Page 10 - OHS, April 2022

IH: HAZARD COMMUNICATION
workers, because no one is as familiar with all aspects of their jobs as they are. Deputize your team to perform chemical inspections, to model good HazCom awareness, and to bring you information you’ll need to keep your chemical inventory and management program accurate and up to date.
Upper Management. When executives demonstrate active knowledge of your HazCom practices, they communicate to everyone that HazCom matters. Of course, it can be difficult to get a significant commitment from this group, and you’ll need to respect their time. But at least some input from executives in developing plans encourage them to take more ownership of the program and advocate for its success.
Understand Your Inventory
You can’t manage HazCom if you don’t know what chemicals you have in the workplace. However, knowing what you have isn’t always as easy as it sounds. Many facilities have at least some “surprise” chemicals lurking around which can be dangerous and have regulatory considerations.
This is where a good relationship with Purchasing and a sound procurement policy will head off many potential problems. Knowing what you have coming in ahead of time allows you to identify hazards, proper handling and storage considerations before the chemicals ever cross your threshold and be able to plan accordingly.
Of course, it’s not just knowing what chemicals you have that matters—it’s also understanding their specific hazards and regu- latory considerations required to properly manage the chemicals. Take methylene chloride, which exposure evidence has linked with increased cancer risks and adverse effects to organs such as the heart and liver. Facility managers rarely think they have methylene chloride in their inventory since there’s nothing about the name of the chemical product that provides an obvious clue, and yet it’s a frequent ingredient found in aerosol cans of degreas- ing sprays. Because they don’t know they have it, they’re unable to demonstrate that they are compliant with OSHA’s methy- lene chloride standard, which requires employers to determine whether any employee exposures exceed the action level (AL) of 12.5 parts per million (ppm), measured as a time-weighted av- erage (TWA) in the air, and to take various protective measures when employees exposures exceed the AL. It should be noted that the EPA has also recently proposed taking its own separate mea- sures regarding methylene chloride, so the regulatory burden of having this chemical in your workplace may get even bigger.
This is just one example that demonstrates the critical importance of understanding what chemicals you have. To help you anticipate and avoid these risks, consider a chemical management software solution that features ingredient indexing capabilities. This will provide you with the visibility needed to manage your chemical inventory properly and meet regulatory requirements triggered by ingredients that may be present in the products you use in the workplace.
Harmonize Your HazCom Program
Once you have a good understanding of the chemicals in your inventory, you can harmonize your management of that inventory and its chemical hazards. This is where you ensure you have a safety data sheet (SDS) for every chemical in your inventory and
request any missing documents or outdated versions from your chemical suppliers.
You shouldn’t be using a single SDS for a chemical product to stand in for individual SDSs from every manufacturer who supplies it to you. OSHA addressed this issue in a 2015 directive, which stated “if the employer is maintaining one SDS for a particular chemical but uses that chemical from a different manufacturer or importer without obtaining/maintaining the SDS from the new manufacturer or importer, the employer is not compliant.” While this might seem like a burden at first, it’s the only way to really be sure you have accurate hazard information for all of your chemicals. If you’ve ever dealt with strong acids like sulfuric acid, you know that there’s a big difference between a concentrated or highly diluted solution, and it can make the difference between skin irritation and a severe burn causing permanent tissue damage. The only way to remove ambiguity and ensure you’re dealing with the same chemical at the same concentration with the same hazards, is to have an SDS from every supplier who sends you the chemical.
The product identifier is key to effective HazCom management. Make sure it matches each chemical across your chemical inventory list, your SDS library, the shipped container labels and any secondary container (or workplace) labels. This helps avoid confusing scenarios when the use of a nickname like “Solvent A” is used for a chemical on secondary container labels in lieu of the product identifier listed on the shipped container label and SDS. This creates ambiguity in the minds of employees seeking the SDS for that chemical, and ambiguity is one of the last things you want when it comes to chemical safety.
Make a Plan... and Then Update It
There’s a reason why a written HazCom Plan isn’t the first step on this list. It’s hard to write a halfway decent plan unless you’ve already built a good management team, assessed your chemical inventory and taken steps to harmonize your program.
Your HazCom Plan is your playbook and needs to reflect the specific chemical hazards and HazCom management policies at your facility. One common pitfall with HazCom compliance is having a written plan that is not sufficiently site-specific. All too often, managers simply download a HazCom Plan template, fill in a few blanks and wind up with something that resembles a completed plan—but is far from it. In actuality, it takes time to develop a plan that is adequately detailed and tailored to your workplace to comply with OSHA’s requirements. That doesn’t mean that your plan has to be perfect at first; in the beginning, it’s okay just go through the exercise of trying to accurately describe your HazCom management practices, get it all down in a draft document, and then refine it later.
The fact is, your written HazCom Plan will always be a work in progress in some sense, because you’ll need to continue to update it each time you make a major change to your program, like introducing a new kind of hazard (i.e., bringing a chemical into your workplace for the first time) or changing details about your workplace labeling system. You’re more likely to be compliant in the long run if you realize that you’re going to need to revisit and revise your Plan. Many people spend the effort to write a detailed HazCom Plan only to end up with a static document that just gathers dust and doesn’t change as their HazCom management
10 Occupational Health & Safety | APRIL 2022 www.ohsonline.com