While the ACC said it welcomed OSHA’s recent launch of a website making it easier to access up-to-date information on Permissible Exposure Limits (PELs) for the workplace, it feels more input is needed.
“The online tool developed by OSHA to help employers assess the relative safety of potential alternatives is too narrow,” according to a statement from the ACC. “As the site acknowledges, these assessments often involve complex tradeoffs and decisions. While there may be considerable value in ensuring broad access to an array of process safety options, ACC is particularly concerned that the tool focuses only on substitution. We strongly encourage OSHA to seek stakeholder input on approaches that could offer a more comprehensive and scientifically established approach to improve worker safety, well beyond substitution.”
Specifically, the ACC said the site should draw on the resources developed by the Center for Chemical Process Safety, Guidelines for Risk Based Process Safety and Inherently Safer Chemical Processes: A Life Cycle Approach.
“OSHA should be careful to communicate the limitations and strengths of the tool in a clear and concise manner. It is critical that alternatives assessment be a part of a comprehensive, thoughtful analysis by facility operators to ensure that ongoing efforts to protect worker safety under other regulatory programs, such as OSHA’s Process Safety Management Standard, are not undermined.”
The ACC pointed out that its member companies have reduced injury and illness rates at their facilities by 79 percent since 1990 – a rate five times lower than the U.S. manufacturing sector as a whole. The group cites an industry program called Responsible Care®, the chemical industry’s environmental, health, safety and security performance initiative, as one reason for the safety performance.