To maintain pace with best practices, you need to get your workplace chemical management program well beyond OSHA compliance within approximately the next 24 months. The target date for having really good program is June 2015, maybe slightly beyond. There may be a lot to accomplish and the target date is not that far off – the sooner you start, the better.
Table I-III summarizes chemical management activities and timelines by key U.S. stakeholders.
On the surface, the big push by U.S. stakeholders to better manage chemicals is done because it is the righteous thing to do. Reality for action is because the U.S. is getting its butt kicked by Europe. Europe opened the tap on new chemical risk information. The U.S. can’t stop the flood of information – they can only prepare for it.
Did you notice the asterisk in Table I? The asterisk comes from OSHA but probably not from the Effective Dates table you showed your boss and employees. Check out the Effective Dates table in OSHA’s HCS Frequently Asked Questions section under the Q: “What is the phase-in period in the revised HCS?” Note: *This date coincides with the EU implementation date for classification of mixtures.
It is a little asterisk but also a big deal. The “mixture rule” deadline required by EU’s Classification, Labelling, and Packaging (CLP) regulation, which went into force in January 2009, impacts your chemical management activity here in the U.S.
Do you know why?
Smart stakeholders know. That’s why timelines for action in the tables above are being pushed.
Table II – Walmart
What Walmart does or does not do bears watching. In 2013 Walmart led the business world in revenue ($248 billion USD) and number of employees (2,200,000). The purchase power of the company’s 8,500 stores worldwide has immense impact on the chemical value chain. Walmart’s Policy on Sustainable Chemistry, announced September 12, 2013, sets the stage for hazard avoidance for “high priority chemicals.” High priority chemicals are almost entirely carcinogenic, mutagenic or toxic to reproduction (CMRs). Walmart understands, thanks to the EU, that customers now have growing and ready access to chemical risk information. Power-to-the-people influences purchases.
Walmart is not alone in measuring, preparing, and responding to customer sentiment on chemicals. Dig deeper into what’s going on and you’ll find it is mostly about the health of kids. If a chemical can harm a kid, get it out of the product. For example, by mid-2014 you won’t be able to find the traditional yellow in Kraft Foods macaroni marketed to kids such as in SpongeBob varieties. Kraft is taking out the artificial dyes and replacing with colored natural spices such as paprika. Adults still get to eat the chemical dyed macaroni.
Table II – American Chemistry Council
No one cares more about how chemicals are viewed and managed than the American Chemistry Council (ACC). The ACC represents about 175 mostly large to mid-sized companies that create nearly 800,000 direct and six million indirect jobs, and have a collective revenue of about $770 billion USD. In 2013 the ACC launched the Responsible Care® Product Safety Code. The code requires ACC members to implement 11 management practices for the safety of chemical products. Code compliance will be verified by third-party certification to ISO 14001 and other ACC objectives. A summary of ACC’s Product Safety Code objectives are found at http://responsiblecare.americanchemistry.com/Responsible-Care-Program-Elements/Consumer-Fact-Sheet.pdf.
Transition to safer chemicals
The major players that manufacture or use chemicals in the U.S. are quickly transitioning to safer use of chemicals, or perception of safer use of chemicals, for a variety of reasons. The approximately five million workplaces subject to OSHA’s HCS standard would be wise to follow a similar path.
In October 2013, OSHA released its seven step process, shown below, on how to transition to safer chemicals. Each step provides guidance and links to resources; with many resources coming directly from the EU or developed from EU concepts.
The transition to safer chemicals is mostly about conformance to voluntary organizational objectives. Each organization will set their own objectives and activities. Usually, I advise my clients to focus on seven key activities:
1) Identify and create a list of all CMRs.
2) Determine by qualitative or quantitative means employee exposure to all CMRs.
3) Use TLVs®, MAKs, and DNELs to evaluate exposure risk.
4) Reduce exposure risk to CMRs; particularly the right half of the R.
5) Inform employees of exposure risk to CMRs.
6) Eliminate management silos between occupational health and public health risks.
7) Implement a safety management system to assure conformance with objectives.
Convince yourself, persuade management
Management of chemicals is no longer business as usual and GHS is not the main reason why. You should dig a little deeper to find out why this is so. Going through OSHA’s safer chemicals information should yield new insight. The timelines in the tables should present some urgency for change.