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November 04, 2013
OSHA's new chemical safety tools: A closer look
By Emily Scace, Senior Editor, Safety

On October 24, OSHA announced two new tools designed to help employers protect their workers from exposure to hazardous chemicals. While use of the tools is voluntary, OSHA strongly urges businesses to adopt these measures because many of its permissible exposure limits (PELs) are outdated and do not adequately protect workers.

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In this article, we’ll take a closer look at the first of OSHA’s new tools, an online guide titled Transitioning to Safer Chemicals: A Toolkit for Employers and Workers.

The toolkit, based around the concept of “informed substitution,” is designed to help employers eliminate or reduce hazardous chemical usage through substitution of safer alternatives, changes to work practices, and other methods. OSHA intends the toolkit to be used as a resource both for businesses looking to improve chemical safety and for workers who wish to better understand chemical use.

7-step process

At the core of the toolkit is a seven-step process for evaluating current chemical use, considering alternatives, implementing substitutions, and monitoring the outcome. For each step, OSHA provides detailed information and resources to assist employers, including searchable databases of hazardous chemicals and alternatives, case studies, and risk assessment tools.

The seven steps of the process are:

  1. Engage. At this step, employers should form a team to develop a plan for transitioning to safer chemical use. Issues to discuss include worker involvement, goals, and scope of the plan. OSHA recommends involving workers who perform a variety of functions across the organization in order to include a range of perspectives and experiences.
  2. Inventory and prioritize. After developing a plan, employers should examine their current chemical use. What chemicals currently in use could be hazardous to workers? What functions do these chemicals perform, and are the chemicals essential? After gaining a good understanding of current chemical use and hazards, employers can set priorities by considering where the most serious hazards exist and the potential for a chemical or process change to improve workplace safety and health.
  3. Identify alternatives. This step is about identifying alternatives with the potential to enhance worker safety. Employers should consider not only chemical substitutions, but changes to processes, design, technology, or materials that could lead to reduced exposure to hazardous chemicals.
  4. Assess and compare alternatives. After identifying alternatives to the chemicals in use, employers should compare those that seem most promising on dimensions like price, performance, and safety. It’s important to ensure that one chemical hazard isn’t simply being replaced with another, so employers should make sure they fully understand any hazards of potential replacement chemicals and how they compare to current hazards.
  5. Select a safer alternative. Based on the information they’ve gathered, employers can now choose a chemical or process change to adopt. Worker input during this stage can be helpful in weighing the advantages and disadvantages of various alternatives. Once a decision is made, employers should make sure to communicate it to all affected parties and develop a plan for implementation of the new method and/or chemical. When selecting a replacement chemical that comes with potential hazards of its own, those who will be exposed to it will need to be trained according to OSHA’s hazard communication standard.
  6. Test the alternative. Employers should begin by using the new process and/or chemical on a small scale in order to evaluate its performance, safety, and other key factors before making a larger commitment to the change.
  7. Implement and evaluate the alternative. Employers should create a plan to implement the new chemical or process on a larger scale and communicate it to those who will be involved, making sure to consider any necessary organizational or technological changes. Once the alternative is fully implemented, continuing evaluate its performance in the workplace is important. Does the alternative meet expectations for safety, performance, and other key factors? How do workers feel about the changes? Finally, companies shouldn’t stop evaluating their chemical use after successfully making one transition. Rather, they should keep informed about the new and constantly evolving methods, chemicals, and other innovations that can improve worker safety.

Benefits to businesses

In addition to the benefits to worker safety and health, OSHA points to several ways in which adopting safer chemical processes can benefit businesses. Reducing exposure to hazardous chemicals can save money by preventing costly work-related illnesses and injuries and the time away from work and disruptions to productivity that often occur as a result.

Furthermore, by transitioning to safer chemicals, employers reduce the risk of the very costly catastrophic events—such as toxic releases, fires, and explosions—that can occur when using certain hazardous substances.

OSHA also points to industry leadership as a benefit of making informed chemical substitutions. By engaging in the process of considering alternatives to hazardous chemical use, OSHA reasons, companies are investing in a form of innovation that can help them to remain competitive.

What’s next?

In the press call announcing the new resources, Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels commented that he views these tools as “part of a larger initiative to refocus on chemical exposures and to help employers do everything they can to reduce exposure to hazardous chemicals in the workplace.” With that in mind, employers can perhaps expect more from OSHA on chemical exposure in the near future. Currently, a proposal to reduce the PEL for crystalline silica is in the comment phase, and OSHA’s Spring 2013 Semiannual Agenda of Regulations also identified beryllium as a target of future rulemaking.

Michaels also commented that OSHA encourages employers to adopt Injury and Illness Prevention Plans, or I2P2s, as a systematic way to find and reduce hazards to employees, calling them a very effective way to address problems of chemical exposure. Although I2P2s are not currently a federal OSHA requirement, some states, notably California, do require them. Michaels emphasized that the I2P2 approach can not only save lives and reduce exposures, but can also help employers’ profitability. An I2P2 proposal was also mentioned on the Spring 2013 Semiannual Agenda of Regulations as an agency priority in the near future.

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