A How-to Guide for OHS Professionals
BY JESSICA B. MANN
Chemistry and its products are the building blocks of our modern world. With innovations spanning a wide range of fields, including plastics, medicines, electronics, coatings, synthetic fabrics, aerospace materials, just to name a few—chemistry has enabled tremendous gains for society and for public health. Yet, as occupational safety and health professionals, we know only too well the darker side of the story: the harmful effects of chemicals on human health and the environment. In the United States, OSHA estimates that 190,000 illnesses and 50,000 deaths occur annually from workplace chemical exposures; similarly, EU-OSHA estimates deaths in the European Union at 70,000 a year. Beneath these staggering numbers lies a heavy burden of worker pain and suffering, financial losses to families, and other costs and negative impacts to society as a whole. THE HIERARCHY OF CONTROLS Industrial hygienists, safety engineers, and allied professionals play a key role in identifying and controlling workplace exposures in the modern workplace. Our work is guided by the principles laid out in the hierarchy of controls (Figure 1), and supported by the many responsible companies that commit to ensuring worker safety. Certainly we have come a long way in our ability to manage hazardous chemicals safely. But the statistics remain troubling. Why, in spite of all the time, money, and effort, do we continue to struggle with this issue? Simply put, elimination and substitution continue to be underutilized when compared to the other control methods. And occupational safety and health professionals continue to spend the majority of their work time on activities in less-effective regions of the hierarchy. A European Commission report in 2012 expressed frustration over this development: Substitution ... is either not even identified as a potential measure to consider, or it is seen as far too complex a process.… Should substitution perhaps be described as a theoretically applauded and promoted way of reducing chemical risk, which is more seldom put into practice? No matter how carefully we design and run our programs, things inevitably go wrong: ventilation systems lose power, fan belts blow, respirators slip, gloves tear, filters overload, training classes get missed. The hierarchy of controls is called a hierarchy for a reason, and out in the real world, elimination of chemical hazards is the hands-down best way to keep workers safe. WINDS OF CHANGE IN THE WORLD OF CHEMICALS Against this backdrop, a revolution has been brewing in the worldwide business of chemicals, with many factors acting collectively to drive change. Perhaps most obvious is the ever-growing number of regional, national, and state regulatory bans and restrictions. These include EU-REACH, RoHS, WEEE, GHS, the U.S. Conflict Minerals Rule, K-REACH (South Korea’s version), upcoming actions in Japan, Taiwan, China, Canada, and a host of U.S. state regulations.
Add to this the growing strength of the safer consumer products movement. Fed up with toxics showing up in personal care and children’s products, consumer groups are successfully using the Internet and social media to demand removal of specific chemicals from products. This, in turn, has driven shifts in the retail sector: the phrase “retail regulations” was coined to describe how major retailers such as Walmart, Target, Staples, Whole Foods, and others have enacted corporate chemical policies and bans on downstream suppliers. And finally, the explosive growth of the corporate sustainability movement continues to fuel all of the above. Today, 95 percent of the world’s 250 largest companies release a sustainability report. Unthinkable even in the recent past, companies now publicly report on sensitive environmental and social issues such as carbon emissions, water use, labor conditions, and employee health and safety.
RESOURCES AIHA: Demonstrating the Business Value of Industrial Hygiene: Methods and Findings from the Value of the Industrial Hygiene Profession Study (2008). American Chemical Society Green Chemistry Institute (ACS GCI). Chemical Footprint Project (CFP). European Agency for Safety and Health at Work: “Minimizing Chemical Risk to Workers’ Health and Safety through Substitution” (2012). Green Chemistry and Commerce Council (GC3). National Academies Press: A Framework to Guide Selection of Safer Chemical Alternatives (October 2014). OSHA: “Transitioning to Safer Chemicals." UN Environmental Programme: “The Business Case for Knowing Chemicals in Products and Supply Chains” (2014). OSHA training course #7225, Transitioning to Safer Chemicals, is offered by OSHA Training Institute Education Centers at various locations. Additional training resources include video modules from the Western Sustainability and Pollution Prevention Network and the University of Washington’s certificate in green chemistry and chemical stewardship.
GREEN CHEMISTRY AND INDUSTRIAL HYGIENE Enter the new and rapidly evolving field of green chemistry, sometimes known as sustainable chemistry. Emerging in the late 1990s, this discipline has grown steadily and is increasingly being adopted by companies as an element of sustainability. Green chemistry seeks to reduce or eliminate the use or generation of hazardous substances in the design, manufacture, use, and disposal of chemical products. It places a priority on prevention and the “designing out” of hazards rather than controlling them or cleaning them up after problems occur. These goals clearly overlap with the apex of the hierarchy of controls. A number of forward-looking corporations have begun to realize the benefits of greening their portfolios. Getting ahead of the “bans and restrictions” curve is recognized as a way to not only reduce risk and liability, but also to gain competitive advantage and market share. The sustainability reports on the websites of companies such as Dell, Sigma-Aldrich, Nike, Apple, HP, Kaiser Permanente, 3M, Akzo-Nobel, and many others include corporate initiatives and goals for greener processes and products. Green chemistry represents a powerful new opportunity for advancing occupational safety and health. By integrating with green approaches and initiatives, occupational safety and health professionals can leverage the success of sustainability and green chemistry, helping to boost prevention as a practical means for protecting workers. While green chemistry is a scientific discipline practiced by chemists in the lab, it can also be viewed as any activity that seeks to reduce or eliminate hazardous substances, from the test tube to the manufacturing floor and on to the marketplace. No matter your function or job title—industrial hygienist, safety engineer, product steward, risk manager, loss control consultant, occupational health coordinator—in a very real and applied sense, occupational safety and health professionals can rightfully claim an important role in promoting green chemistry through their activities. Through a combination of training and experience, occupational safety and health professionals are well qualified to contribute to green chemistry efforts. We work routinely with safety data and technical information related to chemical hazards (for example, hazard classes, physicochemical properties, toxicology, and so on); and we understand routes of exposure and the importance of workplace exposure factors in assessing overall risk. On the soft skills side, we often have good rapport with workers (as our core “customers”), and we know how to communicate risk at all levels, from the shop floor to the executive suite. INTEGRATING GREEN CHEMISTRY “Green” means more than just the environment: it means safer for people, too, and that includes workers. Below are tips, examples, and resources for successfully integrating with green chemistry initiatives in your workplace. Tip 1: Team Up A surprising number of departments get involved with selection decisions around hazardous chemicals. These departments include research and development, industrial design, process engineering, packaging, purchasing, marketing, regulatory affairs, manufacturing, facilities operations and maintenance, and others. So Tip #1 is to seek out partnerships in new areas and look for opportunities to guide chemical use and purchasing decisions that benefit both the company and its workers. Tip 2: “Begin with the End in Mind” An often overlooked first step is to “begin with the end in mind.” Rather than jumping immediately into a search for less toxic alternatives, step back for a moment and consider the underlying need, function, or performance that must be met or achieved. Can it be done without the use of chemicals? This type of thinking can sometimes result in innovative products or process redesign. Take the case of harmful phthalate plasticizers, as described in the National Academies publication A Framework to Guide Selection of Safer Chemical Alternatives. While the traditional approach was to look for more benign plasticizers, Dow realized that customers were not really interested in plasticizer design—they just wanted a safe, flexible material for children’s toys. Dow developed a polymer solution that was inherently soft and pliable without any need for plasticizer. Another example comes from facilities management: instead of using hazardous chemicals in cooling towers to prevent biological growth and corrosion, some companies use a pulsed electric field—a technology originally developed by the food industry for pasteurization—as a chemical-free approach to water treatment.
Figure 1. The hierarchy of controls.
By integrating with green approaches and initiatives, occupational safety and health professionals can leverage the success of sustainability and green chemistry, helping to boost prevention as a practical means for protecting workers.
Tip 3: Focus on Processes Workers are involved at every step of a product’s life cycle, from scale-up through production, and on through the later post-sale stages of maintenance, recycling, and disposal. So a focus on greening of processes offers the opportunity for widespread worker safety benefits. Occupational safety and health professionals can add an often-missing perspective to design teams. The AIHA publication Demonstrating the Business Value of Industrial Hygiene includes a relevant example of a company that had recently moved into the business of manufacturing hybrid car batteries. The process was cumbersome and involved chemicals including titanium tetrachloride (TiCl4), a severe respiratory, eye, and skin irritant, which required the plant to adopt additional worker PPE and controls, and install an air pollution scrubber to protect the local community from the chlorine gas generated by the operation. Anticipating business growth for the product, the company undertook a major redesign of its production process to expand capacity. With the inclusion of industrial hygienists on the redesign team, the plant eliminated use of TiCl4 in the process and achieved its business goal of greater capacity: a true win-win. Tip 4: Analyze Alternatives The history of chemical substitution efforts is unfortunately littered with examples where the replacement turned out to be just as bad, or worse, than the original. So conducting a comprehensive alternatives analysis is a must. Happily, there are now many validated screening tools that can help identify potential safety and environmental issues early on. Due to our professional knowledge of chemical hazard information, occupational safety and health professionals are well suited to help with these efforts—just be sure to choose your analysis tool carefully, with awareness of its pros and cons, applicability, and so on. A critical point to keep in mind is that many assessment tools consider only hazard potential. With our understanding of the key role that exposure factors play in determining risk, we can help ensure that alternatives analyses are done with no regrettable substitutions. Tip 5: Educate Yourself Professionals from different disciplines may not always speak the same language, so make the effort to learn more about green chemistry’s basic principles and terms. Many educational opportunities are available, and some are listed in the “Resources” sidebar. It’s also worth looking into green chemistry- or sustainability-themed trade groups and associations (for example, ACS GCI Pharmaceutical Roundtable, Outdoor Industry Association, Green Chemistry and Commerce Council, and the Retail Industry Leadership Association) where you can access valuable industry-specific knowledge directly applicable to your company. And it should make occupational safety and health professionals happy to know that green chemists recognize a similar issue on their end, and are pursuing courses in safety hazard assessment, toxicology, and so on. Tip 6: Build the Business Case Companies pursue green chemistry initiatives for a variety of reasons, including increased sales or market share, operational efficiencies, increased employee morale, brand image, and customer loyalty. But don’t forget: as seen in the TiCl4 example, the operating cost savings associated with elimination of a hazardous chemical can be significant, and they continue to accrue year after year. So Tip #6 is to track the dollar value of direct costs saved by elimination or substitution. Collecting this information can help your management connect the dots between green initiatives, worker health, and the bottom line, and can potentially make future initiatives an easier sell. When counting, include the full range of costs and staff/employee time. These include costs for air sampling, PPE and respirator equipment, administration, and medical surveillance; employee hazard communication training; hazardous waste disposal; emergency spill planning and equipment; environmental permits and reporting; and pollution control devices. Tip 7: Set Goals and Measure Progress The old adage “you can’t manage what you don’t measure” is as true as ever, and the ability to measure hazardous chemical usage helps to drive progress. However, even as companies routinely report their environmental footprint in areas such as greenhouse gas, water use, and hazardous waste, to date there has not been a globally accepted standard metric for overall corporate chemical use. This may be about to change, however, with the 2015 release of the Chemical Footprint Project (CFP). The CFP (co-founded by the environmental nonprofit Clean Production Action, the University of Massachusetts Lowell Center for Sustainable Production, and the sustainability consultancy Pure Strategies) is designed to benchmark a company’s overall performance in chemicals management. Participation is voluntary, and free; companies answer a standard set of 20 questions to arrive at a total score. Many of the topics are familiar to occupational safety and health professionals, such as chemicals policy, inventory, alternatives analysis, and so on. If your company does not yet have a good way of tracking chemical use, it may be worth looking into CFP as a way to manage progress and visibly demonstrate your organization’s commitment to greening its products and portfolios. SAFER CHEMISTRY Green chemistry represents an important new opportunity for occupational safety and health professionals to advance worker safety and health. By maintaining a prevention mindset, developing new partnerships, and keeping a clear focus on chemical processes, we stand to play an important role in leading our organizations toward safer chemistry for all. JESSICA B. MANN, MPH, CIH, CSP, LEED-AP, is founder and CEO of Green Futures Unlimited in San Diego, Calif. She can be reached at email@example.com or (858) 761-6981.