5 Tips for EHS Compliance Success
Did You Know?
Most EHS folks are well aware that for years OSHA has listed its Hazard Communication Standard (HazCom) in its top 10 most violated standards. But what you may not have known that penalties associated with non-compliance of OSHA standards relating to chemicals (i.e. process safety management, PPE, respiratory protection, flammable and combustible materials) in conjunction with penalties associated to the HazCom standard resulted in over $10.1 million dollars of fines made payable to Uncle Sam for just the manufacturing, transportation and service sectors alone. So, what are some proactive measure that companies can take to avoid such costly penalties? There are several, but here are 5 tips that seem to work universally well for many employers.
5 Tips for Success
1. Take Inventory
Most facilities have an inventory process so that they know what to order, how much to order and when to order. However, for purposes of EHS compliance, chemical inventory activities take on a whole new meaning. You are looking to determine not only what you have and how much, but also you need answers to the following questions, as well as many more, as a result of your inventory:
Do you have an (m)SDS for it?
Is it labeled properly?
How frequently is it used? Who Uses it? How do they apply it?
Have the physical and health hazards been addressed?
Is it an extremely hazardous substance? Is it a carcinogen? Does it trigger OSHA’s process safety management requirements?
Where is it stored currently? Is it being stored properly? Is it compatible with the materials it is currently stored with?
2. Review the (m)SDS before the chemical is used on the floor
You know that you need an (m)SDS for each new chemical, or any time there are significant changes to a current chemical that is being used, but do you have a process in place that allows you to actually assess the potential EHS risks of the chemical before bringing it on-site? For example, will the chemical cause you to exceed your air permit limits because there are HAPs in the material? Will it require special handling instructions? Does it require new PPE? Many times employers do not find out the answers to these questions until there has been some sort of EHS incident on the work floor.
3. Make your training specific to your operations
You have an entire library of training videos that new hires are required to watch and a set that are required for annual refresher training. However, research tells us that in order for adult learners to truly understand the material, they need to put into practice. OSHA frequently cites employers on failure to properly train their employees. In other words, employers often go through the motions so that they can check the box to show that training has been completed.
You should design your training programs so that it incorporates job specific and/or industry specific information into the training itself. You may want to include photos of workers at your facility who are wearing their proper PPE or bring in several different containers that you found out on the shop floor that have both proper and improper labels to show workers the difference. It is these types of hands on exercises that will drive your point home and keep folks safe.
4. Make it easy for your employees to do the right thing
In today’s modern society, people frequently lament that they are “just crazy busy!” Our employees are no execption to the modern day time crunch. They are being asked to do more with less due to employee cut backs and tighter profit margins. The temptation to cut corners is often very great. Therefore, when you are putting together your compliance programs, make it easy for your employees to do the right thing. For example, utilize technology to automate various reports such as near miss events, recordables, root cause analysis and reporting unsafe acts. Additionally, to make sure that containers are properly labeled, you may want to create posters or binders that show examples and photos of what a properly labeled drum looks like, paint lines that clearly designate safe walkways, establish an (m)SDS compliance committee to ensure that the most up to date physical and health hazard information is available for your chemicals. The bottom line is to make it convenient for your employees to exhibit the behaviour necessary to stay safe.
5. Form an inter-departmental EHS steering committee
It has often been said that the mother of innovation is necessity… but what happens when several different groups in an organization need lots of different things? What happens when something is desperately needed, but does not appear that it will benefit the bottom line or have a significant return on investment? In these situations, it is extremely helpful to have one committee that has a representative from each department, such as accounting, purchasing, sales, operations, R&D, quality, and EHS. This type of group can then tackle problems and come up with both short term and long term solutions that will benefit the entire company. If purchasing understands that by spending a few dollars on a product that will be more effective on the machine, will produce higher quality products that are easier to sell and have a low VOC content with zero carcinogens in the formulation, this is a profitable strategy for the company!
Sometimes Everyone Needs a Little Help
Often it is difficult to take on a new project, even when you know that it will be extremely beneficial because there are no extra resources to take on such a project and handle all of the day-to-day fires. This is when calling in the help of a consultant that understands how to handle real-world situations can be very valuable. Additionally, converting manual tasks into automated tasks through the use of technology can free up loads of time to tackle more interesting projects.
Safetec can help you accomplish your EHS goals. Contact us today for more information.