The risk of chemical exposure is a part of daily life, both at home and at work. But even though we encounter chemicals all day, we should still be intentional about managing chemical hazards.
Employers have an obligation to communicate chemical exposure risks and health hazards to employees. However, the obligation doesn’t end with hazard communication. You also need to manage chemical hazards through robust chemical safety programs.
In this follow-up to our overview of chemicals and hazardous substances, we’ll talk you through how you can strengthen the management of chemicals in your workplace to go beyond simply measuring permissible exposure limits (PELS).
- Begin or Revisit Your Program with a Chemical Risk Assessment
- Use the Hierarchy of Controls to Manage Chemicals and Toxic Substances
Complete a Chemical Risk Assessment
A chemical risk assessment is the first piece of the chemical management puzzle. The purpose of the risk assessment is to limit worker exposure by:
- Identifying occupational risks by completing a thorough evaluation of the components
- Providing information to workers and meeting the OSHA Hazard Communication standard requirements
- Deciding whether to eliminate or manage each risk
Tip: The Hazard Communication Standard, 29 CFR 1910.1200, requires employers to keep a complete list of hazardous products and chemicals used in the workplace to share with employees, so you should already have a list to start with. However, you’ll need to update it regularly.
A chemical risk assessment can have as few as four components:
- Identify the types of chemical hazards at your workplace (corrosives, solvents, irritants, asphyxiants, reactive, carcinogens, sensitizers, pesticides, etc.)
- Measure the extent of the exposure (against the permissible exposure levels (PELs) if available)
- Assign hazard characterization
- Name the safety and health effects associated with exposure to the chemical
There’s good news: you will get the information you need from your Safety Data Sheets (SDS), formerly known as Material Safety Data Sheets (MSDS). These are provided by the chemical manufacturer, and your organization must keep them available for workers.
For many companies, completing your risk assessment begins with taking your SDS collection, extracting the right information from it, and organizing it in a way that makes sense. You can do this manually by sorting through the SDS for every chemical, or by using chemical safety software. However, as we mentioned in our last post, we don’t recommend relying solely on SDS data. You can compare data with the NIOSH Pocket Guide to Chemical Hazards (NPG), which is available online, via PDF, or on a phone app.
Looking for a sample? The Health and Safety Executive in the UK offers free example chemical risk assessments on its website.
More free chemical management resources:
Use the Hierarchy of Controls to Manage Chemicals and Toxic Substances
OSHA recommends selecting controls that follow a hierarchy that puts engineering controls at the top and PPE at the bottom. Best known as the hierarchy of controls, this method of protecting workers developed by the National Institute for Occupational Safety and Health puts emphasis on the most effective controls, which means physically removing the hazard wherever feasible.
Because chemical management is complex and there are often no safe exposure limits to many chemicals over the long term, using the hierarchy of controls for chemical management will yield the greatest protection for your workers against health risks.
Elimination
It’s the responsibility of employers to eliminate hazardous chemicals that aren’t a requirement for work. Elimination sits at the top of the hierarchy of controls because by eliminating the hazard, you eliminate the risk of injury or illness from exposure. No other step is as effective.
Elimination is a worthwhile cause, but it’s important to remember that the process is rarely as simple as deciding not to use a chemical or material anymore. You’ll likely need to phase them out.
To identify toxic chemicals for elimination, you’ll use your risk assessment to identify the most high-risk chemicals first and ask, what do we use this chemical for? You will likely find that you need to alter a process or even a product to eliminate a chemical, and this can take time.
Plus, you’ll need to inform customers, suppliers, and any sub-contractors of your change before it goes into effect, giving them lead time to adjust their own processes.
Elimination vs. Substitution
When a chemical can’t be eliminated because it serves a vital function but still exceeds your preferred risk threshold, you can consider substitution.
Substitution replaces one hazardous material with another less hazardous chemical, or at least one where the risks associated are lower.
Here’s an easy example of substitution:
In your home, you likely switched out lead-based paints for non-leaded paints. Non-leaded pigments are safer than lead-based paint, which made for a good substition. However, you still take appropriate precautions when using and storing paint because non-leaded paints still have a risk of harmful effects.
Remember: you must be careful and ensure you don’t swap one high-risk hazard for another high-risk hazard with lesser-known effects.
Implementing a change? Run Safesite’s free Change Risk Assessment template to understand the potential impact of swapping out hazardous chemicals or toxic substances.
Engineering Controls
Once you eliminate and substitute chemicals where possible, it’s then time to dive deeper into your available controls to protect workers, visitors, and the local community by mitigating the risk of exposure.
Some examples of engineering controls for managing chemical hazards include:
- Installing the correct general ventilation and local exhaust ventilation
- Enclosing processes to limit the area of exposure to a room or building
- Automating processes to remove operator exposure
- Eliminating sources of ignition from the area
- Building a chemical storage system based on your inventory’s storage requirements
Administrative Controls
By the time you reach the administrative section of the hierarchy of controls, your risk management program should have reduced the likelihood of exceeding PELs for your hazardous chemicals.
If risks remain, you can then use administrative controls to further reduce the risk. These are always supplementary measures; they don’t serve as the first line of defense. They mitigate the impact if other controls fail.
Examples of administrative controls for managing chemical hazards include:
- Creating a written chemical safety program that contains handling procedures, training requirements, etc.
- Reducing your chemical inventory to store only the quantities needed at the time and ensuring timely disposal of spent hazardous chemicals
- Correctly marketing and labeling all containers with the chemical name, manufacturer’s name and contact info, and potential hazards associated
- Meeting (and ideally exceeding) the minimum OSHA chemical training requirements (including all hazards in an area, methods for detecting hazardous chemicals, how to use PPE, explanation of hazard communication
- Reducing the number of employees on-site to be exposed to chemicals
Personal Protective Equipment (PPE)
Personal protective equipment offers final, front-line protection to workers who cannot avoid hazardous chemical exposures.
It sits last in the hierarchy of controls because whatever the hazard, PPE only effectively manages risk when it is used correctly and when workers are trained to use the PPE to handle the chemical.
Teams typically need the following PPE for handling chemical substances:
- Overalls and aprons
- Gloves
- Chemical resistant glasses
- Respiratory protection, including properly-fitted respirators
Dive deeper into Safesite PPE resources>
The PPE must match the chemical hazard, and the SDS will include the minimum PPE required for handling. As always, you must inspect all PPE before and after use and treat PPE in the event of an incident.
For example, if a worker spills flammable liquids on their gloves or apron, then you must dispose of that PPE appropriately. That PPE is not only a hazard to the worker, but the flammable substance left behind can create a fire hazard in the disposal area.
Get Started with Hazardous Chemical Management
Hazardous chemicals and substances are one of the most complex risks to manage on any jobsite. However, it is possible to protect workers from exposure, and many of the tools you need to go beyond chemical management compliance should already exist, including your chemical inventory and your SDS library.
Digital tools simplify the chemical management process. Using a digital version of your inventory and SDS library will help you stay on top of what’s happening on the ground. And tools like Safesite can help you better manage your inspection and observation processes that serve as the administrative controls.
Are you ready to strengthen your chemical management program? Get started with Safesite to access your digital safety template library from anywhere and save time on every inspection, checklist, and audit.
