Chapter 6 Recognizing, Evaluating, and Controlling Workplace Hazards
6.5 Chemical Inventories: Use, Storage, and Disposal Records
Both OSHA and the EPA require hazardous chemicals to be inventoried and man- aged to be protective of human health and the environment. Specifically, the Hazard Communication Standard, promulgated in 1983 and amended in 1987, requires haz- ardous properties of the chemical or compound to be readily identified on the con- tainer or package. The information has to be readily available to the workers for their use, and training on the hazardous properties of the chemical is required. All chemi- cals used in the workplace must be managed, and information communicated not only to the workers but also to local and state communities because of requirements associated with the Superfund Amendments and Reauthorization Act (SARA) Title III. SARA Title III, also known as the Emergency Planning and Community Right- to-Know Act (EPCRA) which was promulgated in 1986 following the accidental release of methylisocyanate in Bhopal, India, in 1984. As a result of the chemical release, more than 2000 people were injured and chemical management regulations were promulgated that would require companies to inventory and provide chemical
TABLE 6.5
Example Checklist for the Hazard Recognition Process
Date: Walk-through location:____________________________________
Person completing hazard recognition checklist:________________________________
Yes No Comments Chemical Hazards
1. What work is performed in the work location that may use chemicals?
2. Are health hazards of the chemicals readily known, and is information available to the workers?
3. Have there been any workplace incidents or illnesses identified for the chemicals used?
4. Do workers know and understand the health hazards associated with the chemicals being used?
5. Do workers understand how to control and manage exposure to the chemicals they use?
Fire Hazards 1. Are flammable products used in the work
location?
2. Are the flammable materials properly stored?
3. Do workers understand the hazardous properties of the flammable material?
4. What emergency measures are in place to manage a fire?
5. Are the right type of fire extinguisher available?
6. Are fire extinguishing and suppression systems routinely inspected?
7. Do workers understand how to respond to a fire?
Physical and Biological Hazards 1. What are the physical and biological hazards of
the work location?
2. What are the physical and biological hazards recognized by the workers?
3. Is noise generated as part of the work process?
(Continued)
manufacturing and storage information to local emergency response personnel and county and state government agencies. Specifically, under EPCRA companies are required to:
• Provide material safety data sheets (MSDSs) for all chemicals used and stored at a facility
• Submit a toxic chemical release inventory form for all chemicals used above the applicable threshold quantities
• Notify regulatory agencies of releases greater than the reportable quantities (as defined in the regulation)
Chemical inventories, along with use, storage, and disposal records, can provide a piece of the puzzle for the industrial hygienist to use in understanding what health hazards may be posed when employees are performing work. A typical chemical inventory list contains the following information:
• Chemical name
• Chemical Abstract Services number
• Trade name
• Hazard class
• Manufacturer
• Quantity
TABLE 6.5 (CONTINUED)
Example Checklist for the Hazard Recognition Process
Date: Walk-through location:______________________________________
Person completing hazard recognition checklist:_________________________________
Yes No Comments 4. Are biological hazards, such as blood-borne
pathogens, or unique biological hazards, such as bodily fluids or communicable diseases, present? (often associated with research and development activities)
5. Do workers review work conditions prior to initiating work to ensure that any physical hazards have been identified?
6. Do management and workers recognize that changes to their work tasks may trigger a need to review and confirm that no new hazards have been introduced into the work environment?
Based on the information available, the industrial hygienist can then research and identify health hazard properties of the chemicals, as well as understand how the chemicals are used, to quantify health risk to the workers from exposure to the chemicals.
If more than one chemical is used in a work process, the industrial hygienist must also understand the additive and possible synergistic health effects that can be posed by more than one chemical. The use of more than one chemical by the employee can increase and further magnify the health risks posed by the chemicals and may drive additional administrative controls (such as lower acceptable occupational exposure limits) to be fully protective of the worker.
Storage of chemicals can also pose health risks to the workers. As workers per- form their assigned tasks and increase the amount of time spent in a chemical storage area, there is an increased probability that they may be more frequently in contact with chemicals (and therefore potentially have an increased health risk) than those employees that just work with them. Documentation associated with the disposal of chemicals can also provide useful information to the industrial hygienist of what chemicals may be present as part of the manufacturing process.
The hazardous waste manifest and shipping information provide information associated with chemical properties and appropriate response protocol. The indus- trial hygienist can gain very useful information pertaining to the hazard identifica- tion and mitigation process when reviewing shipping information associated with the disposal of chemicals. State and federal government agencies will not allow anything to be shipped without specific information being identified, such as the chemical name and physical and health hazard properties. In addition, hazardous or chemical waste that is shipped for final disposal will not be accepted at the receiving facility without ensuring that the waste is compatible with the waste currently being stored and disposed of, and that the waste meets specific acceptance criteria, which can include toxicological considerations.