A critical issue in global EHS is simply managing the enterprise risk of your hazardous chemical inventories. This means keeping all your people safe from potentially dangerous substances, no matter where they work.
Barriers to a good Enterprise Risk Management (ERM) program for chemical management can come from anywhere: lack of senior management buy-in, budget constrictions, insufficient departmental (and multinational) communication and cooperation, or the lack of a visionary EHS champion.
But don’t allow these roadblocks to stop you from implementing a sound global enterprise solution for chemical management. This brief article is meant to inspire you to provide better protection for your workers enterprise-wide — and to present some ammunition in your quest to sell the need to reduce enterprise risks.
Safety & health’s role
Because you are in charge of worker safety, including possibly process safety management (PSM), you’re intimately involved in any sound global ERM solution for chemical management.After all, OSHA’s process safety management standard (1910.119) requires you to “prevent or minimize†the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.
A first step in “preventing and minimizing†is simply doing physical inventories accurate enough to allow you and your corporate office to know (and oversee) exactly which of your sites are using, storing, and disposing of what chemicals. While this statement seems obvious, believe me, it isn’t.
When my company developed a new electronic tool to streamline chemical inventorying and align actual products on shelves with the companies’ material safety data sheet (MSDS) databases, some of our clients were shocked. After inventorying scores of sites for dozens of North American companies, and reconciling product-to-MSDS gaps, we found most companies were from 50 percent to 85 percent out of compliance. This means the companies had numerous (usually low-volume) chemical products for which they had no on-site or corporate-office MSDSs as required by law.
Another red flag when tying an electronic inventory to the MSDS database was EHS departments managing too many MSDSs, typically for products no longer in use. We have found that all of these situations exist in the real world with far more frequency than you would imagine.
Do you really know what your product-to-MSDS ratio is across your enterprise?
We have seen firsthand that with electronic inventory tracking tied into a searchable, global electronic database, companies can get back into compliance, and save money in the process.
Procurement buy-in
ERM for chemical management involves and benefits many of your company’s departments. Let’s look at problems and solutions from an operational view — the perspective of your regional, national, and/or international procurement people.A huge problem we’ve found across a broad range of enterprise operations and industries is this: most chemicals used at different geographic locations are present at only one location. That means these companies are not consolidating vendors optimally. Procurement usually does a great job of controlling purchases of high-volume, high-cost chemicals, perhaps even through a supply side partner. But too often, these same procurement departments allow too many facilities to P-card purchase their own low-volume, low-cost chemicals — often hundreds, or thousands, of products at each location.
The safety issue, and enterprise risk, this raises is clear. If each facility purchases whatever it wants, without a strict and controlled request-and-approval process, there may be no telling what real risks are inherent in all the products used and stockpiled across the organization. Again, with accurate inventories tied to the corporate master database, these enterprise risks can be mitigated.
Don’t forget IT
Your Information Technology (IT) department must also get involved in chemical management where language and local hazcom issues are concerned.You should be able to communicate and easily share hazmat information with your foreign facilities and workers.But language barriers are not just an issue for hazard communications in non-English-speaking countries. OSHA reports nearly one-fourth of all work-related accidents in the U.S. have a language barrier component. In large cities, such as New York and Houston, the occurrence of accidents with a language barrier factor is as high as 50 percent. While OSHA says it doesn’t require employers to make foreign language MSDSs available, this doesn’t absolve companies of liability in language-related accidents where no foreign-language MSDS exists.
If you have a provider managing your MSDS system, ask them if foreign language MSDSs can be ordered directly from the chemical manufacturer. If they can’t, your provider should be able to manage the process of having MSDSs custom translated. Your EHS software should also allow you to read computer screens and work in your enterprise’s various native languages.
Also make sure your MSDS data providers understand the variations of hazard communication and regulatory compliance between different countries. Here, a text-based database system that automatically completes the required EHS forms with all pertinent fields and symbols (yielding locally compliant versions) simplifies and increases global EHS effectiveness.
There’s much you can do to help build total chemical management processes into your global EHS system. When you’ve created and implemented a well-thought plan for reducing your enterprise risk through better chemical management, you won’t just save money, you might also be saving employees’ lives.
