Upping Your Industrial Hygiene and Chemical Management Game
Industrial hygiene is crucial for controlling chemical hazards by enacting deliberate and systematic protective measures.
OSHA's Hazard Communication Standard (HCS) is designed to protect against chemical-related workplace injuries and illnesses by ensuring employers and employees have the necessary information to anticipate, recognize, evaluate and control chemical hazards. Industrial hygiene (IH) is the art and science of controlling those hazards by enacting deliberate and systematic protective measures.
While the discipline of IH covers a wide range of activities that extend beyond hazardous chemicals to protect the health and safety of employees, we are going to focus narrowly on IH as relates to the hazards of chemicals. It’s through this lens that we see the important relationship between IH and chemical management.
For IH activities to be effective, the hazard information upon which they are based must be complete and accurate. In other words, a strong IH program relies on a strong program of chemical management. The challenge today, in both IH and chemical management, is how to manage the flow and updating of information so the right people have the right information at the right time to take the necessary precautions and perform the right tasks. Under the HCS, a large volume of hazard information is primarily communicated to people through safety data sheets (SDSs), chemical container labels and training. However, the IH tasks necessitated by that information are increasingly being handled by EHS professionals who lack experience in IH.
Luckily, this shifting landscape is occurring at the same time EHS software is providing more efficient methods for managing and accessing workplace hazards. These solutions help simplify complex chemical inventory management tasks, provide visibility and control over chemical hazards throughout the organization, and even offer easy-to-follow guidance on performing IH tasks according to industry standards and best practices.
Let’s take a closer look how software can help strengthen your IH and chemical management programs by streamlining and improving key tasks.
Chemical Inventory & Ingredients Tracking
An accurate chemical inventory is foundational to ensuring you have all the necessary SDSs for the chemicals in your inventory, managing your workplace labels, and training your employees on chemical hazards. What’s equally important, though, is having visibility into the ingredients of those chemical products, and their specific hazards and regulatory considerations.
A good example is methyl methacrylate (MMA), a common ingredient found in many commercially sold floor coatings. MMA is a flammable liquid that presents several exposure concerns, posing potential risks to the eyes, skin and respiratory system. It has an OSHA Permissible Exposure Limit, or PEL, of 100 parts per million (ppm) and an Immediately Dangerous to Life and Health (IDLH) value of 1,000 ppm. Facility managers are often unaware that it’s present in their facilities since the names of the coating products don't provide any obvious clues. Without knowing its presence, it’s unlikely you’re including exposure monitoring for it in your IH program. This not only leaves you out of compliance with OSHA’s air contaminant requirements in CFR 1910.1000, but it places your workers at a significant risk.
Chemical management software can help you avoid this issue by allowing you to easily track all your chemical containers at a company-, facility-, department- and storage-location level. Companies benefit most from software that provides a clear line of sight into their entire chemical footprint with simple-to-use drag-and-drop controls, which enable them to quickly identify and move their chemical inventory on an image map of their facility.
Most of today’s chemical management software solutions offer ingredient indexing tools—and/or ingredient indexing services—to make tracking chemical ingredients across your entire product inventory easier and more accurate to manage. Some of the leading systems use sophisticated, regulatory, cross-referencing technology to automatically flag chemical products or hazardous ingredients that reach threshold limits according a wide variety of regulatory standards. These solutions can provide even more value by eliminating time consuming processes by integrating with a built-in chemical and Occupational Exposure Limit (OEL) database, a vital tool for setting up and maintaining an effective IH sampling program.
Maintaining Labels and SDSs
Under the HCS, employees are required to have access to chemical hazard information, and an easy way to create labels and track chemical containers. Here again, software can help you meet this requirement by providing workers with quick and easy electronic access to SDSs and an efficient way to quickly create compliant secondary workplace labels.
OSHA requires that SDSs for all hazardous chemicals in the workplace be made accessible to employees during work shifts. This has traditionally been accomplished by managing physical copies of SDSs in three-ring binders, but the more modern deployment of online software systems that electronically manages these documents has proven to be more efficient and cost effective over traditional paper-based spreadsheets and filing systems. Today, most software vendors store SDSs in a secure, cloud-based library—making them readily accessible to workers. The most highly utilized systems provide an online database of indexed, manufacturer-original documents versus rekeyed SDS documents for better accuracy and compliance assurance. Some even have on-staff certified authoring professionals that help you track down and obtain newly updated or missing SDSs and ensure they comply with all local, national and international guidelines.
Another significant benefit of chemical management software is the ability to create GHS-aligned labels that correspond with the information found on SDSs. Advanced systems use information indexed on the SDS to “replicate” the chemical's shipped label for most container sizes. A gold-standard solution can even create customized labels to fit the needs of your people and unique work environment, including labels with product identifiers and select GHS elements for very small containers like test tubes and vials.
Chemical Banning and Approval
Full transparency is key with any effective chemical management program. In addition to offering robust chemical container tracking and mapping tools, it’s important to look for a system that helps you manage the process of requesting, authoring and purchasing chemicals based on predefined roles and regulatory requirements. With a more proactive approach to the chemical introduction process, software provides better control over what chemicals are accepted or banned from your facilities for improved transparency into your chemical inventory.
Here again, good software helps you create approval forms and workflows that can be sent to authorized personnel for review and sign-off before a chemical enters your facility. You can also configure the software to alert key stakeholders or staff when a product has been banned from the premises to further control the materials allowed on site.
When an emergency occurs, there’s little time to react, making it critical to have an accurate and robust emergency plan in place ahead of time. Effective emergency planning requires communication on several levels, most importantly between your company and local emergency responders.
While robust chemical management software streamlines chemical inventory and SDS access, some vendors have taken it a step further by giving you tools to easily provide first responders with seamless access to all your SDSs, indexed product summaries, facility floor plans, chemical container maps, and chemical inventory lists available in your system. With this information in hand ahead of time, first responders can more appropriately plan for incidents and are not left in the dark on critical chemical hazards when trying to address rising emergency concerns.
When evaluating complete solutions, look for chemical management software vendors that also provide value-added emergency response services like on-the-spot chemical exposure support for chemical emergencies. These services help ensure your employees always have the critical safety information they need, and they can assist in finding qualified remediation contractors and help with completing required incident reports.
Employee training also plays a critical role in an effective and compliant IH program, and it is another area where chemical management software is invaluable.
OSHA’s HazCom Standard requires employers to train employees on key information contained within SDSs—including health and physical hazards, storage and disposal requirements and emergency response information—prior to them working with any hazardous chemicals. Software can make the management and deployment of this training easier by enabling you to share details of your IH sampling program with workers and provide specific training on your chemical hazards and exposure assessments. We recommend chemical management solutions that also offer engaging training content and helpful tools to schedule trainings and document training completion. Most of these software products have built-in email notification features that remind employees and managers when training deadlines and certification dates are coming up or are past due. Centralized systems for accessing and storing training tracking metrics keep your information up-to-date, and make it accessible anywhere in the organization.
Forming Similar Exposure Groups
Assessing exposures and identifying hazards for each individual employee is a rigorous and costly process. Best practices today suggest grouping employees who likely have similar exposures based on job tasks, frequency and duration of exposure, and similar use of controls into Similar Exposure Groups (SEGs) to avoid having to assess every individual employee within your organization Data from a small sample of workers can be used to predict the exposure of the whole group, saving you significant time and staff resources. From there, you can then determine which SEGs require medical surveillance, qualitative exposure assessments, and additional air sampling.
A critical step when forming SEGs is defining the list of potential stressors they could be potentially exposed to. Here again, a good chemical management in a broader EHS software solution with a robust IH product helps you create and manage SEGs and synchronize them across your organization. IH software features also help you manage your SEGs by including personnel histories and using data from the SEGs to auto-populate other IH functions, like providing key information to your medical surveillance and IH sampling programs—all of which save you significant time versus the traditional spreadsheet approach.
You can't be everywhere at once and—as previously mentioned—the need for IH has increased while the people and resources necessary to manage it have become scarcer. Utilizing the new breed of chemical management and broader EHS software to work for you means that you can share the responsibility for IH compliance tasks and best practices across your organization. Workflows and chemical banning allow you to extend your reach, even when you’re not there in person.
Whether you’re a veteran industrial hygienist trying to determine where best to deploy your resources and demonstrate the value of IH when talking with management, or an EHS professional who inherited an IH program in need of quick improvements, today’s well-designed software can help you succeed. The right software can improve and streamline all aspects of your program to 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 1, 2020 issue of Occupational Health & Safety.