Transportation of Dangerous Goods needs to be integrated into your Chemical Management Program

By: Corinne Paul
If your organization produces or ships chemical products you likely have different departments working on different areas of that product’s life cycle; whether that is marketing them, managing their hazards and risks, or transporting those products. All departments have many common links and tasks between managing a chemical but frequently, they do not communicate with each other. For example, your marketing group may be selling a product under one name, the Safety Data Sheet is likely written for the product under a separate name and when transported the product’s shipping name can be entirely different again. These groups may even be conducting their own sampling of the product.

Communication between the industrial hygienist, process engineers and marketing personnel is important so they all understand what the chemical properties are of the product they are selling and what is being communicated to carriers and customers.

Sampling is critical to many elements of a Transportation of Dangerous Goods (TDG) program. Section 15 on a Safety Data Sheet informs people of the Transportation of Dangerous Goods criteria. Sampling affects classification which determines placarding and safety marks on a means of containment (MOC). Composition affects the class of the product and flammability affects the packing group. Developing a sampling strategy ensures confidence in the proper classification, which flows into accurate and reliable SDSs. Proof of Classification is a regulatory requirement under TDG and needs to be incorporated into your TDG and/or Chemical Management program.  Is that information readily available for all groups to access? Is every group conducting their own sampling activity or can this be consolidated for efficiency?

Better communication between these 3 groups will mitigate the risk of miscommunication on products and reduce an overlap of tasks. It may also minimize the risk of an error on shipping documentation or placarding that can result in a TDG infraction.

How do you define “Fit for Duty”? And how you can incorporate this into your event/incident investigations to uncover the WHY.

By: John Artym

I have recently been part of industry conversation with respect to preventing injuries and occupational illness.  Part of our discussions has raised the issue that industry must move pass deferring to the immediate cause(s) of events/incidents to focus on determining the indirect/root causes of events/incidents to improve how they answer – why events/incidents occur?

The control measures and counter-measures organizations implement must focus on the gaps in management systems and those indirect or root causes. It is easier to focus on substandard conditions or blame an individual for a substandard act(s) then determine the “WHY”.

The worker’s mind was not on task…they made a mistake…impaired decisions…distracted driving…or fell asleep at the wheel are all terms we have heard to explain why an event/incident occurred. A typical investigation focuses too much on anecdotal information, peer discussions and personal experience.

Does your investigation ask if the individual was “Fit for Duty”? Does the organization have a Fit for Duty model or standard? Was this a contributing factor? Or the indirect or root cause?

“Fit for Duty” is a term used by industry to describe the individual’s physical, mental or emotional state and how it enables their job performance in a manner that optimizes safety and performance.

What should be included in “Fit for Duty?”

  1. Physically capable to safely perform the work duties.
  2. Mindset, mentally and emotionally capable to perform the work duties.
  3. Not impaired by drugs (alcohol, legal or illegal drugs).
  4. Medically capable to perform work duties (chemical sensitivities or exposure risks).
  5. Human Factors (communication, language, cultural, social aspects).
  6. Not impaired by fatigue (personal and operational).
  7. Not impaired by cognitive distraction.

Ultimately, it is about having the capacity to make the correct decisions when required and the ability to preform the work activities safely. Usually, there are multiple causes and contributing factors to an incident and considering the aspects of a workers’ emotional, physical and mental state as well as the many aspects of their work environment will help point uncover the WHY.

How to identify chemicals or ingredients for elimination

Banning, Prohibiting and /or Restricting a Chemical or Ingredient

Eliminating the chemical or ingredient in the workplace eliminates the hazards associated with the chemical or ingredient. Elimination can prevent injuries, illness, loss or adverse effect on the environment. Elimination is the first method of control in chemical handling to consider. Elimination of a chemical or ingredient can take on a few different meanings.

Banned Chemicals or Ingredients are not to be present on a job site.

This method of control would begin with controlling access through a chemical approval process. Current inventories can be searched to determine if a chemical is being used and act to eliminate.

Banned Lists contain those chemicals and ingredients that are banned for use. The intention for the “Banned Lists” is not to simply provide a checklist to eliminate chemicals of concern. Rather, it should be viewed as specific examples that may also be used to guide substitution.

Prohibited Chemicals or Ingredients are allowed with very specific controls and limits. May require Senior Management and or HSE Committee approval. Organizations can select what chemicals and or ingredients are prohibited from their job sites, determine controls and limitations during the chemical approval process.

Prohibited Lists contain those chemicals and ingredients that have been approved with very specific controls. The intention for the “Prohibited Lists” is not to simply provide a checklist to eliminate chemicals of concern. Rather, it should also be viewed as specific examples that may substituted and/or require external monitoring or controls verification.

Restricted Chemicals or Ingredients are allowed with very specific controls and limits. Restriction may be based on use, volume, and/or environmental concerns. Organizations can select what chemicals and or ingredients are restricted, determine controls and limitations during the chemical approval process. Products listed in different environment and import requirements can be linked to meet restrictions.

Where to Begin? 3 Steps to Get You Started:

  1. Identify chemicals or ingredients of concern on human health and the environment. This can be done right in msdsBinders, run a regulatory report on designated substances of concern (i.e. BC/ON Designated Substances List, Alberta Code of Practice Schedule 1) for your jurisdiction to scan your chemical inventory. This will identify chemicals of concern in your jurisdiction.
  2. Search for chemicals or ingredients of concern in your chemical inventory. This can be done in msdsBinders by searching your chemical inventory by CAS number for the substance of concern.
  3. Act and eliminate. Once the substance restriction has been adopted, your organization must comply. The elimination of a substance must be in your chemical approval and handling process. It needs to be communicated to all areas from procurement to field workers.

Speak to a Chemscape Representative for further information on the elimination and substitution of dangerous substances as well as how you can use our CHAMP technology in msdsBinders to begin substituting for less hazardous chemicals.

How to Begin Substituting for less Hazardous Chemicals

Reducing your company’s chemical footprint by reducing the exposure to high hazard chemicals in the workplace can be achieved by substituting chemicals you use each day for similar chemicals that are less hazardous. As an example, a liquid can be substituted for a powder, or perhaps the work task to weigh out powders could be eliminated by buying the powder pre-packed. It still needs to confirmed that the replacement substance does not create a greater hazard than the current one.

There are many benefits to an organization from substitution; including:

  1. Improved immediate and long-term health of the workers potentially exposed to the hazardous substance
  2. Reduced costs to the organization by:
    1. lowering sickness absence
    2. spending less on control measures
  3. Cost savings on
    1. fire and explosion protection
    2. product consumption
    3. materials
    4. compliance with environmental standards
  4. Increased efficiency of work processes
  5. Reduced impact on the environment

Where to Begin
Start by eliminating any avoidable exposure to dangerous substances.  Look at open processes, (e.g. painting big surfaces, mixing /compounding in open containers/vessels) and processes that generate dust, vapours or fumes or disperse liquids in the air e.g. welding, spraying paint.

If you cannot change the work process, look at the substances being used by the organization and consider substituting substances that:

  1. increase fire and explosion risks
  2. potentially may lead to high exposure of workers
  3. result in exposure to many workers
  4. are carcinogenic or mutagenic
  5. are volatile, e.g., organic solvents
  6. are dispersed in the air (aerosols, dust)
  7. cause acute health risks, e.g., poisons, corrosives, and irritants
  8. cause chronic health risks, such as allergens, substances toxic for reproduction and others
  9. have already caused problems in your enterprise (health problems, accidents or other incidents)
  10. cause occupational diseases
  11. make regular health monitoring (medical examination of workers) necessary
  12. can be absorbed through the skin
  13. the use of personal protective equipment, especially respiratory protection, is necessary

Practical Steps to Substitution

Approval may be required before you take the practical steps towards substitution, ask yourself:

  • Who decides on what substance is being purchased?
  • Who has to comment or give agreement?

There are three steps to substitution:

Once you have identified that the substance or process is a hazard.

  1. Identify the alternatives: find out all the options available to you. Look for alternative process methods (to remove the need to use a substance entirely) and potential replacement substances (if elimination is not possible). If the substance you wish to replace is used in a widely applied process such as spray-painting or degreasing, then the number of options available is likely to be larger.
  2. Compare the alternatives: evaluate alternatives against the substance or process you are using at the moment. Complete a risk assessment of all the alternatives, including the substance or process used, and compare your findings. Think about what could happen if you use the alternatives. Does the alternative pose a new hazard and risk under the conditions of use? Will it work for the intended purposes?
  3. Decide whether or not to substitute: make a decision based on the regulatory requirements, technological possibilities, potential implications for the quality of the products, costs, including the required investment, and training for use of the new product.

Once you introduce the substitute assess how it is working.

Speak to a Chemscape Representative for further information on the elimination and substitution of dangerous substances as well as how you can use our CHAMP technology in msdsBinders to begin substituting for less hazardous chemicals.

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.