The modern workforce has become much more cognizant of the immediate and long-term health effects of exposure to dangerous chemicals on the job. However, hazardous materials are still in daily use despite our knowledge of the risks they present to workers. Many of these chemicals can be replaced by safer alternatives that would reduce or eliminate the potential for a safety incident to occur. Therefore, OSHA has published a toolkit guide for employers to transition to the use of safer chemicals at their worksites. The steps in evaluating and implementing alternatives for chemicals currently used by your organization are as follows:
Step 1: Form a team to develop a plan
To begin the process of systematic change in chemical use at your organization, you must form an internal team to create a work plan. This team should include employees who perform different functions and vary in their exposures to dangerous chemicals at the worksite. You may also want to identify any external stakeholders who should be involved in the planning process.
Once you have formed your team, it is critical that you establish goals for the changes you desire. Goals can be long-term, industry-specific, or chemical-specific, and should focus on policies regarding the management and use of chemicals in the workplace. Your goals will then inform your work plan, which should include information such as the hazardous chemical in question, the reduction goal (often in %), the action steps needed to achieve the goal, a timeline, and the alternative assessment tool used to evaluate chemicals, such as GreenScreen.
Step 2: Examine your current chemical use
Take a current inventory of the chemicals used at your worksite, including information about how the chemical is made, handled, stored, disposed, and transported, as well as the function the chemical performs, its physical form, and the amount, frequency, and duration of use. For each chemical, identify its associated hazards and whether it is actually necessary to use in your daily operations.
Step 3: Identify alternatives
When examining a particular chemical for substitution, you should broadly consider all possible chemical alternatives, material alternatives, process changes, design changes, technological solutions, or other options to eliminate the hazardous chemical, even if some options are currently not practical. Alternatives can be found in industry-specific information and case examples about what is currently being used in the market, and you can reach out to other companies that use alternatives, as well as suppliers, professional associations, and governmental agencies, for further information. In addition, a variety of resources are available to research alternatives to hazardous chemicals, such as the Substitution Support Portal.
Step 4: Assess and compare alternatives
Before performing any comparisons, prioritize the most promising alternatives to use your limited resources for evaluation. In comparing alternatives, three main criteria should be considered:
Assess the potential hazards of each alternative, including acute health, chronic health, safety, and use hazards. Also consider whether alternatives will significantly change working conditions, which could reveal any additional hazards the alternatives may present to employees.
Assess the performance of each alternative, including the physical properties and performance characteristics (e.g., durability, maintenance requirements) of each alternative.
Assess the cost of each alternative, including direct, indirect, and liability costs, as well as less tangible benefits (e.g., reduced health maintenance costs due to a safer work environment).
Step 5: Select a safer alternative
Weigh the pros and cons of each alternative using the comparison criteria above, identify any trade-offs that may exist, and organize the data in tables/spreadsheets to help facilitate the decision-making process. You may even develop a scoring system that weighs the criteria, but be sure that the selection of a preferred alternative should be directly linked to the goals of your organization and work plan. It is important to gather input from workers who will be most affected by these changes and discuss the practicalities of implementing an alternative.
Once you have selected an alternative, be sure to communicate this decision to all relevant parties, particularly those workers who will use/handle the alternative chemical or new process. Document all steps in the decision-making process, and train employees to use the alternative as necessary.
Step 6: Pilot the alternative
Before completely shifting to a safer alternative, apply the change on a smaller scale to test its effectiveness. You may need to conduct a field test to ensure that the alternative meets your performance and product quality requirements, as well as identify any unforeseen changes in process, exposures, and new risks that may arise due to the alternative.
Pilot testing also allows for an evaluation of the three criteria to confirm that the alternative is effective and improves conditions at the worksite. Employees who will be most impacted by the change should be used for this pilot testing so that they can provide feedback about the alternative and become comfortable using it. Documentation for this step should include a job hazard analysis.
Step 7: Implement and evaluate the alternative
Once you have successfully pilot tested the alternative, plan the technological and organizational changes needed to carry out substitution at full capacity. This includes developing a plan for implementation, documenting the plan, identifying employees who should be involved in implementation, communicating the plan to all employees, and conducting necessary training. Monitor the process as implementation takes place, including tracking impacts on worker safety, performance, hazards/benefits, and changes in productivity and sales.
Judiciously following these steps will guide you to improving safety at your worksite through the use of safer chemicals and processes. I strongly encourage anyone reading this post whose employees work with hazardous chemicals to consider making these changes where possible.