Page 48 - Occupational Health & Safety, January/February 2019

IH/CHEMICAL SAFETY
quirements such as Tier II or TRI report- ing. A comprehensive view of how others in the organization use chemical data could shed light on additional information or re- sources available. Also, understanding the needs of others can help position a chemi- cal management program in a way that complements operations throughout the business. Be sure to speak with colleagues with different areas of expertise and, more specifically, across EHS to ensure that the full picture is accounted for.
Be Thorough
After gaining a thorough understanding of current chemical management practices, it is important to ensure best practices and compliance requirements aren’t falling through the cracks. For each chemical on site, the following items should be true:
■ Full-time employees, seasonal em- ployees, and contractors have access to a recently verified version of the chemical’s SDS.
■ The correct risk assessments have been completed.
■ The PPE requirements for using and being around chemicals are understood.
■ The correct GHS labeling is present on all chemical containers.
■ Correct storage requirements are in place and understood.
■ Compliant reporting requirements are understood and monitored.
■ Emergency response and spill noti- fication procedures are understood.
■ Appropriate spill containment and first aid resources are available on site.
■ Correct chemical disposal practices are used and understood (including air emissions, wastewater management, and hazardous waste information).
EHS teams and regulators often use reactive control measures to ensure the items above are in place, which can include scheduled/spontaneous audits and inspec- tions. When a problem is discovered dur- ing an audit or inspection, it is important to fix the issue immediately and determine the root cause. Determining and assess- ing the root cause helps to ensure that the same issue does not repeat itself. For example, if a container is found without a label, it is easy to apply the appropriate la- bel or dispose of the container if no longer in use or needed. However, if employees
are unaware that a label is necessary, this problem would continue to occur. By ad- dressing this training gap, employees can be educated on GHS label requirements and how proper practices can minimize the chance of personal injury.
Technological solutions also can be an effective fix to common problems. For ex- ample, pre-populated, on-demand labels can help with the labeling example just described. Ensure that the right people are monitoring what is available on the mar- ket to reduce risk, save time, and become more efficient.
Be Proactive
A proactive chemical management pro- gram enables organizations to further miti- gate risk by identifying potential down- stream issues. The farther ahead an EHS program can get, the more predictable and safer day-to-day operations can become. Below are several areas where organiza- tions can become more proactive and im- prove efficiency when it comes to chemical management.
Chemical approval: Implementing a chemical approval process enables the EHS team to review and assess materials before they arrive on site. The key to an effective chemical approval process is ensuring that employees are properly trained and that the approval process is user friendly. As an EHS professional, it would be beneficial to know everything about a material as soon as it is submitted for approval. However, employees would be much less likely to use the chemical approval system if they had to spend hours locating information and completing the assigned steps. Find- ing a balance between user experience and information entry requirements is critical. Many organizations use electronic systems for chemical approval. If this is a solution being considering, be sure there is the op- tion to change the chemical approval pro- cess over time. Doing so ensures there is a balance between information entry re- quirements and engagement to ensure user adoption throughout the organization.
Leveraging technology: Chemical data is continuously changing, and the manage- ment of chemical data can be challenging if a proactive system is not in place. This is especially true for chemical inventories and maintaining accurate SDSs. For current
and correct chemical inventories, having regularly scheduled updates of inventories (especially during slower periods) and us- ing a task management system proves to be a sustainable method. When it comes to SDSs, using an electronic system that pro- vides the most up-to-date SDSs for materi- als can save hours, days, or even weeks.
Employee engagement: The impact of any EHS initiative is directly proportional to employee adoption. Being proactive and considering adoption before making changes is critical. Management buy-in is helpful for user adoption. An effective top-down message throughout the orga- nization helps emphasize the importance of chemical management. Also, ensure that the appropriate end users are kept in mind as the ultimate customer when implementing a chemical management plan. For example, many organizations are making use of mobile devices to remove barriers to SDS access. If employees don’t understand the training or what is expect- ed of them, compliance with a plan will be tough down the road. Lastly, ensure that good behavior is rewarded through posi- tive reinforcement. Being proactive about employee engagement can be the differ- ence between a chemical management plan’s success and failure.
Although it can seem overwhelming at times, an effective chemical management program is paramount to an effective EHS program. Gaining a deep understanding of chemicals on site and what they are used for is the first step toward success. Being thorough and putting controls in place as they pertain to chemicals enables an orga- nization to achieve compliance and mini- mize risk. Lastly, being proactive when possible helps further reduce risk and costs by getting ahead of potential downstream problems. By being informed, thorough, and proactive, EHS professionals can set themselves up to effectively manage chemi- cal risk.
Matt Adams is a thought leader in the EHS and Product Stewardship space and is currently a Senior Solution Engineer at SiteHawk. He has experience in the field as a safety officer and at the solution develop- ment level as a product consultant. He holds a degree in environmental engineering from the University of Guelph in Canada.
42 Occupational Health & Safety | JANUARY/FEBRUARY 2019
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