We know that the most efficient and effective way to protect workers from hazardous chemicals is by eliminating or replacing those chemicals with safer alternatives whenever possible.
This statement from Dr. David Michaels, assistant secretary of labor for occupational safety and health is from an OSHA news release announcing two new tools available to protect workers from exposure to hazardous chemicals in the workplace. One of these new tools: the Annotated Permissible Exposure Limits, or annotated PEL tables will not be discussed here. The purpose of this article is to make known a handy tool that can be of assistance to you in transitioning from hazardous to non-hazardous chemicals in the workplace.
Surprisingly, only a small number of potentially hazardous chemicals in the workplace are regulated. Worker exposure to these chemicals within the US results in 190,000 illnesses and 50,000 deaths annually (according to OSHA’s website). One way to reduce the prevalence of these illnesses and fatalities is to switch to safer, and non-hazardous alternatives. Besides a safer workplace, other benefits include:
- Cost savings
- Industry leadership
- Corporate stewardship
And I will add to that two more very important potential benefits:
- Reduction of hazardous waste generation.
- Reduction in the receipt and off-site shipment of hazardous materials.
While in no way minimizing the importance of the first four bullet points, and of course keeping worker safety as the primary objective, it is important to remember the benefits in cost, reduced regulatory burden, and long-term liability that can result from the transfer from the use of a hazardous chemical to a non-hazardous.
Company A uses a flammable solvent (Acetone) for a parts cleaning operation. The receipt of this chemical at Company A and its off-site shipment as a hazardous waste is subject to the Hazardous Material Regulations of the PHMSA/USDOT; which will require use of a shipping paper, recordkeeping, and training of HazMat Employees.
When spent, the Acetone is a hazardous waste subject to the regulations of the USEPA and/or a state if it has an authorized hazardous waste program. Company A will have a ‘Cradle-to-Grave’ responsibility for the management of that hazardous waste. By transitioning to a non-hazardous alternative, Company A may avoid the regulatory requirements of both the PHMSA/USDOT and the USEPA or authorized state.
To help you in this endeavor, OSHA created the Toolkit for Transitioning to Safer Chemicals. The steps to achieving this goal include:
Step 1 Engage – Form a team to develop and plan
Step 2 Inventory & Prioritize – Examine current chemical use
Step 3 Identify – Identify alternatives
Step 4 Assess & Compare – Assess and compare alternatives
Step 5 Select – Select a safer alternative
Step 6 Test – Pilot the alternative
Step 7 Evaluate – Implement and evaluate the alternative
It is important to note that this toolkit is not a standard or regulation. It creates no new regulatory obligation for a facility. Rather, it is a tool available to regulated industry for its own use in reducing the hazardous chemicals used at its facility. Please contact me if you have any questions about the transportation of hazardous materials or the management of hazardous waste.