Introduction
At ComplianceQuest, we recently authored a whitepaper titled A Step-by-Step Guide to Safety Transformation at your Enterprise. In the paper, we focused on why every company needs a safety management system in place that is reactive, preventive, and proactive.
Being only reactive is certainly not enough. But safety leaders will have to collaborate with both executive management and functional teams across the company to build an organizational mindset that promotes a safety-first approach to all business processes and operations. When it comes to managing material hazards, this approach of “reactive + preventive + proactive” cannot be emphasized enough.
The risk of exposure to hazardous materials is extremely high in industries such as biomedical, pharmaceuticals, medical devices, chemicals, oil & gas, and construction.
According to OSHA (Occupational Safety and Health Administration), such hazardous materials can be of two types:
PSM is necessary to –
- Chemical and toxic substances that pose a health risk due to irritation, sensitization, and carcinogenicity
- Materials such as explosives, gasses, inflammable solids, and liquids that pose physical hazards
Managing the safety risks associated with hazardous materials can be very challenging but also very critical for improving workplace safety performance.
Today’s competitive business environment has placed tremendous pressure on manufacturing companies to lower operating costs, address complex product design, outsource development and seek global expansion plans. Beyond this pressure there is a major opportunity for companies to build a competitive advantage through an integrated risk and compliance management approach, that ensures all features are working together effectively, enabling superior visibility into the value chain.
OSHA also emphasizes the need for worker education and training. As per OSHA’s Hazard Communication Standard (HCS) is “designed to ensure that information about chemical and toxic substance hazards in the workplace and associated protective measures is disseminated to workers.”
Are you looking to automate the process of managing material-related hazards? Worried about how your procurement team will adopt a safety-first approach? Are all hazardous materials being stored and labeled properly? Do you have a finger on the pulse of all risk mitigative actions being taken to prevent the risk of hazardous materials?
Wouldn’t it be terrific if each of these activities (and more) could be monitored using a single EHS Platform?
If yes, look no further than ComplianceQuest’s Safety Quest Solution. Request for a demo here:
8 Best Practices for Hazardous Materials Management
To ensure workplace safety from hazardous materials, the process should beginright at the stage of procurementand be followed through at every stage, including storage, labeling, usage, and disposal.
Some of the best practices would include:
Step 1: Establish Procurement Procedures
Determine and eliminate potential risks before it enters the supply chain by assessing the materials and identifying less- or non-toxic alternatives. Buy only the necessary quantity and store carefully to avoid losses and reduce costs. Define a policy for sampling to decrease accumulation and the associated risks to employee and environmental safety. Centralize purchasing to minimize duplication and wastage.
Step 2: Have Well-Documented Receiving Procedures
Onboard reliable suppliers to ensure the quality of their materials, delivery processes, reliable service, and so on. Identify designated areas to receive the materials, inspect them for safe packaging, and return excess or off-spec materials.
Step 3: Safety Data Sheets
When purchasing hazardous materials, it is important to ensure that the Material Safety Data Sheet (SDS) is available. This will help with knowing the risks, implementing controls and proper handling.
Step 4: Storage and Disposal
Safe storage and disposal are critical to prevent any harm from the materials. They should be isolated and only trained personnel allowed access. Responsible disposal such as recycling and treatment is also important. The material should be stored in ideal conditions such as the right temperature, humidity, etc. to minimize material degradation.
Step 5: Track Materials Across the Lifecycle
Make a just-in-time purchase of time-sensitive materials and track them to ensure that the oldest stock is used first. Labeling with clear information about the hazards and expiration dates is a must. They must also be used efficiently to minimize losses and wastage.
Step 6: Periodic Audits with Data at the Core
Schedule and conduct periodic inspections and audits to make sure the hazardous material procurement, storage, and usage processes are implemented properly. Record any nonconformance and share with the team to correct and improve the processes.
Step 7: Integrated Risk Management
For every hazardous material, identify the risks and the mitigation strategies. Put controls in place to prevent accidents or contain the impact.
Step 8: Train Employees
Processes can succeed only if the people handling them follow them as expected. Train employees to handle hazardous materials carefully and with appropriate precautions such as PPE, gloves, and other protective equipment. Ensure there is no unauthorized access to such materials.
By implementing these best practices, businesses can proactively minimize the risks associated with the use of hazardous materials and prevent accidents. But even in the case of an accident, the employees will also be prepared to respond quickly and efficiently to minimize the damage caused by the hazards.
Regulatory Compliance for Hazardous Materials
A variety of regulations govern the use of hazardous materials across industries. Compliance will not only prevent businesses from getting on the wrong side of the law but also improve workplace safety, ensuring a proactive approach to the risks associated with hazardous materials.
Some of the globally recognized and accepted regulations include:
RoHS (Restriction of Hazardous Substances) Directive: RoHS is an EU directive providing regulations for electrical and electronic equipment sold in the European market to minimize environmental damage. It includes medical devices and monitoring and control instruments. Noncompliance attracts fines and litigation, and even imprisonment of up to 2 years in Germany. Most critically, noncompliance can corrode brand reputation, causing the business to lose the market.
OSHA: CFR 1910.1200 classifies the hazards of all chemicals and aligns with the provisions of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), Revision 3. It requires the data to be shared with all employees to preempt any legislative or regulatory action, and that labeling, training, etc. are as per the regulatory requirements to improve workplace safety.
NFPA: National Fire Protection Association’s code applies to how hazardous materials are stored, used, and handled in all locations and facilities.
PHMSA Regulations: The Pipeline and Hazardous Materials Safety Administration7 regulate and ensure the safe and secure transportation of hazardous materials, including through pipelines. It develops regulations and standards to classify, handle, and package more than 1 million daily shipments of hazardous materials within the United States to minimize damage.
Some of the other regulations include
- US Title 49 CFR Parts 100-189 HAZMAT
- US Title 49 U.S.C. 5103
- HMR by US DOT
- FMCSA
Using a Modern, Next-Generation Safety Solution
RoHS has been revised thrice, with additional hazardous materials added to the list and some provisions changed. Keeping track of such regulatory changes and ensuring compliance can be a challenge to businesses working with hazardous materials. Moreover, businesses with multiple factory locations will find managing the entire procurement to usage and disposal lifecycle of hazardous materials difficult as they have multiple regulatory requirements to comply with. Keeping track of these differences and ensuring local compliance can become a challenge for safety leaders.
An effective reactive, preventive, and proactive approach to workplace safety management requires a cloud-based next-gen solution that provides greater flexibility, visibility, and workflow integration. ComplianceQuest’s EHS software is designed to meet regulatory requirements while empowering employees and management with a tower of data needed to manage hazardous materials efficiently, right from procurement to effective storage, usage, documentation, and worker training.
The ComplianceQuest solution helps with:
Risk Management – Taking a risk-based approach to managing material hazards will help businesses identify the risks of each hazardous material, the frequency, and severity of the risk impact, and the controls needed. Based on cost-benefit analysis, the risks can be prioritized and mitigated. A centralized list of risks can also help with capturing trends and implementing effective safety processes across the organization.
Supplier Management – The CQ solution can help businesses with creating a list of potential suppliers, onboarding those who meet the requirements, exchanging documents from within the system, reviewing performance, training or replacing the suppliers, and ensuring compliance. This can ensure that the purchases are made in a timely manner, in required quantities, appropriately packed and labeled, received safely, and stored as per instructions.
Safety Data Sheets – The document management system integral to the CQ EHS solution can be used effectively to create a master list of all hazardous materials with their safety data sheets. This will help safety leaders and the manufacturing team avoid duplicating purchases and safely handle the materials. An SDS template will also help with faster documentation of hazardous materials received with all relevant data.
Audit Management: The audit management software helps with the scheduling of periodic audits and provides tools to record findings. This is accessible to all reviewers and can help with the continuous improvement of hazardous materials management and compliance.
Training Management – The training management software facilitates constant upskilling of employees for the proper handling of hazardous materials and to improve workplace safety. It can help identify skill gaps, provide access to relevant training materials, assess the worker’s performance, and alert and notify in case the worker has not completed the required training.
Change Management – When a hazardous material is replaced or a new one is introduced, change management helps with identifying the risks and implementing new processes to avoid introducing new hazards.
Incident Management – Despite all precautions, there may be an incident, a near miss, or an observation. The CQ Incident Management software helps with capturing the details of the event, doing a root cause analysis to identify the root cause, and triggering CAPA to take corrective and preventive action.
Management Review – The CQ EHS software provides 360-deg visibility into processes, integrates workflows, and generates data that can help the management and the safety teams to draw insights. This can help make informed decisions, assign responsibilities, and track and monitor progress to improve the safety management of hazardous materials proactively.
Permit-to-Work – The CQ EHS also enables automating the permit-to-work (PTW) process by ensuring only authorized personnel can access the hazardous materials with appropriate training and protection and at a specified time duration. This minimizes risks and improves safety performance.
The CQ solution is also aligned with all leading safety regulations and, therefore, improves compliance while enabling the implementation of changes as and when needed across the organization.
To know more about ComplianceQuest’s Health & Safety Solution, request a demo here: https://www.compliancequest.com/online-demo/
