Working with Newer Chemicals
Barbara Kanegsberg
The choice of chemistry, be it a single molecule or a blend, is often driven
by environmental requirements. Given the plethora of environmental regulatory
mandates, employee safety can all too easily be pushed to the back burner.
Toxicologists in Utah recently reported exposure of workers to high levels
of n-propyl bromide (nPB, 1-bromopropane). SQRC has reviewed information
obtained from OSHA, and we have spoken with some of the researchers involved.
According
to the OSHA report, the manufacturing process involved spraying an adhesive
that contains nPB onto foam as part of the production of foam cushions
for furniture. Three employees were seen by emergency room doctors, hospitalized,
and diagnosed with bromide toxicity. At least some employees appeared
to be
exposed to high levels of the adhesive over a period of years.
What changes could be made to make the process safer? The statements
in the OSHA report strongly suggest the need for improved worker safety
and
for improved
worker education. Rather than presenting a negative case-study or rather
than attempting to second-guess what might have been done, the episode
is more productively
used as the inspiration for positive, common-sense, and relatively simple
reminders about the basics of chemical handling. While in this instance
the problem was
exposure to exceedingly high levels of nPB, the bottom line is that any
chemical, particularly any aggressive (or effective) chemical, chemical
blend, or chemical
process, has the potential for worker exposure problems.
Chemical Management Reminders
A written safety and health program is essential, but it is not sufficient.
To be of value, the safety program must actually be implemented.
In the course of our own site visits, we occasionally see pro-forma, “canned” hazardous
communication programs. There they are, in impressive bound notebooks,
taking up space on the shelf. Most of us in the manufacturing world
are pre-occupied
with production issues, quality issues, cost containment, lean manufacturing,
and environmental regulatory concerns. Books of MSDS and lofty tomes
of written verbiage are of no value if the appropriate ways of working
with both the
chemical and the process are not communicated in a compelling and
effective manner.
Information about pertinent health/safety policies and procedures need
to be provided to employees in a manner that is clear, definitive, and
understandable.
All employees have to be educated in managing not just hazardous materials
but also the total process. Aside from worker safety, such communication
makes sense in terms of product quality. If your management tends to
move safety
concerns to the back burner, you might remind him or her that safety,
process consistency, and product quality can be treated as a single issue.
Unsafe
practices tend to reflect poorly controlled processes and a high reject
rate. When employees
are asked to perform a manufacturing process, an employer interested
in making a profit teaches employees to achieve a technically correct
product.
It is
imperative that employees are also taught to achieve the appropriate
safety, chemical handling, and environmental aspects of the process.
The hazards of the workplace must be clearly and compellingly communicated
to workers. For most of us, information about chemical hazards does not
inherently make for fascinating reading or a compelling lecture. The
challenge is to make
chemical handling information compelling and memorable.
I suspect that we have all seen incorrect chemical handling and poor process management; and this is by no means restricted to supposedly unsophisticated or uneducated workers. Engineers, academics, even rocket scientists have been known to store bottles of toxic, flammable, and reactive chemicals in their offices. Some anonymous colleagues like to store their MSDS book in the refrigerator, presumably to dampen even the mere description of reactivity of incompatible chemicals. This is amusing, unless someone has to find emergency chemical information quickly.
Further, we have the additional challenge of communicating
hazards to workers where English comprehension is very limited
and where
workers are simply
not comfortable speaking English. In our inspirational example,
the employees
using
nPB had Hispanic surnames; and it is our unofficial understanding
that they were all immigrants. The OSHA report does not indicate
the language
of the
worker safety program. I have long been in favor of having
MSDS and safety related programs appropriately translated.
Over the
years,
I have unfortunately
heard supervisors say: “Let ‘em learn English, like my grandpa
did.” Desirable as this may be for the overall cohesiveness
of the Nation, it is vital to communicate important health,
safety, and
technical
information
within the comfort level of the workers.
Speaking of comfort level, the most successful safety programs I have seen involve multi-media communication, and with good reason. For one thing, we learn differently. Some of us do better with lectures or demonstrations than with the written text. For another thing, semi-literacy is a reality; I have had to educate workers who were functionally illiterate. Humor helps, a lot. Employees who block out the “red-asphalt” approach to safety training will often remember safety procedures that are presented in a humorous manner.
The bottom line is that employees must understand both
the technical aspects of the job and the safety aspects
of the
job. If you
hired them, you have
to teach them. If you hired those MIT grads who are convinced
the laws of physics
don’t apply to them, either re-educate them, or hire
different MIT people. If you hired a group of assemblers
from a remote
South-sea island
who speak
only an obscure dialect of an unknown language, either
learn that language or find a good translator; and get
that safety
program
across to them.
• Just as acceptance criteria and a daily maintenance program for
equipment are important, it is imperative to have initial safety training
for new employees and to schedule regular safety meetings.
Most successful companies would not purchase production equipment without
making sure that it is built to specification, that
it performs properly, and that
it is maintained properly. This involves initial acceptance
criteria, ongoing maintenance, and ongoing performance criteria. In
a similar manner, there
is a well-established confluence of safety, environmental,
and
quality issues (Kanegsberg, Kanegsberg, and Unmack). Effective
production means more than
training workers in performance, worker safety, and
environmental issues. Because
processes are increasingly complex, training by rote
is not enough, we must educate workers both initially and on an on-going
basis.
Unfortunately, some
of the same companies that would never consider running
equipment
and processes without both acceptance and maintenance criteria
consider that “on the
job” or “on the spot” safety training
is a reasonable approach. Bad idea!
Training is only one aspect; because people are complex (have many variables), you have to actually observe your work force. As is the practice in many companies, the company with the nPB exposure issues had an ongoing drug testing program, both prescreening and random testing. A drug testing program may be useful in some instances; and such a program might be considered quantifiable and easier to manage. As a chemist who at one time designed clinical laboratory tests, including drug tests, it is my opinion that, while such testing may have value in some situations, it cannot replace observation, and communication with employees.
If production equipment began to malfunction in a
manner not covered in the Preventive Maintenance
program or
if the process
changed
in a manner
not
covered by normal monitoring, management would
very likely take action. In an analogous
sense, employees may be sober; they may use no
illicit drugs. However, ongoing observation of employee behavior
and communication
with
employees might prompt
suspicions concerning overexposure to industrial
chemicals. For example, higher than expected lost
workdays or
a drop in productivity
during
exposure to a
chemical could be a warning sign. It is important
to take immediate action if an employee appears
to be
intoxicated or starts to
behave haphazardly,
or complains that he or she is “high.” The “high” could
very well be attributable to chemicals in the workplace (or perhaps coming
from a neighboring workplace); the “high” may
not be from a recreational drug.
Perhaps more importantly, we do not want to reach the point of overexposure. Controlling and minimizing exposure to all industrial chemicals is essential to worker safety. In addition, in our experience, reducing chemical loss improves the bottom line and the steps leading to appropriate chemical control tend to go hand in hand with a higher quality product.
In setting up and controlling any industrial process
involving chemicals, it is important to evaluate
the process on a case
by case basis.
I personally cast a jaundiced eye on uncontrolled,
highly emissive uses of any chemical; I prefer
to see solvent
containment that is protective
of both
employees and the environment. In managing
the containment of any solvent for any process,
it
is important to
consider and coordinate the technical,
environmental,
and safety aspects.
In designing process controls, it is important
to consider not just the single employee
but any potential negative
impact of a control on others
in the workplace.
For example, where exhaust fans are employed,
they have to be placed effectively. Placing
fans in
a tandem manner
can
have the undesired effect
of pushing
vapor-laden exhaust air away from one employee
into the breathing zone of other employees.
Then there is the matter of respiratory protection. Engineering controls (where emissions from the process are minimized) are far preferable to employee respiratory protection. However, where respiratory protection is provided, it has to be appropriate to the chemical under consideration. Employees have to understand when it is required, and they have to be trained in how to use it. In some cases, additional personnel monitoring is required. Simply providing the equipment is not adequate. Further, in a number of instances, we have seen workers incorrectly assume that nuisance odor masks will provide protection from chemical vapors.
How do we know what constitutes a high
exposure? We don’t
always know. Monitor all chemicals and
blends, understand what you are using,
how your
process works, and minimize exposure.
Some people, even some safety professionals,
take issue with air sampling when the
exposure level
has not been
firmly
set. We do
not agree with
this attitude,
particularly because new chemicals and
chemical blends are continuously being
introduced.
For many if not
most chemicals
and chemical
blends, inhalation studies have not been
performed. Other safety professionals
and some enforcement
people agree with this more prudent approach,
citing Section 5 or what is
commonly termed the “general duty clause” of the venerable Public Law 91-596.
This section alludes to workplaces that are “free from recognized hazards.” I
think we have to “recognize” that
all industrial chemicals pose potential
hazards, depending
on how they
are used.
As with many halogenated solvents, exposure
studies using animals and cell-culture
(in vitro) studies
are being
conducted on nPB. While agencies
debate an
appropriate exposure limit for nPB,
it would seem reasonable to minimize worker
exposure,
and to document both by analytical
techniques, by process design, and by employee education
that
such exposure
has been minimized.
To reiterate, it would seem unreasonable
to avoid the concept of Section 5 by
adopting process chemicals
or chemical blends
where the worker exposure
profile is not well understood.
Further the prudent employer, when
adopting a new mixture to be used
repeatedly and
in an emissive
manner, would
do well to analyze the level
of all major
components of a mixture. There is
a plethora of new chemicals on the market,
and we
know very little
about
the synergistic
or antagonistic
behavior
of mixtures (This means that, for
a mixture of two chemicals, one plus
one could
add up to greater than or less than
two in terms
of
reactivity,
cleaning ability, performance, or
health impact.) So even if exposure studies
have been
conducted for the pure (neat) chemicals,
it is very likely that exposure studies
have not been done for every blend
of those chemicals.
A few concluding thoughts
Let’s recap the major points.
1. A written safety and health program is essential, but it is not sufficient. To be of value, the safety program must actually be implemented.
2. Information about pertinent health/safety policies and procedures need to be provided to employees in a manner that is clear, definitive, and understandable.
3. Just as acceptance criteria and a daily maintenance program for equipment are important, it is imperative to have initial safety training for new employees and to schedule regular safety meetings.
4. In setting up and controlling any industrial process involving chemicals, it is important to evaluate the process on a case by case basis.
5. How do we know what constitutes a high exposure? We don’t always know. Monitor all chemicals and blends, understand what you are using, how your process works, and minimize exposure.
Environmental regulatory requirements and community environmental justice issues are often greater immediate drivers than are employee safety issues, in part because the inspections may be more frequent and fines may be very high.
Workers, assemblers,
technicians are the valuable
assets of
a company. While “zero
risk” is impossible,
given the availability of
engineering controls and
of well-contained
process equipment, there
is no reason to compromise
worker
safety. If you extract the
essence
of the five safety reminders,
what emerges is:
Understand the process (including the chemicals)
Understand your workforce
Educate your workforce.
These concepts should be familiar to those concerned with enhancing the competitive edge. Indeed, when you implement an employee safety program, you also enhance process control, product quality, and lean manufacturing.
References:
File #305400616, obtained
from the Utah Labor
Commission, Occupational
Safety
and Health
Division, through
a GRAMA request.
Kanegsberg, B., E.
Kanegsberg, and
J. Unmack, “Safety, Environmental,
and Contamination Control,” A2C2
Magazine, March, 2004.
Public Law 91-596,
Occupational
Safety and Health Act
of 1970, section
5, “Duties.”