Page 14 - OHS, January/February 2022

IH: CHEMICAL SAFETY
added to your inventory since the last time IH sampling was conducted during inspections. If chemicals added since then have established exposure limits, and you have not yet conducted exposure monitoring for them, you are 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 are not only sampling for eight-hour time-weighted average exposures such as the permissible exposure limit (PEL), but also for shorter-term exposure guidelines such as:
■ Short-term exposure limit (STEL), measured as a 15-minute TWA concentration.
■ Immediately dangerous to life and health (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 concentration 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 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 eight-hour TWAs. Assess your equipment and sampling needs, because you may find it necessary to purchase or rent a photoionization detector (PID) to capture airborne concentrations in real time and install monitors with alarms to warn workers when concentrations reach dangerous levels.
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.
IH software can assist you in managing your IH sampling program by giving you a simple platform for selecting chemicals to be sampled, identifying correct analytical methods, creating your SEGs and even helping choose the right laboratories for the job. Along the way, your information is accessible to all parties that need to access it, including corporate EHS representatives, consultants and laboratory technicians. This not only makes your job easier, but helps ensure the seamless hand-off of responsibilities from one stakeholder to the others, minimizing the chance for mistakes or miscommunications and keeping your entire workforce safer.
IH Reporting and Employee Right-to-Know
Once you have your IH sampling results, you need to make sure you are able to easily share the results with employees. Keep in mind that specific standards require the employer to automatically notify affected employees of monitoring results. For instance, employers must notify employees of their methylene chloride exposures within 15 working days of receiving results. “Access
14 Occupational Health & Safety | JANUARY/FEBRUARY 2022
to Employee Exposure and Medical Records” in OSHA standard 1910.1020 requires employers to provide access to exposure records within 15 days of an employee request. If this cannot be done, the employer must inform the employee of the reason for the delay and the earliest day when the records can be available.
Software makes it easier to comply with these notification requirements by tracking results and maintaining them in one centralized location. The solution also flags results that exceed the applicable OEL to help you prioritize your communications and know when follow-activities are needed.
Employee Training and Preparedness
One of the keys to getting IH right is employee training. Here, too, software is invaluable. Employers are required to train employees on key information in SDSs (including health and physical hazards, storage and disposal requirements, and emergency response information) prior to their working with hazardous chemicals,butSDSsalsohelpemployeesputthattraininginto use in the moment. Software that makes that information easy to access wherever and whenever your people need it makes it more likely they will use it.
A robust IH solution streamlines training through reporting tools that enable you to share details of your IH sampling program with your workforce and give them the kind of specific training on your chemical hazards and exposure assessments you need to promote the success of your IH program. Software also simplifies IH training management 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.
Chemical Banning and 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 software helps you do just that by creating approval workflows that require sign-off from authorized personnel before a chemical enters the facility, or even letting everyone know within the software when a product isn’t allowed on premises.
Picking the Right Tools
You cannot be everywhere at once and, as mentioned before, the need for IH has increased while people and resources to manage it have become scarcer. Putting this new breed of EHS software to work for you means that responsibility for IH best practices can be shared. Workflows and chemical banning allow you to extend your reach, even when you’re not there in person.
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. While there are quite a few nuances to doing chemical management and IH effectively, the right tools help you meet the challenges of IH in changing times and provide a safer, healthier workplace for all.
Phil N. Molé, MPH, is an EHS & Sustainability Expert at VelocityEHS. www.ohsonline.com