The field of industrial hygiene (IH)—the deliberate and scientific control of occupational hazards and risks—is at a crossroads. With more chemicals hitting the workplace every day, the need to assess and manage workplace hazards is greater than ever, and yet the corporate investment support for traditional IH programs has steadily declined. As a result, IH responsibilities are being subsumed by technicians and EHS generalists, outsourced to costly consultants, or even left unfulfilled entirely.
The EHS industry is changing in response to these challenges, most notably with the growth of EHS software solutions aimed at empowering employees at all levels to make workplaces healthier, more productive environments. By cutting through the time and complexity of the most important IH tasks, software makes it possible to maintain a world-class program and have real-time visibility and reporting of important activities.
Following is a look at the top ways software can help strengthen your IH program, improve chemical management, and protect the safety of your workforce.
TRACKING CHEMICAL INVENTORY AND INGREDIENTS
Everything starts with knowing what chemicals you have in the workplace. It’s the key to drafting an accurate written hazard communication (HazCom) plan, ensuring you have all necessary safety data sheets (SDSs) for the chemicals in your inventory, effectively managing workplace labels, training your employees on chemical hazards, and meeting regulatory responsibilities.
Yet just knowing what chemical products you have isn’t enough. You also need visibility into the ingredients of those products, as well as their specific hazards and regulatory considerations. Take for instance methylene chloride, a common ingredient in aerosol degreasing sprays and paint-removing solvents that often goes unnoticed by facility managers because the names of the products don’t provide obvious clues. If you don’t know methylene chloride is present in your facility, it’s unlikely that your IH program includes exposure monitoring for it, which means you’re out of compliance with OSHA’s methylene chloride standard.
A good chemical management software solution can help you avoid this issue by tracking chemical containers at the company, facility, department and even storage level. Software systems can provide visual insight into your chemical footprint with drag-and-drop controls that allow you to instantly identify, move and manage your chemical inventory on an image map of your facility. And some solutions feature ingredient indexing to help you track chemical ingredients across products, while flagging those that are subject to more stringent regulatory standards. When you’re evaluating different chemical management software options, look for a solution with a built-in chemical and Occupational Exposure Limit (OEL) database, as this information is vital for setting up and maintaining an IH sampling program.
Chemical management software can also help by providing access to SDSs and streamline the creation of workplace labels. Advanced systems use information indexed on the SDS to “replicate” the chemical’s shipped label for most container sizes, and ensure all HazCom information on that label is communicated to workers. Some solutions even create customized labels to fit the needs of your people and unique work environment, including labels for very small containers like test tubes and vials with select GHS elements.
FORMING SIMILAR EXPOSURE GROUPS
Assessing exposures for each individual employee can be time-intensive and expensive. Instead, a good practice is to group employees who likely have similar exposures based on their location, job, or tasks into similar exposure groups (SEGs). Once defined, you can then determine which SEGs require medical surveillance, qualitative exposure assessments and additional air sampling.
Some advanced software programs simplify this process by helping to identify SEGs and performing qualitative exposure assessments to meet your unique IH program needs. They also make it easier to keep historical tracking of each employee’s inclusion in an SEG in order to document exposure histories that support medical and legal inquiries.
CREATING AND MAINTAINING YOUR IH SAMPLING PLAN
Having a complete and current chemical inventory list with exposure assessments is a prerequisite to putting together your sampling plan, and is important to inspectors as well. During compliance inspections, it’s common for regulatory compliance officers to ask which chemicals have been recently added to your inventory and whether an exposure assessment has been conducted. While qualitative assessments can reduce the number of samples, they are still needed to document the actual exposure potential and show compliance with the regulations.
As new chemicals arrive, carefully review information in their SDSs to identify all ingredients that may pose exposure hazards and include all relevant occupational exposure limits (OELs) in your IH plan. Make sure you not only consider sampling for 8-hour time-weighted average exposures, but also for shorter-term exposure guidelines such as short-term exposure limit (STEL) and immediately dangerous to life and health (IDLH) concentrations.
How you incorporate this information into your IH sampling plan will depend on your operations. Most begin full-shift exposures assessed against the 8-hour OELs. Later, you can assess tasks with periodic aspects to them, like cleaning out a tank or adding chemical ingredients to a mixture when concentrations can temporarily spike. Evaluate compliance while those tasks are performed, in addition to evaluating 8-hour time weighted averages (TWAs).
Once you’ve established a baseline of samples, you can adjust the IH sampling plan accordingly. You may determine you don’t have sufficient data to make accurate determination of the risk or you may decide there is sufficient data and reduce the number of samples required.
IH software can assist with all of these mundane tasks by giving you a simple platform for selecting chemicals to be sampled, identifying correct analytical methods, creating your SEGs, and even helping choose the right laboratories for the job. Again, during your evaluation phase, you’ll want to short-list cloud-based solutions, since these systems enable the information to be accessible to all parties that need access to it, including corporate EHS representatives, consultants and laboratory personnel. This helps ensure the hand-off of responsibilities from one stakeholder to the other, minimizes the chance for mistakes, and saves both time and effort throughout the overall process.
IH REPORTING AND EMPLOYEE RIGHT-TO-KNOW
Once you have your IH sampling results, you need to make sure you’re able to easily share the results with employees. Specific standards require employers to automatically notify affected employees of monitoring results. For example, you must notify your employees of their methylene chloride exposures within 15 working days of receiving results. And the OSHA Standard “Access to Employee Exposure and Medical Records” in 1910.1020 requires you to provide access to exposure records within 15 days of an employee request. If this cannot be done, you must inform the employee of the reason for the delay and the earliest day when the records will be available.
Again, software helps streamline these notification requirements by allowing you to track and maintain your results in one centralized location. Most solutions today will flag results that exceed the applicable OEL to make it easier to prioritize and automate communications and know when follow-on activities are needed.
EMPLOYEE TRAINING AND PREPAREDNESS
Employee training is a critical part of an effective and compliant IH program. Here, too, chemical management software is invaluable.
Under OSHA’s HazCom Standard, you’re required to train your employees on key information in SDSs—including health and physical hazards, storage and disposal requirements, and emergency response information—prior to their working with any hazardous chemicals. But SDSs also play an important role in helping your employees put that training into use in the moment. Workers are more likely to access SDSs when using software that makes that information easier to access wherever and whenever they need it.
Today’s software options make training management and deployment easier by enabling you to share details of your IH sampling program with your workforce, and providing the kind of specific training on your chemical hazards and exposure assessments necessary to promote the success of your IH program. The best systems not only give you access to engaging training content, but also give you helpful tools to schedule trainings, document and verify training completion, and have built-in e-mail notification features that remind employees and managers when training deadlines and certification dates are upcoming or past due. Centralized systems for accessing and storing training tracking metrics keep your information up-to-date, and make it accessible anywhere in the organization. These tracking tools are particularly useful for those who oversee a large workforce or are coordinating training over multiple locations to ensure all local training requirements are being met.
CHEMICAL BANNING AND APPROVAL WORKFLOWS
Another major component of IH is following the hierarchy of controls, so one of the best ways to control chemical hazards is to keep them out of the workplace in the first place. Well-designed chemical management software helps you do just that by creating approval workflows that require sign-off from authorized personnel before a chemical enters the facility, or even alerting everyone within the software when a product isn’t allowed on premises.
You can’t be everywhere at once and—as previously mentioned—the need for IH has increased while the people and resources necessary to manage it have become scarcer. Putting this new breed of EHS software to work for you means that responsibility for IH best practices can be shared. Workflows and chemical banning allow you to extend your reach, even when you’re not there in person.
Whether you’re a veteran CIH trying to determine where best to deploy your resources and demonstrate the value of IH when talking with management, or an EHS professional who inherited an IH program in need of quick improvements, today’s well designed software can help you succeed. The right software can improve and streamline all aspects of your program to help you meet the challenges of IH in changing times and provide a safer, healthier workplace for all.