Page 44 - Occupational Health & Safety, September 2018

CHEMICAL SAFETY
fines a hazardous chemical as any chemical that poses a physical or health hazard. Physical hazards are chemicals for which there is sci- entifically valid proof that it is a combustible liquid, a compressed gas, flammable, an organic peroxide, an oxidizer, pyrophoric, wa- ter reactive, or is otherwise unstable (reactive). Health hazards are chemicals for which there is statistically significant evidence that acute or chronic health effects may occur in exposed employees. This includes chemicals that are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepa- totoxins, nephrotoxins, neurotoxins, agents that act on the hema- topoietic system, and agents that damage the lungs, skin, eyes, or mucous membranes.
These requirements and definitions provide the foundation for how you should define your chemical management plan and chemical safety training program.
Your Chemical Safety Training Guide
Your chemical safety training program should offer the following core information: chemical inventory listing; standard operating procedures for the use of chemicals in the workplace; safety data sheet and labeling information; specific chemical risks in your fa- cilities; precautions and emergency response procedures; storage, disposal, and transportation considerations; and training resources and requirements. Let’s consider these in a bit more depth:
Chemical inventory listing. This should contain either a listing of the chemicals in your facility or instructions on how to access the inventory if you are using another format to publish chemical information, such as an online SDS management system. The list- ing should be maintained on a periodic basis, ideally through an annual physical chemical inventory to account for additions, sub- tractions, and disposals. Furthermore, the listing can and should be used to reconcile to safety data sheets made available to employees.
Chemical SOPs (Standard Operating Procedures). This would include general guidelines on the usage of and presence of chemicals in the workplace. Some specific SOPs include: fol- lowing company chemical approval processes, understanding the hazards prior to usage, ensuring that you are outfitted with all rec- ommended PPE prior to usage, not working alone while working with hazardous substances, avoiding direct contact with hazardous substances, and having a general understanding of exposure con- trol systems for the chemicals in your area and being mindful if you experience any of those conditions.
Safety data sheets (SDS). Your training should outline where to find SDS and how to read them. If using an online SDS sys- tem, make sure that you provide clear operating instructions and training on that system. This is typically the most effective way to publish chemical information and provide access, as these systems offer multiple methods to access chemical information—either di- rectly from the safety data sheet or from indexed data that can be searched directly, such as PPE, emergency response, etc.
Labeling. Chemical containers must include a label outlining the product name, manufacturer, signal words, hazards, precau- tionary statements and pictograms. Train your workers on how to read these labels, especially the visual pictograms.
Specific facility risks. You might have specific chemical risks in your facilities due to the nature of your business or industry. You might have higher volumes of certain chemicals or maybe more hazardous substances. It’s always a good idea to emphasize these
and even specifically identify these in your training plan for ex- tra attention and education. For example, identifying chemicals by particular hazards, such as flammable, carcinogens, volatile/reac- tive, combustible, etc. is always a good idea.
Precautions and emergency response procedures. What are the standard precautions and emergency response procures for your facility? What PPE is required? Where can it be accessed? Where are emergency eyewashes, showers, exits, etc. in the event of a chemical spill, exposure or emergency? What is the evacuation plan? Your chemical training plan should address these facility- specific questions to ensure maximum protection.
Storage, disposal, and transportation considerations. Define the storage requirements for hazardous chemicals or refer to the specific instructions per the chemical label. Ensure that employees are aware of potentially incompatible chemicals that exist in your facility or chemicals with specific storage requirements.
Training resources and requirements. Provide easy access information so workers know where to get more information. There is a lot to communicate with chemicals, so it’s important to reinforce any periodic training with on-demand training and resources for specific instances that an employee may face while working. This could be in the form of on-demand, mobile train- ing on their phones so they can review safety precautions prior to working with a chemical. It also may include posters with emer- gency response information that detail how to access safety data sheets or call an emergency response line in the event of a chemi- cal exposure or spill.
Put It Into Practice
So how do you implement the training plan, and what are some best practices for chemical safety training? First, combining both instructor-led training and online training is a good way to re- inforce concepts repeatedly for your workforce. As noted above, chemical information can be overwhelming at times, so offering repeatable, bite-size concepts repeatedly is often the best way to handle employee training. This is known as “micro-learning”—fo- cus on smaller, more defined concepts in an on-demand environ- ment so the student learns and retains the key learning concepts.
Additionally, make your training global and local: Offer general training and information related to chemical safety as a whole, but also deliver location-specific, chemical-specific, and hazard-specif- ic training for individual locations or employees working with ex- tremely hazardous substances. Consider a “connected compliance” approach. If you have your chemical/SDS management system on the same platform as your training, you can more easily match em- ployees, chemicals, and chemical risks by location to deliver the right training to the right employee at the right time.
Regarding timing and frequency, it’s recommended that work- ers receive training regarding the physical and health hazards of the chemicals in their work area at the time of their initial assignment to the work area, whenever a new chemical hazard is introduced into the work area, or annually as part of a coordinated workplace safety training effort.
Kraig Haberer is General Manager of the SafeTec strategic business unit for the Health & Safety Institute (HSI). HSI is an EHS Man- agement software provider specializing in workplace safety training, chemical management, and emergency response solutions.
40 Occupational Health & Safety | SEPTEMBER 2018
www.ohsonline.com