OSHA 3 VIII JRNL

OSH 2303, Hazardous Materials Safety 1

Course Learning Outcomes for Unit VIII Upon completion of this unit, students should be able to:

4. Summarize methods of monitoring hazardous materials program effectiveness. 4.1 Discuss the process of establishing a hazardous materials program that meets Occupational

Safety and Health Administration (OSHA) regulatory requirements. 4.2 Explain how best practices can be used to enhance a hazardous materials program. 4.3 Select methods that can be used to evaluate the effectiveness of a hazardous materials

program. Required Unit Resources Chapter 4: Hazard Communication Benchmarking and Performance Criteria, pp. 137–151 Chapter 5: Best Practices in Hazard Communication, pp. 153–191 In order to access the following resource, click the link below. Read pages 27–29 of the following resource. Occupational Safety and Health Administration. (2016). Recommended practices for safety and health

programs (OSHA Publication No. 3885). United States Department of Labor. https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf

Unit Lesson In this unit, we expand our discussion and examine the importance of finding and using best practices in pursuit of safe handling and use of hazardous materials in the workplace. Best practices are simply procedures, methods, and programs developed to not only comply with regulations but also go beyond the requirements of the regulations and provide an additional level of protection for the employees. Experienced safety practitioners understand that compliance with the Occupational Safety and Health Administration (OSHA) regulations is only the start of building effective Hazard Communication (HazCom) and Hazardous Waste Operations and Emergency Response (HAZWOPER) programs.

Best Practices Best practices are particularly important in the study of hazard communication, since many sections of the OSHA HazCom Standard are performance-based; that is, they describe the desired end state but do not necessarily explain how to get there. The reasons for this type of standard originates in the huge number of chemicals and diversity of workplaces in which they are used. A regulation could not possibly provide a single solution for everyone. Hazardous materials are much more complicated than, for example, the prescribed height of a stair railing (32–34 inches). The adoption of the Globally Harmonized System of Classification and Labeling (GHS) has made compliance with label and safety data sheet (SDS) requirements easier, but there are still areas that leave safety practitioners searching for the best route to compliance and employee understanding. For example, in-house labeling systems are still permitted, and there are numerous ways to make SDSs available.

UNIT VIII STUDY GUIDE How to Evaluate the Effectiveness of a Program, Including Benchmarking

OSH 2303, Hazardous Materials Safety 2

UNIT x STUDY GUIDE Title

Not all best practices are created equal, and some industry practices may not be best or even good. Haight (2012) offers some criteria that can be used as benchmarks:

• the practice meets the basic legal requirements set by OSHA and the Environmental Protection Agency (EPA),

• the practice goes beyond the basic requirements to include the realities of the workforce, and • the practice goes beyond the basic requirements to include everyday realities.

Where do we find best practices? Often, you will not need to look further than your own industry. Trade associations, labor unions, and professional associations are all possible sources, as well as safety-related organizations, such as the National Safety Council, American Society of Safety Engineers, and even OSHA itself. The OSHA website contains links to multiple sources of best practices that were developed through the OSHA Alliance Program. Access the list of these best practices at the "Alliance Program Participants Developed Products" web page.

Evaluate and Update Programs Regardless of what best practice is found to be the best fit, remember that it still must be tailored to your organization as well as continually evaluated and updated. Best practices can be the bridge between compliance and increased effectiveness. We certainly want our HazCom and HAZWOPER programs to meet the OSHA standards, but we also want to ensure they are making a difference. As we have seen, HazCom and HAZWOPER programs are complex, and there is no one single measure for effectiveness. It can be helpful to return to the sequential steps of HazCom program development and examine each step for its contribution to overall effectiveness. A similar process can be used to evaluate your HAZWOPER program.

Identify responsible staff: Effective programs start with effective leaders. Top management must show support for the program by providing the resources necessary for its success. These resources include a knowledgeable, motivated staff. Organizations that do not have knowledgeable in-house staff should consider hiring one or more consultants. The cost will likely be offset by the cost avoidance of not being cited and fined by regulators.

Elements of an effective hazard communication program (OSHA, 2014, p. 29)

OSH 2303, Hazardous Materials Safety 3

UNIT x STUDY GUIDE Title

Know the regulations: There are no best practices that can be substituted here. You must read and understand the applicable regulations. This may seem obvious but is often overlooked by those looking for a cookie-cutter HazCom program. Identify and list all chemicals: The operative word here is all. There are some chemicals excluded from the standard, but the exclusions should be applied after the full list is prepared. Again, there is no substitute for a knowledgeable and experienced staff. Best practices include establishing a timeline for updating the chemical inventory and establishing a review process for all chemical purchases so that new chemicals can be added as soon as they are purchased. Be sure chemicals that are no longer used are deleted from the inventory. Write the plan: OSHA has compiled best practices on written programs, which can be accessed for more detailed information on the "HazCom 1994 Program Guidance" web page. Written plans must reflect the organization’s culture and the way it does business (Haight, 2012). A compliance officer would probably notice that your written program discusses solvents used in parts cleaning processes, even though no such processes are present. Maintain good labeling on containers: The HazCom Standard requires chemical manufacturers and importers to provide labels that comply with the standard; however, employers who use chemicals must ensure that the information on the labels remains legible. In some cases, employers may be required to transfer information from a shipping container to individual containers. Third-party labeling systems may be used if the label information is consistent with the hazard definitions in the standard (OSHA, 2014). Provide quick access to SDS for all employees on all shifts: SDSs should flow downstream; chemical manufacturers and importers are required to develop the SDS information and provide a copy of the SDSs for all chemicals they sell or distribute. In general, employers who purchase these chemicals are not required to develop SDSs themselves but are required to make them available; SDSs must be requested from the manufacturer if missing. Be sure someone is designated to obtain and maintain them. How the SDSs are stored and retrieved may depend on the size of the organization and the number of chemicals used. Most organizations have gone to computer-based or web-based SDS retrieval systems. One of the keys is to keep it simple. It may be cost-effective to subscribe to an SDS retrieval service if you have large numbers of chemicals. Be sure there are no obstacles that prevent employees from obtaining the information when they need it. Train all employees on all possible chemical exposures: Since the overall goal of the HazCom Standard is to ensure all employees know and understand the hazards of all the chemicals they work with, it follows that employee training is critical to program compliance and effectiveness. Again, note the use of the word all. HazCom training may benefit most from best practices. OSHA provides best practice recommendations in its Model Training Program for Hazard Communication document as well as OSHA Publication 3695 (OSHA, 2014). Additional HazCom training information can be found on the Internet as well as with the ever-present safety consultant industry. Be sure your training considers the diversity of your workforce and the realities of your day-to-day operations. International trade, transportation of hazardous materials, potentials for terrorism, contaminated worksites, and new technologies can all affect the training needs. Frequently review and revise the program: This is perhaps one of the most important activities, but it is most often the one that is left out. All safety activities need to be a part of an active continuous improvement loop to keep up with changes in regulations, changes in the workforce, and changes in technology. Why would you take the time to develop and implement a complex program and then not examine it to see if it is effective? Leaving the program unattended on the shelf is likely one of the reasons that the HazCom Standard has been in OSHA’s top 10 list of most frequent citations for decades. A best practice would be that the written HazCom program specify the frequency of these reviews, who is to accomplish them, and how identified program deficiencies are to be resolved. OSHA’s HazCom Standard is not new, and most organizations likely have achieved some level of compliance. Unless you are creating a program where one does not exist, the review process is the place to start. Haight (2012) presents the idea that safety professionals do not just have to keep up; they must stay ahead. Researching and using best practices for HazCom and HAZWOPER is a best practice that will help achieve an effective world-class occupational safety and health program.

OSH 2303, Hazardous Materials Safety 4

UNIT x STUDY GUIDE Title

References Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of

Safety Professionals. Occupational Safety and Health Administration. (n.d.). Alliance program participants developed products.

United States Department of Labor. https://www.osha.gov/alliances/products Occupational Safety and Health Administration. (2014). Hazard communication: Small entity compliance

guide for employers that use hazardous chemicals (OSHA Document No. 3695-03). United States Department of Labor. https://www.osha.gov/Publications/OSHA3695.pdf

Suggested Unit Resources In order to access the following resources, click the links below. Learn more about the European Union’s registration, evaluation, authorization, and restrictions of chemicals (REACH) program at the webpage below. International Trade Administration. (2015). REACH (registration, evlauation, authorization and restrictions of

chemicals). http://2016.export.gov/europeanunion/reachclp/ Read more about the advantages and disadvantages of control banding on the National Institute for Occupational Safety and Health (NIOSH) website below. National Institute for Occupational Safety and Health. (n.d.). Control banding. Centers for Disease Control and

Prevention. https://www.cdc.gov/niosh/topics/ctrlbanding/ctrlbandingfaq.html Learning Activities (Nongraded) Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, contact your instructor for further guidance and information. The Occupational Safety and Health Administration (OSHA) has published a list of best practices for multiple topics through the OSHA Alliance Program webpage. Access the list of best practices, and review them. Read some of the documents for topics that you are interested in. How do the practices that are summarized in the documents relate to practices that are used at your current place of employment or somewhere you have worked in the past? How would you recommend getting management to buy into using these practices? Summarize your thoughts in a personal journal.

OSH 2303, Hazardous Materials Safety 1

Course Learning Outcomes for Unit VIII Upon completion of this unit, students should be able to:

4. Summarize methods of monitoring hazardous materials program effectiveness. 4.1 Discuss the process of establishing a hazardous materials program that meets Occupational

Safety and Health Administration (OSHA) regulatory requirements. 4.2 Explain how best practices can be used to enhance a hazardous materials program. 4.3 Select methods that can be used to evaluate the effectiveness of a hazardous materials

program. Required Unit Resources Chapter 4: Hazard Communication Benchmarking and Performance Criteria, pp. 137–151 Chapter 5: Best Practices in Hazard Communication, pp. 153–191 In order to access the following resource, click the link below. Read pages 27–29 of the following resource. Occupational Safety and Health Administration. (2016). Recommended practices for safety and health

programs (OSHA Publication No. 3885). United States Department of Labor. https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf

Unit Lesson In this unit, we expand our discussion and examine the importance of finding and using best practices in pursuit of safe handling and use of hazardous materials in the workplace. Best practices are simply procedures, methods, and programs developed to not only comply with regulations but also go beyond the requirements of the regulations and provide an additional level of protection for the employees. Experienced safety practitioners understand that compliance with the Occupational Safety and Health Administration (OSHA) regulations is only the start of building effective Hazard Communication (HazCom) and Hazardous Waste Operations and Emergency Response (HAZWOPER) programs.

Best Practices Best practices are particularly important in the study of hazard communication, since many sections of the OSHA HazCom Standard are performance-based; that is, they describe the desired end state but do not necessarily explain how to get there. The reasons for this type of standard originates in the huge number of chemicals and diversity of workplaces in which they are used. A regulation could not possibly provide a single solution for everyone. Hazardous materials are much more complicated than, for example, the prescribed height of a stair railing (32–34 inches). The adoption of the Globally Harmonized System of Classification and Labeling (GHS) has made compliance with label and safety data sheet (SDS) requirements easier, but there are still areas that leave safety practitioners searching for the best route to compliance and employee understanding. For example, in-house labeling systems are still permitted, and there are numerous ways to make SDSs available.

UNIT VIII STUDY GUIDE How to Evaluate the Effectiveness of a Program, Including Benchmarking

OSH 2303, Hazardous Materials Safety 2

UNIT x STUDY GUIDE Title

Not all best practices are created equal, and some industry practices may not be best or even good. Haight (2012) offers some criteria that can be used as benchmarks:

• the practice meets the basic legal requirements set by OSHA and the Environmental Protection Agency (EPA),

• the practice goes beyond the basic requirements to include the realities of the workforce, and • the practice goes beyond the basic requirements to include everyday realities.

Where do we find best practices? Often, you will not need to look further than your own industry. Trade associations, labor unions, and professional associations are all possible sources, as well as safety-related organizations, such as the National Safety Council, American Society of Safety Engineers, and even OSHA itself. The OSHA website contains links to multiple sources of best practices that were developed through the OSHA Alliance Program. Access the list of these best practices at the "Alliance Program Participants Developed Products" web page.

Evaluate and Update Programs Regardless of what best practice is found to be the best fit, remember that it still must be tailored to your organization as well as continually evaluated and updated. Best practices can be the bridge between compliance and increased effectiveness. We certainly want our HazCom and HAZWOPER programs to meet the OSHA standards, but we also want to ensure they are making a difference. As we have seen, HazCom and HAZWOPER programs are complex, and there is no one single measure for effectiveness. It can be helpful to return to the sequential steps of HazCom program development and examine each step for its contribution to overall effectiveness. A similar process can be used to evaluate your HAZWOPER program.

Identify responsible staff: Effective programs start with effective leaders. Top management must show support for the program by providing the resources necessary for its success. These resources include a knowledgeable, motivated staff. Organizations that do not have knowledgeable in-house staff should consider hiring one or more consultants. The cost will likely be offset by the cost avoidance of not being cited and fined by regulators.

Elements of an effective hazard communication program (OSHA, 2014, p. 29)

OSH 2303, Hazardous Materials Safety 3

UNIT x STUDY GUIDE Title

Know the regulations: There are no best practices that can be substituted here. You must read and understand the applicable regulations. This may seem obvious but is often overlooked by those looking for a cookie-cutter HazCom program. Identify and list all chemicals: The operative word here is all. There are some chemicals excluded from the standard, but the exclusions should be applied after the full list is prepared. Again, there is no substitute for a knowledgeable and experienced staff. Best practices include establishing a timeline for updating the chemical inventory and establishing a review process for all chemical purchases so that new chemicals can be added as soon as they are purchased. Be sure chemicals that are no longer used are deleted from the inventory. Write the plan: OSHA has compiled best practices on written programs, which can be accessed for more detailed information on the "HazCom 1994 Program Guidance" web page. Written plans must reflect the organization’s culture and the way it does business (Haight, 2012). A compliance officer would probably notice that your written program discusses solvents used in parts cleaning processes, even though no such processes are present. Maintain good labeling on containers: The HazCom Standard requires chemical manufacturers and importers to provide labels that comply with the standard; however, employers who use chemicals must ensure that the information on the labels remains legible. In some cases, employers may be required to transfer information from a shipping container to individual containers. Third-party labeling systems may be used if the label information is consistent with the hazard definitions in the standard (OSHA, 2014). Provide quick access to SDS for all employees on all shifts: SDSs should flow downstream; chemical manufacturers and importers are required to develop the SDS information and provide a copy of the SDSs for all chemicals they sell or distribute. In general, employers who purchase these chemicals are not required to develop SDSs themselves but are required to make them available; SDSs must be requested from the manufacturer if missing. Be sure someone is designated to obtain and maintain them. How the SDSs are stored and retrieved may depend on the size of the organization and the number of chemicals used. Most organizations have gone to computer-based or web-based SDS retrieval systems. One of the keys is to keep it simple. It may be cost-effective to subscribe to an SDS retrieval service if you have large numbers of chemicals. Be sure there are no obstacles that prevent employees from obtaining the information when they need it. Train all employees on all possible chemical exposures: Since the overall goal of the HazCom Standard is to ensure all employees know and understand the hazards of all the chemicals they work with, it follows that employee training is critical to program compliance and effectiveness. Again, note the use of the word all. HazCom training may benefit most from best practices. OSHA provides best practice recommendations in its Model Training Program for Hazard Communication document as well as OSHA Publication 3695 (OSHA, 2014). Additional HazCom training information can be found on the Internet as well as with the ever-present safety consultant industry. Be sure your training considers the diversity of your workforce and the realities of your day-to-day operations. International trade, transportation of hazardous materials, potentials for terrorism, contaminated worksites, and new technologies can all affect the training needs. Frequently review and revise the program: This is perhaps one of the most important activities, but it is most often the one that is left out. All safety activities need to be a part of an active continuous improvement loop to keep up with changes in regulations, changes in the workforce, and changes in technology. Why would you take the time to develop and implement a complex program and then not examine it to see if it is effective? Leaving the program unattended on the shelf is likely one of the reasons that the HazCom Standard has been in OSHA’s top 10 list of most frequent citations for decades. A best practice would be that the written HazCom program specify the frequency of these reviews, who is to accomplish them, and how identified program deficiencies are to be resolved. OSHA’s HazCom Standard is not new, and most organizations likely have achieved some level of compliance. Unless you are creating a program where one does not exist, the review process is the place to start. Haight (2012) presents the idea that safety professionals do not just have to keep up; they must stay ahead. Researching and using best practices for HazCom and HAZWOPER is a best practice that will help achieve an effective world-class occupational safety and health program.

OSH 2303, Hazardous Materials Safety 4

UNIT x STUDY GUIDE Title

References Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of

Safety Professionals. Occupational Safety and Health Administration. (n.d.). Alliance program participants developed products.

United States Department of Labor. https://www.osha.gov/alliances/products Occupational Safety and Health Administration. (2014). Hazard communication: Small entity compliance

guide for employers that use hazardous chemicals (OSHA Document No. 3695-03). United States Department of Labor. https://www.osha.gov/Publications/OSHA3695.pdf

Suggested Unit Resources In order to access the following resources, click the links below. Learn more about the European Union’s registration, evaluation, authorization, and restrictions of chemicals (REACH) program at the webpage below. International Trade Administration. (2015). REACH (registration, evlauation, authorization and restrictions of

chemicals). http://2016.export.gov/europeanunion/reachclp/ Read more about the advantages and disadvantages of control banding on the National Institute for Occupational Safety and Health (NIOSH) website below. National Institute for Occupational Safety and Health. (n.d.). Control banding. Centers for Disease Control and

Prevention. https://www.cdc.gov/niosh/topics/ctrlbanding/ctrlbandingfaq.html Learning Activities (Nongraded) Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, contact your instructor for further guidance and information. The Occupational Safety and Health Administration (OSHA) has published a list of best practices for multiple topics through the OSHA Alliance Program webpage. Access the list of best practices, and review them. Read some of the documents for topics that you are interested in. How do the practices that are summarized in the documents relate to practices that are used at your current place of employment or somewhere you have worked in the past? How would you recommend getting management to buy into using these practices? Summarize your thoughts in a personal journal.