Mastering Chemical Safety Management: From TRI Reporting to EPA Bans and Beyond

Between 2021 and 2023, over 825 hazardous chemical-related incidents, including fires, explosions, and toxic chemical releases, were reported to regulatory authorities. In 2023 alone, more than 270 of these incidents occurred, according to data from the Coalition to Prevent Chemical Disasters. 

Of the 42 reported fatalities, the majority were workers at chemical plants or facilities handling hazardous chemicals.

The continued occurrence of chemical incidents despite existing regulations highlights the need for further improvements in chemical safety management, particularly in the oil and gas extraction industry and in facilities that manufacture plastics, pesticides, and petrochemical products from fossil fuel feedstocks.

Chemicals pose several threats to the health and safety of employees, communities, and the environment where they are stored and used.

These threats include:

• Hazard 1 – Injuries and Illnesses: Chemical exposure through inhalation, skin contact, ingestion, or injection can cause a range of injuries and illnesses, from mild to severe, depending on the level of exposure and the strength and toxicity of the chemicals.
• Hazard 2 – Loss of Productivity: Illnesses and injuries result in lost productivity due to absenteeism. Prolonged absences may require hiring and training replacements to ensure tasks are completed properly, leading to extended periods of reduced productivity.
• Hazard 3 – Increased Costs: Costs can rise significantly for manufacturers due to lost productivity, expenses related to hiring and training replacements, penalties, and potential litigation. Additionally, companies may need to invest in investigations and corrective actions, further delaying operations.
• Hazard 4 – Risk to Assets: Accidents such as fires and explosions caused by poor storage practices can result in significant property damage. This not only disrupts production schedules but also requires costly repairs and maintenance, further increasing delays.
• Hazard 5 – Poor Employee Morale: Ineffective chemical safety management can erode employee trust in the organization, negatively affecting engagement levels. This lack of trust may also increase chemical hazards due to a lack of awareness and proper handling processes.

Meeting Chemical Safety Regulatory Requirements

Chemical Safety Management is essential from a business perspective—for the safety and health of employees and the environment. It is also a regulatory requirement, especially in high-risk industries such as oil and gas, where chemicals are commonly used.

OSHA's Hazard Communication Standard (for worker education and training) is covered in 29 CFR 1910.1200, 1915.1200, 1917.28, 1918.90, and 1926.59. These mandates sharing information about workplace chemical and toxic substance hazards and the protective measures with the workers. To ensure accurate information is shared, chemical manufacturers and importers must assess the hazards of the chemicals they manufacture or import, label them correctly, and prepare safety data sheets to share the hazard information with their customers and the workers who are exposed to them. They must also be provided with training to handle the chemicals correctly.

Process Safety Management (PSM) of Highly Hazardous Chemicals Standard is another OSHA standard that focuses on preventing or reducing the impact of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.

The Toxic Substances Control Act (TSCA) empowers the Environmental Protection Agency (EPA) to review the production, distribution, use/handling, and disposal of existing and new chemicals.

The EPA is also authorized under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) to identify individuals and/or companies responsible for environmental contamination of a site and ensure cleanup.

The Emergency Planning and Community Right to Know Act (EPCRA) requires manufacturers to implement mitigation measures to prevent or reduce the impact of chemical-related emergencies, report releases of hazardous or toxic chemicals, and inform local citizens in case of any chemical release in their area.

The Resource Conservation and Recovery Act (RCRA) governs the proper storage, transportation, and disposal of solid hazardous waste.

Best Practices for Chemical Safety Management

Here are some best practices for effective chemical safety management:

• Assessment and Review:

• Identify and assess the hazards of the chemicals being produced, imported, used, stored, or handled. This helps determine appropriate mitigation strategies to minimize incidents and prevent injuries or illnesses.

• Implement the Hierarchy of Controls:

• Following the Hierarchy of Controls enhances chemical safety management. The steps include:
• Elimination
• Substitution
• Engineering controls
• Safe handling through PPE (Personal Protective Equipment)

• Labeling and Safety Data Sheets (SDS):

• Accurate labeling of chemicals and ensuring the availability of SDS for all chemicals used, stored, or managed are crucial steps to minimize risks and hazards.

• Training:

• It is vital to empower workers with training on safe chemical handling, hazard awareness, and proper usage. Easy access to SDS and providing resources to address any questions regarding chemical use are also essential to maintaining safety.

• Safe Storage:

• Proper chemical storage is critical to reducing the risk of explosions and fires. Understanding chemical properties and storing only compatible chemicals together are simple but essential safety measures.

• Chemical Safety SOPs:

• Creating and documenting a chemical safety program is important for maintaining safety standards. The program should detail the chemicals used in the workplace, their hazards, mitigation strategies, proper labeling, handling procedures, and steps to take in case of an incident.
  
  Environmental reporting, such as Tier II and Toxics Release Inventory (TRI), is a regulatory requirement and should be part of the SOPs. A proactive approach to chemical safety management allows organizations to go beyond compliance, using a risk-based approach to continuously improve safety protocols.

Role of Technology in Improved Chemical Safety Management

Manufacturers often use various chemicals, each sourced from different suppliers and presenting unique risks. Manually managing chemical hazards can be challenging and inefficient.

A cloud-based Environment, Health, and Safety (EHS) management solution like ComplianceQuest, built on Salesforce, can automate processes and improve efficiency. Key benefits of using technology for chemical safety management include:

• Risk-Based Approach: The software identifies and ranks risks, ensuring that high-risk chemicals receive priority attention. It also helps identify high-risk processes for continuous improvement based on past incidents.
• Labeling and SDS Management: The solution automates the creation, management, and access to labels and Safety Data Sheets (SDS), simplifying compliance. With a centralized location for documents, users can access them anytime, anywhere, based on permissions and needs.
• Supplier Management: The quality of chemicals and their associated documentation is critical for safety and compliance. Supplier management features help ensure supply chain safety, minimizing upstream and downstream incidents.
• Automation: Automating processes reduces the risk of human error and enhances compliance through timely interventions. It also provides access to relevant data to identify potential risks and take appropriate action promptly.
• Audits and Inspections: The software facilitates scheduling and conducting periodic audits and inspections to ensure proper chemical storage and handling, thereby improving compliance.