Improve your approach to hazardous materials

Committing a significant level of resources to dealing with hazardous materials can be difficult for small companies. Learn to focus on developing an accurate inventory and gain a strategic advantage.

By Jess Kraus and Michael Beckel, 3E Company

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Why is the inventory so important? Because, with so many companies doing inventories so poorly, a company that does it right gains a significant strategic advantage. When analyzed, the size and diversity of hazardous products within an organization is almost always a surprise. Unfortunately, because EH&S staff and managers haven’t seen the whole picture, the result is misguided programs, misleading reporting, insufficient training and poor decision-making.

The implications

The accuracy of the inventory has cascading effects within an organization, from specific EH&S responsibilities, to employee well-being, management decision-making and corporate responsibility. If even 10% of your inventory is inaccurate, the following issues may arise:

MSDS compliance. MSDSs won’t be available when needed or may contain outdated information. Staff may be spending valuable time and resources acquiring and maintaining MSDSs for products that aren’t really used or stored on site. At the same time, if MSDS files are used to maintain a firm’s 30-year exposure record, failing to archive outdated MSDS could indicate chemical use when there was none, thus increasing potential liability.

Chemical exposures. On-site data may not be available for the chemicals to which an employee is exposed. If the data are provided, they may refer to a previous or generic version of the product, increasing the likelihood of mistreatment.

Transportation. Products may be improperly classified for shipment due to out-dated information. This directly impacts the safety of the product in-transit, as well as the safety of the transporting vehicle (air, ground, sea) and its driver, crew and passengers. If an in-transit incident occurs, emergency crews will be ill-prepared to respond if working with incomplete or misleading information.

Disposal. The designated budget for disposal may be inadequate if it doesn’t account for all items. Likewise, contingency planning for emergency response will be incomplete.

Regulatory reporting. Sensitive chemicals (such as those on the SARA 302 Extremely Hazardous Substances List) may not appear on reports. Items listed on the inventory but not actually used or stored on site could push amounts over thresholds that trigger greater reporting burdens and unnecessarily lead to higher fees related to the amount reported.

Training and preparedness. An incomplete inventory means that employees may  be  unaware of all the chemicals in their workplace. This can significantly increase the risk of exposure or injury and the related cost of treatment. Lack of related inventory data, such as MSDSs and storage quantities, can also mean that all hazards are not properly evaluated.

Site-specific lapses

Similar issues can arise if a company assumes that the inventories at all sites or departments within its organization are the same:

MSDS compliance. Site-specific MSDSs are not immediately available or are completely unavailable.

In a true emergency, such as ingestion, inhalation or exposure, treatment information contained on the MSDSs will not be accessible by responding personnel. The company is then out of compliance with the Hazard Communication standard, which requires employee access without barriers to MSDSs, and risks an OSHA citation.

Chemical exposures. If a company is unaware of the specific hazards at a given site or within a department, it may  be unprepared to respond to employee exposure or injury. In addition, it may lack proper personal protective equipment, eyewash stations or containment tools in place for the specific chemicals.

Transportation. Shipping personnel may be inadequately trained on the types of chemicals and products they are shipping. This can delay shipments or cause them to go out improperly labeled, packed and placarded. If shipping by ground, the drivers may be unqualified to transport the hazardous materials. Potential fines for non-compliance, from the DOT and FAA, are large and can be assessed on individual executives.

Disposal. Established processes for handling specific waste streams may  be inadequate. This could lead to waste being on site longer than necessary and, thus, higher risk and cost. Uncertainty about what exactly is in a company’s waste stream may result in using waste contractors without proper training, certification, tools and insurance. Likewise, a company’s own staff may not have the training and tools to manage the waste they are generating.

Regulatory reporting. Using a “master” report, based on one location as representative of all locations, may cause some chemicals to be reported unnecessarily. This could also trigger additional local or state reporting and their associated cost. The reverse is also true — a “master” report could leave some chemicals unreported, increasing risk and opening the company up to potential fines.

Training and preparedness. Lack of understanding of the exact nature of the hazards at a specific location makes proper training impossible. Locations where the amounts of hazards have been underestimated won’t have enough training. This is amplified in situations where substances that require unique handling procedures, such as lead and mercury, are found on-site. Over-training, which unnecessarily increases costs, can also occur.

Potent payoff

Simply starting with an accurate inventory can result in more wins under your belt. By focusing efforts on gathering and analyzing the right information, EH&S personnel can impact the cost to acquire, track, store, ship and dispose of hazardous materials and improve the HazMat understanding among employees throughout the organization. EH&S departments are winning every day because they are looking at the right data and making good decisions. Strive to become one of them.

Jess Kraus is founder of 3E Company, Carlsbad, Calif. E-mail him at jkraus@3ecompany.com. Michael Beckel is manager of consulting services for the firm. E-mail him at mbeckel@3ecompany.com.

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