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IH: CHEMICAL SAFETY risks are approached with green chemistry principles in mind, the benefits extend well beyond safety and environmental safeguards to include several other advantages for the organization. These benefits include: ■ Cost savings–reduce expenses and future risks ■ Efficiency–improve process performance ■ Industry leadership–invest in innovation to stay competitive ■ Corporate stewardship–advance socially responsible chemical management practices ■ Social stewardship–improving employee safety and well- being According to OSHA, actively reducing or eliminating chemical hazards at their source is the most effective means of protecting workers, and it establishes a chemical management system that surpasses simple compliance with HazCom requirements. In some cases, unfortunately, substitution with a greener, less hazardous chemical is not an option. Such was the case in our arsenic example, where the chemical was produced as a contaminant by the client who shipped parts to our facility. Exposure Assessments at the SDS Level During a new chemical review, industrial hygienists will typically assess the site’s existing exposure monitoring data, ventilation specs and other exposure controls to determine if further monitoring will be necessary when the new substance is introduced. What some hygienists don’t realize is that we can simultaneously protect workers while reducing the need for exposure monitoring by completing a qualitative exposure assessment (QEA) at the SDS level, prior to a chemical even entering the plant. Using this proactive approach, substances that have been flagged within the chemical management software will be automatically assigned to the hygienist for approval, allowing them to use the known hazard information in the SDS to conduct their QEA. As mentioned in our Industrial Hygiene Program Management Guide, the AIHA has developed a simple model for conducting QEAs. See Figure 1: Formula Conducing QEAs Had I been the site industrial hygienist responsible for doing an SDS-based QEA for our arsenic example, I would have used my knowledge of the site’s engineering controls and PPE requirements to hypothesize that the exposure rating (ER) was going to be a 4, while assigning a health effect rating (HER) of 4 since arsenic is a known human carcinogen: ER of 4 x HER of 4 = Risk Rating of 16. With a risk rating of 16, the QEA would have provided preemptive documentation that handling this chemical with existing exposure controls was going to be a high-risk task. Before the chemical entered the plant, I would have been able to use this information to determine appropriate ventilation and PPE, adjust my IH sampling plan if I did not already have data and educate employees on the hazards being introduced and the controls implemented to protect their health. Final Thoughts In our example, had the environmental engineer included IH considerations in the risk assessment process, the hazards of the arsenic would have been proactively recognized and evaluated to determine if the site had appropriate ventilation controls and PPE, and prioritize parts cleaning tasks for additional IH monitoring. If the company had used a chemical management software solution in their chemical safety reviews, the arsenic could have been flagged due to its acute and chronic health effects as well as OSHA regulatory requirements. The hygienist could have done the QEA before the parts entered the plant and would have known in advance what the risk rating was, along with having already made the determination of what controls were needed. By performing the QEA at the SDS level, we could have then used those findings to focus on chemical safety basics: educating affected workers on the chemical’s hazards and how to handle them safely. Kristi Hames, Senior Solutions Strategist, Industrial Hygiene at VelocityEHS, supports the development of industrial hygiene and ergonomics software products that empower users to improve their health and safety performance. Kristi assists customers in developing, implementing, evaluating and improving their industrial hygiene and ergonomics processes. Prior to joining VelocityEHS, Kristi has had 15-plus years of experience in managing corporate industrial hygiene and ergonomics programs for a Fortune 500 specialty chemical company. Her responsibilities included the development, implementation, and monitoring of health and safety programs for workplace hazards ranging from manufacturing facilities to office environments. Kristi actively worked with leadership to identify hazards and develop control strategies for future regulatory concerns. 0: <1% of the OEL 0: Nuisance health effects of concern 2: Between 10% and 50% of the OEL 2: Severe, reversible health effects of concern 4: > 100% of the OEL 4: Life-threatening or disabling injury or illness Figure 1: Formula Conducing QEAs Risk Rating = Exposure Rating x Health Effect Rating Here are common ratings used for these variables: Exposure Rating 1: Between 1% and 10% of the OEL 3: Between 50% and 100% of the OEL Source: AIHA: A Strategy for Assessing and Managing Occupational Exposures, 4th Edition Health Effect Rating 1: Reversible irritation or discomfort 26 Occupational Health & Safety | JUNE 2023 www.ohsonline.com 3: Irreversible health effects of concern