Ensure that the appropriate end users are kept in mind as the ultimate customer when implementing a chemical management plan. (SiteHawk photo)

The Three Keys to Effective Chemical Management

Although it can seem overwhelming at times, an effective chemical management program is paramount to an effective EHS program. Gaining a deep understanding of chemicals on site and what they are used for is the first step toward success.

Environmental, Health and Safety (EHS) professionals are at the forefront of maintaining visibility and mitigating risk in a business environment that is changing faster than ever before. As organizations adapt to take advantage of new opportunities and remain competitive, they must account for the change that occurs in their risk profiles. In EHS and product stewardship, this means new processes, new ingredients, new compliance obligations, and changing job responsibilities. Whether it's in the supply chain, during operations, during the delivery of services, or during the end use of a product, there is ongoing risk surrounding the use, storage, and data management of chemicals. Being able to identify risks, handle them accordingly, and be proactive is vital to protect the organization, its employees, the public, and the environment. This article is intended to provide three principles and accompanying guidelines to help any organization effectively mitigate the ever-changing risks associated with chemical management.

Be Informed
When it comes to mitigating risk, knowing is half the battle. It's important to understand which chemicals are on site throughout each operating location and understand what those chemicals are used for and the hazards/compliance requirements associated with using them.

Determining which chemicals are on site is generally done by tracking new chemicals as they come in and performing periodic inventories. The more organized the data, the easier it is to understand and maintain the inventory. Organizations often segment operating facilities into chemical areas and manage the inventories area-by-area, thus allowing them to roll up into a general facility-wide inventory. Along with these inventories, it is necessary to maintain an up-to-date copy of the Safety Data Sheet (SDS) for each chemical. Solutions to organize and maintain a chemical inventory and the respective SDS that goes along with each chemical can vary from manual methods to full-service electronic options. Utilizing technology and automated systems can save time and money. Some solutions also include services to update SDSs, enabling employees to focus on their area of expertise.

Identifying what chemicals are used for is important, as well. Chemicals used in processes need to be considered in training, risk assessments, and PPE requirements. Over time, organizations tend to store chemicals that may have been used only for a one-time purpose or process that has since changed or been eliminated. Safely disposing of all excess chemicals can reduce the time and effort spent on inventory maintenance and compliance tasks.

It is crucial to consider any compliance requirements when understanding an organization’s chemical management obligations. There are chemical-focused requirements pertaining largely to safety, such as HazCom and REACH, but there are also chemical requirements that could potentially overlap with other areas of responsibility in the organization. For example, consider chemicals of interest for the Department of Homeland Security or environmental-specific requirements such as Tier II or TRI reporting. A comprehensive view of how others in the organization use chemical data could shed light on additional information or resources available. Also, understanding the needs of others can help position a chemical management program in a way that complements operations throughout the business. Be sure to speak with colleagues with different areas of expertise and, more specifically, across EHS to ensure that the full picture is accounted for.

Be Thorough
After gaining a thorough understanding of current chemical management practices, it is important to ensure best practices and compliance requirements aren't falling through the cracks. For each chemical on site, the following items should be true:

  • Full-time employees, seasonal employees, and contractors have access to a recently verified version of the chemical's SDS.
  • The correct risk assessments have been completed.
  • The PPE requirements for using and being around chemicals are understood.
  • The correct GHS labeling is present on all chemical containers.
  • Correct storage requirements are in place and understood.
  • Compliant reporting requirements are understood and monitored.
  • Emergency response and spill notification procedures are understood.
  • Appropriate spill containment and first aid resources are available on site.
  • Correct chemical disposal practices are used and understood (including air emissions, wastewater management, and hazardous waste information).

EHS teams and regulators often use reactive control measures to ensure the items above are in place, which can include scheduled/spontaneous audits and inspections. When a problem is discovered during an audit or inspection, it is important to fix the issue immediately and determine the root cause. Determining and assessing the root cause helps to ensure that the same issue does not repeat itself. For example, if a container is found without a label, it is easy to apply the appropriate label or dispose of the container if no longer in use or needed. However, if employees are unaware that a label is necessary, this problem would continue to occur. By addressing this training gap, employees can be educated on GHS label requirements and how proper practices can minimize the chance of personal injury.

Technological solutions also can be an effective fix to common problems. For example, pre-populated, on-demand labels can help with the labeling example just described. Ensure that the right people are monitoring what is available on the market to reduce risk, save time, and become more efficient.

Be Proactive
A proactive chemical management program enables organizations to further mitigate risk by identifying potential downstream issues. The farther ahead an EHS program can get, the more predictable and safer day-to-day operations can become. Below are several areas where organizations can become more proactive and improve efficiency when it comes to chemical management.

Chemical approval: Implementing a chemical approval process enables the EHS team to review and assess materials before they arrive on site. The key to an effective chemical approval process is ensuring that employees are properly trained and that the approval process is user friendly. As an EHS professional, it would be beneficial to know everything about a material as soon as it is submitted for approval. However, employees would be much less likely to use the chemical approval system if they had to spend hours locating information and completing the assigned steps. Finding a balance between user experience and information entry requirements is critical. Many organizations use electronic systems for chemical approval. If this is a solution being considering, be sure there is the option to change the chemical approval process over time. Doing so ensures there is a balance between information entry requirements and engagement to ensure user adoption throughout the organization.

Leveraging technology: Chemical data is continuously changing, and the management of chemical data can be challenging if a proactive system is not in place. This is especially true for chemical inventories and maintaining accurate SDSs. For current and correct chemical inventories, having regularly scheduled updates of inventories (especially during slower periods) and using a task management system proves to be a sustainable method. When it comes to SDSs, using an electronic system that provides the most up-to-date SDSs for materials can save hours, days, or even weeks.

Employee engagement: The impact of any EHS initiative is directly proportional to employee adoption. Being proactive and considering adoption before making changes is critical. Management buy-in is helpful for user adoption. An effective top-down message throughout the organization helps emphasize the importance of chemical management. Also, ensure that the appropriate end users are kept in mind as the ultimate customer when implementing a chemical management plan. For example, many organizations are making use of mobile devices to remove barriers to SDS access. If employees don't understand the training or what is expected of them, compliance with a plan will be tough down the road. Lastly, ensure that good behavior is rewarded through positive reinforcement. Being proactive about employee engagement can be the difference between a chemical management plan's success and failure.

Although it can seem overwhelming at times, an effective chemical management program is paramount to an effective EHS program. Gaining a deep understanding of chemicals on site and what they are used for is the first step toward success. Being thorough and putting controls in place as they pertain to chemicals enables an organization to achieve compliance and minimize risk. Lastly, being proactive when possible helps further reduce risk and costs by getting ahead of potential downstream problems. By being informed, thorough, and proactive, EHS professionals can set themselves up to effectively manage chemical risk.

This article originally appeared in the January/February 2019 issue of Occupational Health & Safety.

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