them accessible to employees during the workshift but not reviewing and using the storage and handling instructions in Section 7 of the SDS.
It’s at times like this that we remember why OSHA issued the HazCom Standard in the first place, and what makes it so valuable. Simply put, we need the information on SDSs and shipped labels to be able to work safely with chemicals, and a big part of that is knowing how to store them properly. We might have a complete SDS library, an up-to-date chemical inventory, and a thorough and site-specific written HazCom Plan, but if we’re storing our chemicals in a way that is dangerous, we’re failing in one our most fundamental obligations.
So be sure to pay close attention to Section 7 of the SDS and use that information to inform your chemical storage practices. Remember, certain chemicals are incompatible with others because they react strongly, such as acids and bases (like those in our example above), or oxidizers and reducers. There are also chemicals such as pure potassium metal, or lithium aluminum hydride, that react violently with water, and should not be stored anywhere close to a sink or other water source. Other chemicals may become unstable at higher temperatures.
Obviously, you’ll need to know these details about the chemicals in your own inventory, and plan your storage practices accordingly.
Think of chemical emergency planning as the practice of planning to avoid “unplanned incidents” involving chemicals such as fires or spills, and preparing to respond as quickly and safely as we can to the incidents that occur in spite of our preparation. Certainly safe storage practices, as discussed earlier, help to prevent incidents from happening in the first place, but we have many other emergency planning obligations for which the information found on the SDSs and shipped labels will be helpful.
For instance, it is critical that you know the amounts of chemicals (or sometimes even the amount of certain ingredients within chemicals) stored on-site. This helps with effective emergency planning, and can be part of your regulatory obligations with EPA’s Emergency Planning and Community Right to Know Act (EPCRA).
For facilities with chemicals stored above their threshold limit, which is 10,000 pounds for most chemicals but significantly lower for chemicals listed as extremely hazardous substances (EHSs), compliance with EPCRA includes providing your State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department with SDSs or lists of chemicals grouped by hazard categories. You may also need to complete and submit Tier II chemical inventory reports to the same parties by March 1 for those chemicals by March 1 of each year.
On a more basic level, it’s your business to really know the pictograms and hazard classifications (including hazard statements and precautionary statements) for your chemicals. They are a primary source of information about your chemicals’ health and physical hazards. For example, a chemical classified as “Eye Damage Category 1” will have the hazard statement “causes serious eye damage,” along with specific precautionary statements based on the classification. These statements also provide specific instructions for prevention, response, storage and disposal of the chemical.
Applicable pictograms, hazard and precautionary statements are required elements of a shipped container label, and are included in Section 2 of an SDS.
It’s part of your obligations to ensure that your workforce is familiar with this information and where to find it, and that you’re actually using this information in your emergency planning. Investigations following many real-life chemical accidents often trace the causes back to organizations simply failing to actively incorporate this information, resulting in gaps in areas like risk assessments and personal protective equipment (PPE) evaluations.
Related issues arise for organizations when they fail to: update their emergency planning as new hazard classes of chemicals enter the facility; update their plans when manufacturers provided them with new SDSs containing revised classifications for existing chemicals; or update their plans when emergency drills or real-life incidents identify problems with existing emergency plans.
Sometimes we make the mistake of thinking about emergency planning as something that rests entirely on our own organization. We may develop plans involving our local fire department, the area hospital and various other first responders, but don’t include those parties in the planning stages and don’t provide them with the complete, updated information about our chemicals they need to be able to perform their roles effectively. Unfortunately, too often, the very first time the local fire department ever actually sets foot on a property is when they arrive to respond to an emergency.
Emergency planning is not something businesses need to do on their own – it’s something businesses, emergency responders and regulatory agencies need to do together. It’s a collaborative process that goes beyond the sharing of information, as important as that may be. It’s about having relationships with all stakeholders, involving them early in the process and making sure there are no gaps in communication that could prove costly during an emergency.
In addition to doing a thorough job identifying the hazards of your chemicals and associated emergency response measures, also consider mapping your chemical storage locations onto a diagram of your facility, and sharing this with your local fire department along with a current chemical inventory list and copies of your SDSs. Do what it takes to make sure your first responders are prepared should a chemical emergency occur.
You work hard to manage HazCom, so make sure it works just as hard for you! Effective management and sharing of emergency planning information is about more than just avoidance of bad outcomes – it’s a positive benefit to your business and your entire community.
One of the significant challenges of managing chemicals is identifying those that are subject to specific regulatory obligations. Let’s consider the issue of emergency planning again for a moment. We’ve already seen that chemicals listed as EHSs trigger Tier II reporting and notification requirements at smaller storage thresholds than other chemicals. Similarly, certain listed substances are subject to Toxic Release Inventory Reporting (TRI) under Section 313, and trigger TRI (aka “Form R”) reporting based on the amounts manufactured, processed, or otherwise used throughout the calendar year.
These are far from the only regulatory standards that may apply to our chemicals. For instance, for US facilities, we need to identify which of our chemicals may be listed as Clean Air Act (CAA) Hazardous Air Pollutants (HAPs) to comply with EPA air emissions permitting requirements, and which chemicals are found on EPA lists of hazardous wastes, so we can properly manage the chemicals once they become a waste stream – which is something that often makes chemical management particularly vexing!
If we have facilities outside the US, there are other sets of regulations we need to track. For instance, Canada’s National Pollutant Release Inventory Reporting (NPRI) requirement is roughly analogous to TRI reporting in the US, triggering reporting for certain facilities, activities, and usage amounts of chemicals listed on one of 6 different substance lists.
To be able to identify and meet different regulatory obligations, we need our HazCom information to be as accessible and usable as possible. We need access to ingredient information in Section 3 of our SDSs to know what individual chemicals are actually present in our products, and to any regulatory information that may be included in Section 15, when provided by the manufacturer. The problem is, the larger our chemical inventory is, the harder this task gets.
Here’s an example from my own past. When I used to prepare TRI/Form R reports as a consultant, I needed to get full chemical usage information from the client, as well as a giant stack of all SDSs for every product used. Then I sat down with the stack of documents, reviewed the ingredients listed for each product, and highlighted all of those listed as TRI-reportable, taking care not to overlook chemicals because of alternate names. The process took quite a while and almost always resulted in a headache, and sometimes in an initial mistake or two I’d have to catch by carefully reviewing all of my work.
Thankfully, better strategies are available today. Look into modern chemical management software solutions, which can provide you with ingredient indexing functions to have full visibility of your true inventory at the ingredient level. The best solutions even flag those chemicals on specific regulatory lists, so you can bypass the tedium of the past while reducing the potential for mistakes and oversights that can compromise your regulatory compliance status.
Industrial hygiene (IH) is another area where ingredient-level knowledge of your inventory is important. Take methylene chloride, for example, a common ingredient in aerosol degreasing sprays and paint-removing solvents. Facility managers are often unaware it is present in their facilities because the names of the products don't provide obvious clues. And if you don’t know you have methylene chloride, it's unlikely that your IH program includes exposure monitoring for it, which leaves your employees at risk and you out of compliance with OSHA’s methylene chloride standard.
It’s worth pointing out something that you’re probably noticing already, which is that an agency’s regulations are intended to function as a whole, in an interrelated way. So for example, OSHA’s Air Contaminants standard (1910.1000) establishes airborne exposure limits for various listed chemicals, and it assumes that the employer is aware whether these chemicals are present in the workplace because of SDSs manufacturers must provide under the HazCom Standard.
Of course, it is up to you as an employer to make sure that this information is accessible and actionable enough to let you develop a good IH sampling program. That includes not only knowing what chemicals you have, but also knowing which have OSHA exposure limits such as Permissible Exposure Limits (PELs), Short-Term Exposure Limits (STELs), and ceiling values. Employers often miss the latter two in sampling programs, because they focus only on 8-hour time weighted average (TWA) concentrations for purposes of evaluating compliance with the PEL.
That’s only the beginning of your IH obligations. You also need to determine which of your employees you will include in your sampling, based in part on determining Similar Exposure Groups (SEGS), which are groups of employees who’d likely have very similar exposure patterns on based on job tasks, frequency and duration of exposure, and similar use of controls. Then you need to choose appropriate analytical methods, and select laboratories that can perform the analyses, review and interpret the results, and take appropriate actions based on them.
Once again modern software solutions can help, by giving you a simple platform for planning an entire sampling program, minimizing the potential for mistakes or miscommunications.
Keep the Right Perspective
We’ve covered a lot of ground here, and we’ve seen the importance of making sure your HazCom program is an active, living system that shapes all aspects of your chemical safety. That leads us to another, related point: Don’t focus on simply doing what the regulations require – focus on making sure what you’re doing is effective.
Sometimes at my conference talks, attendees ask me about recent OSHA inspections in which the compliance officer was not satisfied with some facet of their HazCom management. “I do HazCom training and make all of my SDSs available to employees,” someone might say, “but the inspector commented that not all employees knew where to access an SDS. She also remarked that it seemed to take quite a long time to retrieve an SDS they asked for. What should I do?”
I’ll usually answer that I’m glad they’re asking the question, because it shows they’re serious about HazCom, and their description of the situation shows they’re definitely doing some of the things they need to do. But on another level, I’ll point out that the ultimate test of our HazCom management is that it actually works. We can’t simply train our employees and then move on to other projects, because the real test of compliance and training effectiveness is that employees understand the training. Likewise, the whole purpose of having an SDS library is to be able to access a document quickly when we need it the most. If we have an SDS access system in place that doesn’t meet that purpose, the shortcomings will become obvious pretty quickly in the event of an emergency.
Don’t wait for that to happen. To return to the question of what you should do if you find yourself in a similar position as the conference attendees mentioned above, the answer is “look for a solution, and then test the solution.” Have a mindset of continuous improvement instead of a mindset of just getting it done.
The truth is, we’ve all been guilty of the “get it done” mindset at one time or another. It would take a truly extraordinary EHS professional to avoid that perspective at all times, and I must confess I’ve never found such a person, and have looked pretty much everywhere, including my own mirror. But I advise that you’ll find that your system will work better and promote better engagement if you stay focused on the right things, and always look for ways to test and improve its effectiveness.
Stories of HazCom: Past and Present
Well, here we are. We’re just about finished with your introduction to HazCom, and we hope that in this particular installment, we’ve put across the importance of HazCom as not just a regulatory obligation, but a way to make your workplace safer. As we wrap up, I’d like to share a couple of personal stories that demonstrate this point, by looking at the real impact that the HazCom Standard has had on worker safety.
Our first story takes us back to when I was a graduate student in an environmental and occupational sciences program, and one of my program requirements was participation in a clinic program at a nearby hospital. The purpose of the program was to allow patients with health conditions linked to their work history to talk about their past and current jobs to better understand the origins of their health issues. I met many people during my participation, but there’s one gentlemen I’ve never forgotten.
His job for most of his working career was to wash greasy parts in a “dip tank,” which is basically just a metal wash basin filled with solvent. Each day this man would punch in at work, and then set down by the basin with a rack full of dirty machine parts, and begin dunking them into the basin to remove the oil and grease. He’d then wipe them with a rag and set them to dry, and then repeat multiple times per day, every day, for about 35 years.
For most of the time he’d had this job, there wasn’t even a HazCom Standard yet. In fact, he hadn’t even known the identity of the chemical in the basin, which turned out to be toluene — a chemical that should be taken very seriously. Since he didn’t know what he was working with, he also didn’t know how to work with it safely. He worked every day with this chemical without proper ventilation or personal protective equipment (PPE), dunking the parts into the solvent with his bare hands and breathing in the fumes.
As a result, he had very little short-term memory. He was able to talk to us about his work history, as well as about meeting his wife, and getting married, but couldn’t remember what he’d done earlier that same morning. In fact, he couldn’t seem to remember things he’d said five minutes earlier in the conversation. It also became clear that his wife, who’d accompanied him to the interview, was doubling as his caretaker.
Throughout the past twenty-five years, I’ve been haunted by that man and his story. They’ve underpinned and informed everything I’ve done in this industry since then.
Here’s a second, more recent story, with a happier ending. About four years ago, there was an incident in which a worker at the end of his shift disposed of the residual chemicals in his work pails within a single “waste drum.” The chemicals already in the drum, from a different waste stream, were incompatible, and they catalyzed a reaction. When an employee on the next shift reported in for work, he noticed the drum was bulging at the sides, and was looking like it might explode. He reported the observation and management made the decision to evacuate the building.
Luckily, plant personnel were able to quickly locate the SDSs for the materials involved in the reaction, and using the composition information in Section 3 and the stability and reactivity information in Section 10, were able to identify and safely contain the chemical reaction before an explosion could occur. While the incident certainly revealed problems with their hazard awareness and waste management practices, plant personnel avoided a potentially catastrophic outcome, and all of their workers made it home safely.
The difference in outcome between these two stories is a legacy of OSHA’s HazCom Standard.
We started you along your HazCom journey by telling you about the real safety benefits that have come from the HazCom Standard, and how much things have improved since the bad old days before the standard existed. As we send you on your way, we’d like to remind you of that.
HazCom isn’t just about meeting a regulatory obligation, or avoiding a violation. It’s about getting our workers home safely. Always remember that, because if you do, you might just get the perspective you need to excel at HazCom management.
Enjoy the rest of your journey – we think you’ve got it from here. Just keep on plugging ahead, with both eyes on the road and two hands on the wheel. And remember that everything you learn along the way will give you new perspectives that will shape your understanding of the whole journey, right back to the beginning.
As T.S. Eliot said in the last poem in his Four Quartets,
“We shall not cease from exploration
And at the end of all our exploring
Will be able to arrive we started
And know the place for the first time.”
Let VelocityEHS Help!
This post may be the end of our series, but not your personal HazCom journey. As you continue your own journey, you’ll probably find you still have questions, and might want some additional support. We’re always here when you need us.
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