Time is critical when tracking down hazardous substances. Whether it’s trying to mitigate safety incidents before they happen, comply with applicable safety and environmental regulations, or gather all the pertinent information during an emergency involving a chemical spill, fire or natural disaster, having an efficient way to trace every ingredient is paramount.
However, many chemical product names tell you nothing about the ingredients they contain. You need ingredient-level visibility of hazardous chemicals to not only keep your employees and surrounding community safe but also meet many regulatory requirements and everyday safety management obligations.
Chemical Processing spoke with Philip Molé, ESG and EHS expert at VelocityEHS, a leader in development and implementation of EHS and ESG software, to discuss how acquiring the necessary information about the chemicals you use at their ingredient level ensures visibility for informed decisions. The following is an edited version of that conversation.
Q: What are the key components of a robust chemical ingredient indexing system, and how do they contribute to ensuring safety and compliance?
A: A big challenge in the chemical industry is that you’re working with a huge inventory of chemicals, which might change constantly. We've always been chemical ingredient indexing to identify the hazardous chemical ingredients posing the greatest levels of concern (LoCs); we've just been doing it in a very labor-intensive and burdensome way. The old way, which I’ve done myself, involves going through SDSs, often in physical form, and hunting for the chemical ingredients across all the sheets.
Chemical ingredient indexing today is based on machine learning. When you have software capabilities within chemical management software, it can auto-extract all ingredients on your safety data sheets. Then, it will be able to cross-reference them against different regulatory lists. When it finds a chemical ingredient that is regulatory cross-listed, for example, on EPA’s list of Toxic Release Inventory (TRI)-reportable chemicals, it red flags that for you. It pulls together statistics almost like the back of a baseball card, where it tells you some of the main regulatory lists that it's on and some of the main things that you need to know to be better able to manage the chemical. Machine learning teaches itself based on a data set. So, it's always further improving. The more data in the system, the better it can do what it does.
One of the safety management challenges that I think a lot of us have in general is that we have a person rather than a system — all the knowledge is in their head. If they leave, go on vacation or are out sick, you don't have access to that information. However, software based on machine learning helps you create a system.
Q: Digging further into compliance, what are some of the regulatory actions in motion regarding per- and polyfluoroalkyl substances (PFAS)?
A: The EPA is taking a whole agency approach to PFAS. Just recently, a final rule was issued that made water standards for public water drinking systems, called the National Primary Drinking Water Regulations, which establish enforceable legal levels for public drinking water systems.
There have also been actions to introduce more regulation of PFAS as Toxic Release Inventory (TRI) chemicals, commonly known as Form R reportable chemicals. There is now an automatic mechanism to add new PFASs to that list every year based on risk assessments that the EPA has been doing. For 2023, which is due to be reported July 1, 2024, there are 189 PFASs currently reportable. There will be 196 that will be reportable for 2024, for Form R reports due by July 1 of next year.
Outside of the U.S., several PFASs are now on EU’s REACH candidate list. A couple of years ago, several PFASs were added to the Stockholm Convention on Persistent Organic Pollutants (POPs.) There are restrictions involving the import and export of those.
Canada is also taking similar actions, including putting their own drinking water regulations into effect. The key point is that you have to know whether you have PFASs in your inventory. So, you might have a chemical that's called Green Coat B. You can't tell from the name what's in that. That's why you need to know at the ingredient level whether you've got chemicals of concern, including PFASs.
Q: How does better chemical management fit in with environmental, social and governance initiatives we're seeing right now?
A: Environmental, social and governance (ESG) is a shorthand that pertains to things we used to call sustainability combined with traditional areas of environmental and safety management and EHS regulations.
Another big area of ESG is social sustainability, which refers to building safe places, whether inside or outside a company.
So, social sustainability pertains to being able to better manage the chemicals that you're using and to know what sorts of safety and environmental issues they might pose. And it also pertains to stakeholder management. You have a lot of different partners, including suppliers, distributors, transporters and retailers. All of them have safety issues, too. All of them have a vested interest in knowing that the chemicals you provide for them to work with are safe or that they at least understand the risks associated with them, which means some of them may be coming to you for additional information about the products you’re putting out there, and the ingredients in them.
Another aspect of ESG is the “circular economy,” which is a perspective based on ensuring you have a lifecycle approach to the products and services you're providing, including understanding and risk control over what happens to them at the end of their life. Do they become hazardous wastes? Do they require additional treatment? Is the treatment that they're going to get going to create exposures for communities that are, for example, near the treatment storage and disposal facility?
And then an overarching consideration is the “G” in ESG, which stands for governance. Governance is a measure of how well a company is managed and whether it has oversight of safety and sustainability “baked into” its management approach. A great thing about chemical ingredient indexing is that it is a verifiable process you can point to as part of your governance of chemical hazards because of the way it improves your visibility of chemical ingredients and their hazards throughout your inventory and your ability to communicate those hazards to stakeholders.
Q: Is there any concern about proprietary information being accessible?
A: Chemical ingredient indexing extracts information present on safety data sheets. If chemical suppliers or manufacturers use trade secrets to protect the identity of an ingredient in their product, then the ingredient would not be listed in the SDSs, and so chemical indexing software could not automatically extract it.
Q: Is there anything you’d like to add?
A: Think about the size of your chemical inventory. Think about the context of your organization. The context of your organization is the whole world in which your business operates. That includes not only how you're sourcing your chemicals but what your company is doing with them to provide the products and services that it makes, as well as everybody involved in bringing that to market, from your distributors to your transporters to your end users. Everybody is affected by the chemicals that you're using. That starts with you; it starts with having the information that you need about the chemicals that exist at the ingredient level, that are not being hidden by chemical names, so that you could have that visibility.
Once you have the visibility, you not only can manage things better for everybody involved in your company and who is affected by what your company does, but you could potentially make better decisions about what chemicals to use less of and substitutions you could make. It all starts with having this basic level of information. It might be time to look into the benefits that chemical ingredient indexing, especially when it's enhanced by machine learning, can provide because, across the board, it's going to improve your ability to build ESG maturity, it's going to improve the safety of your workplace, and it's going to improve the long-term business resilience of your company.
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