Taking the Lead on Chemical Substitution

It still takes individuals properly trained and positioned within an organization to make it all work. OH&S professionals are primed to take the lead.

• By Chuck Haling
• Oct 01, 2014

Chemicals in the workplace lead to over 190,000 illnesses and 50,000 deaths annually in the United States. These shocking statistics, referenced by OSHA on its chemical substitution web page, stem from a 2006 California Policy Research Center report entitled "Green Chemistry in California: A Framework for Leadership in Chemicals Policy and Innovation."

Statistics aside, there is a global growing awareness that more can and should be done to safeguard employees, our communities, and the environment from the effects of hazardous chemicals. Chemical substitution has been identified as one of the primary tools for achieving those ends, and on that front, OH&S professionals are uniquely positioned to take the lead.

Following are five steps OH&S professionals, or anyone charged with leading a chemical substitution initiative, can follow in order to maximize the benefits of their activities.

1. Know why OH&S professionals make great leaders.
The role of safety professionals in many organizations has expanded in recent years to encompass sustainability, greening of the supply chain, and a variety of important resource management initiatives. Safety professionals have a number of attributes and responsibilities that make them well suited to the tasks of chemical substitution.

First, worker safety is squarely under their domain. Second, safety professionals work cross-departmentally and are likely to have the institutional relationships necessary to help implement a far-reaching change. Third, years of experience talking about difficult subjects with unsympathetic audiences have honed their communication skills, which are needed to garner buy-in. Finally, safety professionals often have the technical experience required to understand the hazards of workplace chemicals and to discern the tradeoffs of potential alternatives.

Too often in the workplace, safety has been treated as a cost center and ignored until something goes wrong. Conversely, sustainability, as of late, has been gaining favor as a responsible course of action that benefits a company’s bottom line. Safety professionals may want to investigate how their activities can be folded under the sustainability marquee, for greater acceptance and access to needed resources. Regardless, chemical substitution is in the wheelhouse of the safety department, providing an opportunity for safety managers to demonstrate how the priorities of health and safety align with the financial and production priorities of the organization as a whole.

2. Understand the push toward chemical substitution and the potential benefits.
There are myriad reasons for transitioning away from hazardous chemicals to safer alternatives. On a basic level, it conforms to the hierarchy of controls, which posits that there is an order in which hazards should be dealt with, with the most effective controls considered first and the least effective controls used when necessary. The controls in order of effectiveness are:

• Elimination
• Substitution
• Engineering controls
• Administrative controls
• Personal protective equipment (PPE)

Looking at these controls through the lens of chemical safety, the order makes sense. Eliminating chemicals hazards in the workplace removes the risks they pose. Next best is substituting the hazardous chemical for something non-hazardous or less hazardous. These activities can reduce the costs and work associated with storing and disposing of chemicals and training and equipping employees. It can also reduce liabilities and costs from downtime due to accidents and occupational injuries and illnesses.

It is important when substituting chemicals to select safer alternatives and not just swap one harmful agent for another, which could do even more harm to employees and downstream users of products.

If a company is unable to remove the hazard entirely or minimize it, then it should look next at engineering controls, which physically change the workplace to remove the hazard or place a barrier between the hazard and the worker. Next, it should look at administrative controls that require employer/employee actions to align with new processes that seek to mitigate risks. If a hazard cannot be controlled by the methods described above, then an employer may have to resort to PPE, which is generally considered the least effective method of control.

The benefits of chemical substitution go beyond safety, and a strong business case can be made that chemical substitution benefits include improvements to productivity through gained efficiencies, as demonstrated by the American Industrial Hygiene Association (AIHA) in a 2008 study, "Demonstrating the Business Value of Industrial Hygiene." These efforts, the study concluded, positively contribute to a company's bottom line.

Proof of the business case can be seen in the marketplace today: Local, state, federal, and international regulations are mandating the move toward safety alternatives; consumers are demanding safer products and services and are rewarding companies that provide it, and communities are holding business more accountable for their actions; larger downstream companies are mandating safer chemicals and tighter hazard communication protocols from upstream suppliers. In today's marketplace, sustainability is good business.

3. Get Buy-In from Upper Management
Unless the directive to transition to safer chemicals in the workplace comes from upper management, making a move to alternative chemicals is likely to require buy-in from several organizational layers, and change is a notoriously difficult sell. Getting support at the executive level can open a lot of minds down the organizational chart and provide the resources necessary to effect change. How to do it:

First, learn where management stands on safety and chemical hygiene. Get to know their thoughts around safety and other topics--don't try to sell at first, really listen to them.

Second, generate support. Identify one or two executives who will give a new proposal a fair hearing. Any feedback they provide is valuable. Ideally, one of them will become a champion for the idea… and to that end, give them as much credit for the idea as necessary.

Finally, craft an appropriate business case. Use the work in steps one and two to craft an argument that addresses the viewpoints, concerns, and priorities of the decision-makers. Too often, safety initiatives are couched in soft, moral arguments, rather than the language of business to which executives are trained to respond. Match the language to the audience.

4. Carry out the transition to safer chemical alternatives.
OSHA has outlined seven steps it recommends for making the transition successful. Those steps are:

More specifically, OSHA recommends:

• Getting the right mix of stakeholders together to ensure a comprehensive and successful implementation. With this team, set goals, tasks, and timelines.
• Performing a chemical inventory, making sure to include all chemicals to which employees are exposed and that a safety data sheet is on hand for each.
• Prioritizing chemicals for substitution based upon their intrinsic hazards and potential for exposure. A good electronic SDS management tool can make it easier to search safety data sheets for chemicals of concern, even at the ingredient level. Extremely hazardous chemicals as identified by the EPA, OSHA, and other agencies should be at or near the top of the list.
• Locating alternatives that could replace the chemical in question, including using steps outlined in the hierarchy of controls to abate the chemical hazard.
• Making an informed decision by analyzing the comparable hazard footprints of the alternatives under consideration, including data about hazards, performance, costs, and other factors, and then selecting the best option. The best option will likely include a number of trade-offs, some of which may require new protections to safeguard employees, even though safety as a whole improves.
• Testing and evaluating to ensure that the piloted improvement achieves desired results without complicating matters. This final step is never really finished because chemical hazard abatement is an ongoing process, and new technologies and chemical alternatives are being developed at an accelerated pace.

5. See the big picture when it comes to hazardous chemicals.
Chemical substitution is just one step among many that should be taken in workplaces to mitigate dangers of hazardous chemicals. OH&S professionals must also consider the fitness of their HazCom plan in general. Questions to ask include: Are all chemicals inventoried and safety data sheets secured? Is the requisite information available to employees in their work areas during their work shifts? Are all affected employees trained on the hazards of the chemicals to which they are exposed? Is the labeling strategy adequate to meet the needs of employees and downstream users? What obligations exist to communicate information to community stakeholders?

Regarding this last question, many employers with chemicals of an extremely hazardous nature, or chemicals present in sufficient quantities, are required to report information on their chemical inventories to the EPA, Local Emergency Planning Committees (LEPCs), State Emergency Response Commissions (SERCs), and local first responders. Even without regulations compelling compliance, open and active dialogue with those responsible for public safety benefits both businesses and the community. Recently, Executive Order 13650 called on a coalition of federal agencies to improve chemical facility safety. The group's preliminary findings state the need for improvement in the communication of hazard information from businesses to first responders.

This problem can be addressed only so far by governmental agencies and new policies; also needed is help from the private sector in the form of new services and technologies that make connecting the information between stakeholders faster and easier. An example of the latter is MSDSonline's Plan 1 service that allows for the seamless distribution and sharing of customers' safety data sheets, product summaries, and facility floor-plan maps with local fire departments. New communication channels must be opened up, the information is there, but it does no good if it is not in the right hands at the right time.

OH&S in the Lead
Chemical management in general, and chemical substitution specifically, are increasingly in the cross hairs of global commerce and regulatory initiatives. The Globally Harmonized System (GHS), a model HazCom system sweeping into prominence around the world, is making it easier for everyone in the hazardous chemical supply chain to share information and best practices. But it still takes individuals properly trained and positioned within an organization to make it all work. And for the items discussed above, OH&S professionals are primed to take the lead.

References
1. https://www.osha.gov/dsg/safer_chemicals/index.html
2. http://coeh.berkeley.edu/docs/news/06_wilson_policy.pdf
3. https://www.aiha.org/votp_new/pdf/votp_report.pdf

This article originally appeared in the October 2014 issue of Occupational Health & Safety.