Removing Bias in your Risk Assessment for a Healthier Chemical Footprint

For Health and Safety Professionals a risk assessment is a process where you:

  • identify all hazards at your work-site – this includes chemical hazards
  • evaluate the likelihood that a hazard can cause harm
  • determine who might be harmed
  • determine corrective actions so the hazard will not cause harm or minimize that harm
  • prioritize hazards and control measures

Your risk assessment should strive to be as objective as possible. Subjective is the opposite of objective and subjective bias naturally creeps in when humans perform assessments. Subjective means based on or influenced by your personal feelings, tastes or opinions. Personal opinions can influence the outcome. Unfortunately, if you are dealing with a Kidney Toxin your kidney does not care about various personal opinions.

Some other issues can affect the objectiveness of the decision process.  Confirmation Bias is when people will look for information that support their opinion and ignore others; this leads to bad decisions.  When Confirmation Bias and Subjectivity are combined, it can lead to risk assessments that may overlook long term health effects of chemical exposure. Unfortunately, by the time people develop illness they are too sick and beyond repair.  For instance, if someone thinks a specific solvent will not harm them even though the data sheets state clearly it is hazardous, they are exhibiting their personal feeling perhaps because they have worked with it for a long time and they feel fine. Maybe it’s a product they like to use or it’s cost effective. Since people appear fine this reinforces the confirmation bias.

Most hazard & risk assessments don’t have true experts doing the assessment or available to advise.  If process safety implications exist. Will an engineer be available to categorize the hazards into risks?  How about a toxicologist? Or an ergonomist?  Since these highly skilled people are not part of the discussion process these issues are often under or overestimated based on subjective opinions and confirmation biases.

The sad part is that a worker’s health bears the brunt of the risk. Usually people do not have the skills to address all the hazards in a knowledgeable way and how these hazards could cause harm. All hazards including chemical hazards need to be considered and this means more than just reading a SDS.  Safer chemicals or less toxic chemicals should be considered. Using an objective hazard ranking method is the best method to select safer chemicals.

To do an objective hazard ranking, begin with a complete chemical inventory. List all the chemicals at the site, identify and rank the hazards.  Select different products capable of performing the same task and compare their hazard ranking, select the lowest feasible hazard that will perform the task.

Top 10 reasons to do spring cleaning with a chemical inventory

Spring is a great time to take stock of all your chemicals onsite and purge what is no longer required. Having an accurate inventory benefits many areas of your health, safety and environment program. Here are 10 reasons to start spring cleaning and take inventory:

  1. Dispose of obsolete chemicals to minimize the type and the quantity of chemicals in storage. Some chemicals have an expiry date and their chemical state changes over time to become reactive or explosive.
  2. Dispose of chemicals not used in the last year. These pose unnecessary hazards in your workplace.
  3. Ensure PPE inventory and other controls matches the hazards of your chemical inventory.
  4. Check if your emergency plans are up-to-date. If there is an incident do you have an awareness of what exactly is onsite and where it is stored?
  5. Be aware of all physical, health and environmental hazards on-site.
  6. Ensure your SDS Binder matches the product inventory.
  7. See if you can eliminate or substitute high hazard chemicals? See if you require additional monitoring or exposure tracking for chemicals of concern. Do you need additional communication plans (i.e. code of practice, exposure control plans)?
  8. Evaluate if storage of your chemicals is compatible, secure, and properly labelled.
  9. Check if training/education needs to be updated for the hazards on hand.
  10. See if you can optimize chemical purchasing.

2017: the year GHS will solve all our problems?

Important Update: Health Canada announced a new deadline for suppliers after this article was published. Canadian suppliers now have until June 1, 2018 to update their SDSs in Canada. Originally the deadline was May 31, 2017. 

As the GHS is implemented in Canada under the handle of WHMIS 2015 and Canada nears the May 31, 2017 deadline for Suppliers to update their SDSs in Canada, our consulting business is busy authoring SDSs and Labels, to prepare for the change. I have heard some opinions from dealings in my consulting work that this must be the last time Suppliers will ever need to think about authoring a Safety Data Sheet document. This is a misconception and it is incorrect.  There are several issues to consider:

If we look back to 2003, the United Nations (UN) adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS includes criteria for the classification of health, physical and environmental hazards, as well as specifying what information should be included on labels of hazardous chemicals as well as safety data sheets. Canada was an active participant in the development of the GHS, and is a member of the UN bodies established to maintain and coordinate implementation of the system. The official text can be found on the UN web page.

During these discussions, there was significant debate to not use the term “Standardized” and settled on the term “Harmonized”.  Why? The efforts to “harmonize” took 20 years so common classification schemes could be adopted – “standardized” where everything had one universal standard would have taken much longer.

Harmonizing classifications, SDSs and labels is an improvement for global trade but Safety Data Sheets are authored to meet the individual regulations for the country the product is sold or imported into and this is where things vary based on the country.

For instance, in Canada the 3-year rule will be gone except for some provinces/territories that have shifted the responsibility from the Supplier to the Employer (to date: BC, SK, NWT, YK). In these provinces, the employer needs to check every 3 years that no significant information has changed on the Safety Data Sheet. If there are changes to classifications, toxicity information, Exposure Limits for your product a new SDS might be required.

Classification changes for a product can affect Section 14 of the Safety Data Sheet on Transportation Information that Transport Canada seems all too willing and able to enforce for the past several years for many of our Oil and Gas clients.

A hazardous product for sale in Canada must have an SDS and supplier label available in the official languages of French and English. For example, an English only SDS arriving from the USA may be challenged on language grounds, in some workplaces if a portion of the population of the workforce communicates in French as a first language.

If new data becomes available, Canadian producers have 90 days to make this knowledge public for a hazardous product sold or imported into Canada, by a written notice along with an SDS document. Supplier Labels need to be updated within 180 days.

Exporting products beyond North America is still a challenge.  The European formatted SDSs are similar to SDSs in North America but there are different cutoff points for hazardous products depending on the type and degree of hazard.

There are significant other hurdles to exporting to Europe beyond the cutoff quantities. REACH legislation forces extensive risk assessments along the value chain of the product.  This is a significant barrier to entry for a new product to enter Europe.

The hope for some that GHS has “harmonized” us into one standard for all safety data sheets is unfortunately not the case. Suppliers will continue to need to keep on top of their product classifications, language requirements, and other related regulation changes in their country/state to stay compliant.

May 31, 2017 is the deadline for Suppliers to update their SDSs in Canada.

Important Update: As noted at the beginning of the article Canadian suppliers now have until June 1, 2018 to update their SDSs in Canada.