Page 54 - Occupational Health & Safety, May 2019

CHEMICAL SAFETY/SDS
difference here. The same software used to track your chemical inventory also should provide employees immediate RTK access to up-to-date SDSs. A true cloud software solution can provide that access from any tablet or smartphone, along with offline access out in the field through an accompanying mobile app.
When considering chemical software options, pay attention to how easy it is to fill gaps in your SDS library. Do you get a library of SDSs to start your search (some of the best solutions have millions of SDSs) and a simple way to request missing or updated SDSs? How often does the solution update existing documents, and does it push updates to you automatically? These features can make a huge difference when it comes to compliance and safety.
Your chemical management software also should provide a fast and easy way to create workplace labels. Information indexed on the SDS can be used to “replicate” the chemical’s shipped label and ensure that all Hazard Communication information on that label is communicated to workers or create customized labels to fit the needs of your people and unique work environment.
Employees armed with the tools described above are more empowered to make their workplaces safer, which is essential as IH increasingly becomes a shared responsibility.
3. Employee Training & Preparedness
One of the keys to getting IH right is employee training. Here, too, chemical management software is invaluable. Employers are required to train employees on key information in SDSs (includ- ing health and physical hazards, storage and disposal requirements, and emergency response information) prior to their working with hazardous chemicals, but SDSs also help employees put that train- ing into use in the moment. Software makes that information easy to access wherever and whenever your people need it.
EHS software also can help simplify your IH training manage- ment by tracking who’s been trained on what and when, while also providing engaging content in a format that’s easy for you to deploy and your people to access.
A common mistake employers make is using a single SDS from one manufacturer to stand in for SDSs from other manufacturers who supply
a similar product. In a 2015 directive, OSHA explained that employers are out of compliance if they don’t maintain the specific SDS for a particular chemical from its manufacturer.
4. Keeping Your IH Sampling Plan Up to Date
A common mistake employers make is using a single SDS from one manufacturer to stand in for SDSs from other manufacturers who supply a similar product. In a 2015 directive, OSHA explained that employers are out of compliance if they don’t maintain the specific SDS for a particular chemical from its manufacturer. Having the specific documents is the only way to make sure you can under- stand and control exposure to the hazards of those chemicals.
Likewise, if you don’t keep your inventory and SDS library cur- rent, you won’t be able to maintain your IH sampling plan. During compliance inspections, it’s common for regulatory compliance officers to ask which chemicals have been added to your inven-
tory since the last time IH sampling was conducted. If chemicals added since then have established exposure limits and you haven’t yet conducted exposure monitoring for them, you’re putting your regulatory compliance and workers at risk.
As new chemicals arrive, carefully review information in their SDSs to identify all ingredients that may pose exposure hazards and include all relevant exposure limitations in your IH plan. Make sure you’re not only sampling for 8-hour time-weighted average ex- posures such as the permissible exposure limit, but also for shorter- term exposure guidelines such as:
■ Short-term exposure limit (STEL), measured as a 15-minute TWA concentration
■ IDLH concentration, which indicates a maximum level above which only a highly reliable breathing apparatus, providing maximum worker protection, is permitted
■ Lower explosive limit (LEL), which is the lowest concentra- tion of a gas or vapor capable of igniting with air
How you incorporate this information into your IH sampling plan will depend on your operations. Those with periodic aspects to them, like cleaning out of a tank or adding chemical ingredients to a mixture, are good examples of instances in which concentrations can temporarily spike. Evaluate compliance with short-term limits like the STEL, IDLH, and LEL while those tasks are performed, in addition to evaluating 8-hour TWAs. Assess your equipment and sampling needs, because you may find it necessary to purchase or rent a photoionization detector (PID) in order to capture airborne concentrations in real time and install monitors with alarms to warn workers when concentrations reach dangerous levels.
The right chemical management software can assist you in tracking this information by grouping products and chemicals into customizable categories that serve up the pertinent information to your people quickly and easily. EHS software also can help you manage your monitoring schedule.
5. Chemical Banning & Approval Workflows
A major component of IH is following the hierarchy of controls, so one of the best ways to control chemical hazards is to keep them out of the workplace in the first place. Well-designed chemical management software can help by creating approval workflows that require sign-off from authorized personnel before a chemical enters the facility, or even letting everyone know within the soft- ware when a product isn’t allowed on premises. Putting this new breed of EHS software to work for you means responsibility for IH best practices can be shared. Workflows and chemical banning al- low you to extend your reach, even when you’re not there in person.
Picking the Right Tools
What should you look for in software for managing IH? It should be easy to implement, easy to use, and work the way you work. The right software can significantly reduce or eliminate the high costs associated with hiring consultants and improve and streamline all aspects of your program. However, the wrong software can become just another obstacle to overcome.
Phil N. Molé, MPH, is an EHS & Sustainability Expert at Veloci- tyEHS, a global leader in cloud environment, health, safety and sus- tainability software. To learn more, visit https://www.MSDSonline. com and https://www.ehs.com.
MAY 2019 | Occupational Health & Safety 50