By June 1, 2016, OSHA expects all employers to be fully compliant with GHS adoption.

Chemical Management: Five Ways to Meet the Challenges of IH in a Changing Industry

The most robust software solutions feature ingredient indexing to help you track chemical ingredients across products while flagging those that are subject to more stringent regulatory standards.

Industrial hygiene (IH), the deliberate and scientific control of occupational hazards and risks, is more important than ever. Yet for the last 20 years, the number of certified industrial hygienists (CIHs) has been on the decline. CIH responsibilities are being subsumed by technicians and EHS generalists, farmed out to costly consultants, or even left unfulfilled.

The EHS industry is changing in response to these challenges. For one thing, professional organizations such as the American Industrial Hygiene Association (AIHA) have opened their doors and have begun targeting their message about the importance of IH to broader audiences.

For another, EHS software is empowering employees at all levels to make workplaces healthier, more productive environments. Best of breed cloud-based programs make it easy to follow industry best practices, capture data, facilitate the flow of information, and provide real-time visibility and reporting into occupational activities.

A great example of the ability of software to bolster IH is in the management of chemicals. Proper chemical management is a critical component of a solid IH program, even if many organizations fall short. Hazard Communication has ranked #2 or #3 on OSHA’s annual list of most cited violations for more than a decade, which points to systemic chemical management issues that undermine the effectiveness of IH programs and place workers at risk.

Following is a look at five ways software can help improve chemical management, strengthen your IH program, and protect the safety of your workforce.

1. Chemical Inventory & Ingredients Tracking
Everything starts with knowing what chemicals you have in the workplace. It's the key to drafting an accurate written HazCom plan, ensuring you have all necessary safety data sheets (SDSs) for the chemicals in your inventory, effectively managing workplace labels, training your employees on chemical hazards, and meeting regulatory responsibilities.

However, knowing what chemical products you have isn’t enough. You also need visibility into the ingredients of those products, along with their specific hazards and regulatory considerations. Take methylene chloride, for example, a common ingredient in aerosol degreasing sprays and paint-removing solvents. Facility managers are often unaware it is present in their facilities because the names of the products don't provide obvious clues. And if you don’t know you have methylene chloride, it's unlikely that your IH program includes exposure monitoring for it, which leaves you out of compliance with OSHA’s methylene chloride standard.

A good chemical management software solution makes it easy to avoid this issue. Chemicals can be tracked by container at the company, facility, department, and even storage level. Some software even gives you visual insight into of your chemical footprint with drag-and-drop controls that allow you to instantly identify, move, and manage your chemical inventory on an image map of your facility. And the most robust software solutions feature ingredient indexing to help you track chemical ingredients across products while flagging those that are subject to more stringent regulatory standards.

2. Right-to-Know (RTK) Access
Not only must you know what chemicals you have, but also you must make sure your workforce does, as well. That means ensuring employees have access to SDSs in their work areas during their work shifts and that all chemical containers remain properly labeled with the original manufacturer-supplied label on shipped containers or employer-created workplace labels on secondary containers.

Chemical management software can make a big difference here. The same software used to track your chemical inventory also should provide employees immediate RTK access to up-to-date SDSs. A true cloud software solution can provide that access from any tablet or smartphone, along with offline access out in the field through an accompanying mobile app.

When considering chemical software options, pay attention to how easy it is to fill gaps in your SDS library. Do you get a library of SDSs to start your search (some of the best solutions have millions of SDSs) and a simple way to request missing or updated SDSs? How often does the solution update existing documents, and does it push updates to you automatically? These features can make a huge difference when it comes to compliance and safety.

Your chemical management software also should provide a fast and easy way to create workplace labels. Information indexed on the SDS can be used to "replicate" the chemical's shipped label and ensure that all Hazard Communication information on that label is communicated to workers or create customized labels to fit the needs of your people and unique work environment.

Employees armed with the tools described above are more empowered to make their workplaces safer, which is essential as IH increasingly becomes a shared responsibility.

3. Employee Training & Preparedness
One of the keys to getting IH right is employee training. Here, too, chemical management 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, but SDSs also help employees put that training into use in the moment. Software that makes that information easy to access wherever and whenever your people need it makes it more likely they'll use it.

EHS software also can help simplify your 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.

4. Keeping Your IH Sampling Plan Up to Date
A common mistake employers make is using a single SDS from one manufacturer to stand in for SDSs from other manufacturers who supply a similar product. In a 2015 directive, OSHA explained that employers are out of compliance if they don't maintain the specific SDS for a particular chemical from its manufacturer. Having the specific documents is the only way to make sure you can understand and control exposure to the hazards of those chemicals.

Likewise, if you don’t keep your inventory and SDS library current, you won't be able to maintain your IH sampling plan. During compliance inspections, it's common for regulatory compliance officers to ask which chemicals have been added to your inventory since the last time IH sampling was conducted. If chemicals added since then have established exposure limits, and you haven't yet conducted exposure monitoring for them, you're 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're not only sampling for 8-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 of 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 8-hour TWAs. Assess your equipment and sampling needs, because you may find it necessary to purchase or rent a photoionization detector (PID) in order to capture airborne concentrations in real time and install monitors with alarms to warn workers when concentrations reach dangerous levels.

The right chemical management software can assist you in tracking this information by grouping products and chemicals into customizable categories that serve up the pertinent information to your people quickly and easily. EHS software also can help you manage your monitoring schedule.

5. Chemical Banning & 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 chemical management software can help you do 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.

You can't 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.

Picking the Right Tools
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.

As we've seen, there are quite a few nuances to doing chemical management and IH effectively, but the right tools help you meet the challenges of IH in changing times and provide a safer, healthier workplace for all.

This article originally appeared in the May 2019 issue of Occupational Health & Safety.

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