Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine workplace chemical hazards.
Every day, on-the-job exposures to chemicals can pose health and safety hazards to your employees. Those can be addressed by exposure control methods like engineering or administrative controls, personal protective equipment (PPE), and the information and training provided in a hazard communication (HazCom) program. For chemicals without established exposure limits, occupational exposure banding, or “control banding,” methods may help you protect your employees.
Sometimes there are accidents involving chemical processes. The Occupational Safety and Health Administration (OSHA) investigated a July 2024 gas release at a Chambersburg, Pennsylvania, soap and detergent manufacturer that sent a dozen workers to the hospital. OSHA announced on January 14 that the employer will face a $161,310 fine following the investigation.
Chemicals reacted while being processed by company employees, leading to a release of nitrogen dioxide gas.
The company took no immediate action to assess the impact of the release, according to OSHA, and didn’t swiftly evacuate workers from the building as a precaution. Inspectors learned workers were exposed to nitrogen dioxide gas levels above the chemical’s regulated ceiling limit. As a result, 12 employees were evaluated at a local hospital, and two required hospitalization.
Agency inspectors determined that the company had no emergency response plan and that its respiratory protection and HazCom programs didn’t meet federal requirements.
OSHA suggested that the company address several emergency response plan issues, including:
- Pre-emergency planning and coordination with outside parties;
- Personnel roles, lines of authority, training, and communication;
- Emergency recognition and prevention;
- Safe distances and places of refuge;
- Site security and control;
- Evacuation routes and procedures;
- Decontamination;
- Emergency medical treatment and first aid;
- Emergency alert and response procedures;
- Response and follow-up critique; and
- PPE and emergency equipment.
Your HazCom program
OSHA’s HazCom Standard is its most cited general industry standard. In fiscal year 2024, the agency cited 2,888 violations.
A compliant HazCom program includes worker information and training on workplace chemical hazards. Information is provided on both chemical labels on containers and safety data sheets (SDSs). Both direct employees and contract or temporary employees must receive training on chemical hazards in the workplace and on the appropriate controls for these hazards.
The entire program must be documented in a written HazCom program. OSHA inspectors will cite you for any missing program elements and the lack of a written program.
Any OSHA inspection for HazCom compliance begins with a review of the written HazCom program. Agency compliance safety and health officers (CSHOs) will confirm that your program includes a complete inventory of all hazardous substances in the workplace, as well as methods for informing employees of hazards they may encounter in nonroutine tasks.
CSHOs will also inquire about information and training for temporary or contract employees. Inspectors will interview both workers and supervisors to gauge your level of HazCom compliance, and they’ll ask about whether workers know how to access and use SDSs.
Agency inspectors will check that the chemical labeling aspects of the program include a description of the labeling system and alternatives to labeling used for workplace containers, the designation of a person responsible for workplace labeling and labeling of shipped containers, and procedures for reviewing and updating labels in the workplace.
Manufacturers, importers, and distributors are responsible for classifying hazards and labeling the chemicals they offer for sale. During a workplace inspection, CSHOs will ensure containers of hazardous substances are labeled and that labels are legible and prominently displayed. Labels must be in English but may include label information in other languages. Labels must be attached to the immediate container, although fold-back or pullout labels or tags can be used on small or oddly shaped chemical containers. They’ll also check that the product identifier on the label matches the chemical inventory in the written HazCom program.
Inspectors will evaluate the effectiveness of any in-house labeling system by conducting employee interviews to confirm employees understand the hazardous effects of chemicals to which they may be exposed.
Inspectors will confirm that you’ve received SDSs for all chemicals in your facility. Manufacturers, importers, and distributors must provide an SDS with the first shipment of a chemical, but SDSs may be transmitted electronically. However, manufacturers, importers, and distributors can’t require you to buy any new technology to access SDSs. Manufacturers, importers, and distributors must also confirm that you’ve opted into electronic transmission.
Simply having a collection of SDSs isn’t a substitute for training. An agency CSHO will determine whether workers are aware of the chemical hazards to which they’re exposed; understand how to read container labels; can locate, read, and understand SDSs; and know the necessary precautions to take when exposed to hazardous substances.
The National Institute for Occupational Safety and Health (NIOSH) Pocket Guide to Chemical Hazards (NPG) can be a valuable resource for compliance and is available in print, online, as a PDF, or as a mobile Web app from the institute.
OSHA has set regulatory permissible exposure limits (PELs), and NIOSH has published recommended exposure limits (RELs) for some chemicals found in the workplace. Many others have no established occupational exposure limits (OELs). In those instances, occupational exposure banding, or “control banding,” methods can point to exposure controls you might use.
Studies of human health effects or toxicology can indicate an appropriate hazard “band” for a specific substance. There are three tiers to NIOSH’s occupational exposure banding approach:
- Tier 1 requires relatively little employee information and only modest specialized training. A quick summary of the most critical health effects associated with exposure to a substance will suffice.
- Tier 2 requires employers to examine publicly available databases and extract relevant toxicological data for information that will be plugged into an exposure banding algorithm.
- Tier 3 requires expert judgment to critically evaluate experimental data to discern likely toxicological outcomes.
OSHA regularly updates the HazCom Standard to conform to the internationally recognized Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The agency revised its HazCom rule last year, bringing it more in line with the seventh revision to the GHS.
Changes included updates to the requirements regarding the content and form of SDSs, as well as changes in Appendix A of the standard to address the communication of health hazards of chemicals in the workplace. With the 2024 revisions, the standard is better aligned with elements of the GHS and Canadian chemical safety regulations.
The hazards of chemical processes
Facilities like the Pennsylvania soap and detergent manufacturer where workers perform chemical processes have their own set of hazards. Most chemical processing plants must comply with OSHA’s Process Safety Management (PSM) Standard.
Whether the standard applies is determined by the quantity of highly hazardous chemicals at a facility rather than the likelihood of a release. Appendix A of the PSM Standard lists the threshold quantities of highly hazardous (toxic or reactive) chemicals.
Chemical accidents, both reactions and releases, are investigated by the independent U.S. Chemical Safety and Hazard Investigation Board (CSB). The board’s investigation reports and YouTube videos are informative if you’re interested in accident prevention.
The CSB investigates industrial chemical incidents but doesn’t issue citations for regulatory violations or impose any fines. The board provides safety recommendations to companies, industry groups, labor unions, and regulatory agencies, including OSHA and the Environmental Protection Agency (EPA). The president appoints board members, who are subject to confirmation by the Senate.
The CSB last year recommended increased use of remote isolation equipment at chemical facilities. The board provided recommendations to the EPA, OSHA, and the American Petroleum Institute (API), an industry association, in the study “Remote Isolation of Process Equipment.” According to the board, remote isolation of process equipment could quickly stop releases of hazardous substances, help prevent fatalities and serious injuries to workers at chemical facilities, reduce damage to facilities, and better protect communities and the environment.
The board’s investigations stress the importance of assessing and maintaining the integrity of processing equipment to ensure chemical process safety. For instance, the CSB concluded that a paint and polymers manufacturer in Columbus, Ohio, didn’t adequately provide the mechanical integrity of a 20-inch manway recently installed on a process vessel. The oversight led to a flammable vapor explosion and fire at the facility. The board also concluded that the employer didn’t have adequate safeguards to minimize the consequences of the incident. The explosion and fire killed a press operator lead and hospitalized eight other employees.
OSHA cited the paint and resins manufacturer with two willful and 33 serious safety violations, including violations of the PSM and Hazardous Waste Operations and Emergency Response (HAZWOPER) standards. OSHA also cited the employer for failing to provide employee training and for not providing PPE.
The HAZWOPER Standard regulates the protection of worker safety and health from accidental releases of hazardous substances during emergency response and site cleanup.
The CSB identified problems with the mechanical integrity of equipment as a cause in another June 2019 fire and explosion at a Philadelphia, Pennsylvania, refinery. A corroded pipe elbow ruptured, releasing process fluid into the refinery’s hydrofluoric acid alkylation unit. Over 5,000 pounds (lb) of highly toxic hydrofluoric acid was released. A 38,000-lb vessel fragment launched off-site, landing on the other side of the Schuylkill River.
The board also concluded that the company failed to verify the safety of its equipment after changes in industry practices. The refinery also lacked remotely operated emergency isolation valves in its hydrofluoric alkylation unit, according to the CSB.
OSHA cited the refinery with serious violations of the PSM Standard, proposing penalties totaling $132,600. Deficiencies in the refinery’s PSM program included failing to establish or implement written procedures, insufficient hazard analysis, and inadequate inspection of process equipment, according to OSHA.
Requirements of OSHA’s PSM Standard include performing a process safety hazard analysis, compiling process safety information, and developing and implementing written operating procedures. Other requirements include establishing and implementing “management of change” (MOC) procedures; maintaining the integrity of chemical process equipment; performing a pre-start-up safety review in new or modified facilities; informing contractors of known explosion, fire, or toxic release hazards; and issuing “hot work” permits for any hot work operations performed on or near process equipment.
All employers must comply with OSHA’s HazCom Standard. The PSM Standard may apply if you have toxic or reactive substances above the standard’s thresholds.